Legal
Child Safety Standards
Application
Free to call
Child Safety Standards
Application: Free to Call (the “App”)
Developer / Operator:
Invicta Solutions, s.r.o.
Pod Jiráskovou čtvrtí 752/14, 147 00 Praha 4 – Braník, Czech Republic
Company ID (IČO): 21341303
VAT ID (DIČ): CZ21341303
Registered in the Commercial Register maintained by the Municipal Court in Prague
Contact e-mail: info@invictas.cz
Contact phone: +420 730 842 100
Last updated: 21 April 2026
Version: 1.0
Invicta Solutions, s.r.o. (“Invicta Solutions”, “we”, “us”, “our”), as the developer and operator of the Free to Call mobile application (“Free to Call” or the “App”), maintains a zero-tolerance policy toward child sexual abuse and exploitation (“CSAE”) and child sexual abuse material (“CSAM”). This document describes the standards, safeguards, and reporting mechanisms we apply to protect minors on the App, in compliance with the Google Play Child Safety Standards policy.
1. Our commitment
- Free to Call is a communication application developed and operated by Invicta Solutions. We are committed to providing a safe environment for all users and to preventing the misuse of the App in any way that endangers children.
- We have zero tolerance for CSAE and CSAM. Any content, behavior, account, or activity that sexually exploits, endangers, or grooms a minor is strictly forbidden on the App.
- These Child Safety Standards apply to all users of the App and form an integral part of our Terms of Service.
2. Prohibited conduct
The following is strictly prohibited on Free to Call and will result in immediate account termination and, where legally required, reporting to the relevant authorities:
- Creating, uploading, sharing, requesting, promoting, or otherwise distributing CSAM in any form (images, videos, audio, text, links, or generated content).
- Sexual solicitation, grooming, sextortion, or any attempt to contact a minor for sexual purposes.
- Engaging in, encouraging, or facilitating the sexual exploitation, abuse, or trafficking of minors.
- Exposing minors to sexual content, sexually suggestive material, or adult content.
- Sharing personally identifiable information of a minor in a manner that could enable contact by predators or otherwise endanger the minor.
- Impersonating a minor with the intent to deceive or harm other users, or impersonating another user to contact a minor.
- Use of the App by any person who does not meet the minimum age requirement set out in our Terms of Service.
Accounts found to be in violation of these standards will be terminated without prior notice, the content will be preserved for investigative purposes to the extent required by law, and the matter will be reported to the competent authorities.
3. Compliance with laws
We operate in full compliance with all applicable child-safety and online-safety laws and regulations, including but not limited to:
- 18 U.S.C. § 2258A — mandatory reporting of apparent CSAM to the U.S. National Center for Missing & Exploited Children (“NCMEC”) via the CyberTipline, where we are subject to U.S. reporting obligations;
- Regulation (EU) 2022/2065 — Digital Services Act (DSA), including the obligation under Article 18 to notify competent authorities of information indicating serious criminal offences involving a threat to the life or safety of a person;
- Regulation (EU) 2024/1689 — the EU AI Act, insofar as applicable;
- Directive 2011/93/EU of the European Parliament and of the Council on combating the sexual abuse and sexual exploitation of children and child pornography;
- Act No. 40/2009 Coll., the Czech Criminal Code, in particular provisions penalizing the production and distribution of child pornography (§ 192–193) and the abuse of a child for the production of pornography;
- Act No. 110/2019 Coll. (Czech GDPR adaptation act) and Regulation (EU) 2016/679 (GDPR), which govern any processing of personal data undertaken in connection with reports or investigations;
- any further national implementing legislation in the jurisdictions where the App is made available.
Where a conflict exists between these Child Safety Standards and mandatory local law, the stricter standard applies.
4. In-app reporting mechanism
Users can report CSAE, CSAM, or any abusive behavior directly to us through multiple channels:
- In-app report: open the App and navigate to Settings → Report a problem → Report abuse / child safety. The form lets the reporter describe the incident, identify the offending user or content, and attach evidence where available.
- Long-press on a message or user profile inside a conversation and select “Report”, then choose the category “Child safety / CSAM”.
- E-mail: reports may also be submitted at any time to childsafety@invictas.cz.
Reports concerning child safety are triaged with priority over other report types. We commit to:
- acknowledging receipt of every child-safety report promptly;
- reviewing the report as soon as reasonably possible, and in any event without undue delay;
- taking appropriate action, which may include content removal, account suspension or termination, preservation of evidence, and notification of law-enforcement authorities or NCMEC;
- protecting the confidentiality of reporters to the extent permitted by law.
Reporters are never required to investigate or confront a suspected offender themselves — reporting to us (or directly to law enforcement in an emergency) is sufficient.
5. Handling CSAM
If CSAM is identified on Free to Call — whether through a user report, proactive detection, or otherwise — we apply the following procedure:
- Immediate removal. The offending content is removed from the App as soon as it is identified.
- Account termination. The account responsible for uploading, sharing, or requesting the content is terminated without notice. Associated accounts linked by shared identifiers may also be terminated.
- Evidence preservation. The content, associated metadata, and account information are preserved in a secure manner for the period required by applicable law, so that they can be provided to competent authorities.
- Reporting to authorities. We report the incident to the National Center for Missing & Exploited Children (NCMEC) via the CyberTipline where required under U.S. law, and/or to the Czech Police (Policie České republiky) and any other competent national or EU authority, in accordance with applicable legal obligations.
- Cooperation with investigators. We cooperate with lawful requests from law enforcement and child-protection authorities, including the preservation and disclosure of data as permitted by applicable law.
- Review and prevention. Each incident informs our prevention measures — including detection heuristics, moderation workflows, and user-education materials — so that we continually reduce the risk of recurrence.
We do not use CSAM for any purpose other than the minimum handling required to remove it, report it, and cooperate with authorities.
6. Child Safety Point of Contact
We have designated a point of contact responsible for child-safety compliance at Invicta Solutions. This person can be reached to discuss our CSAM-prevention practices, handle escalations from trust-and-safety partners, and respond to inquiries from platforms, regulators, and law enforcement.
- Name: Matyáš Pšenička
- Role: Child Safety Officer, Invicta Solutions, s.r.o.
- E-mail: childsafety@invictas.cz
- Postal address: Invicta Solutions, s.r.o., Pod Jiráskovou čtvrtí 752/14, 147 00 Praha 4 – Braník, Czech Republic
For urgent matters involving an imminent threat to a child, contact your local emergency services (in the Czech Republic: 158 for the Police, 112 for EU-wide emergency) before contacting us.
7. Changes to these standards
We may update these Child Safety Standards from time to time to reflect changes in our practices, applicable law, or platform-policy requirements. The “Last updated” date at the top of this document indicates when the latest changes took effect. Material changes will be communicated in the App or by other reasonable means.