Effective Date: 09/01/2025
LinkSouls.AI ("we," "us," or "our") is committed to prohibiting all individuals under the age of 18 (collectively, "Minors") from accessing or using our AI-powered emotional companionship platform (the "Services"). We strictly adhere to laws and regulations governing minors’ protection and age-appropriate service access, including the General Data Protection Regulation (GDPR) (EU), the Children’s Online Privacy Protection Act (COPPA) (U.S.), and other applicable regional laws.
This policy outlines our measures to prevent Minors from using the Services, eliminate accidental collection of Minors’ personal data, and ensure full compliance with the "no Minors access" rule.
1. Age Restrictions
- Minimum Age Requirement: The Services are explicitly not intended for, and we strictly prohibit, any individual under the age of 18 from accessing, registering for, or using the Services—regardless of whether parental or legal guardian consent is provided. This prohibition applies globally.
- User Representation and Warranty: By accessing or attempting to use the Services, you irrevocably represent and warrant that you are at least 18 years old. Providing false information about your age constitutes a material breach of this policy and our Terms of Service.
2. Prevention of Underage Access
To enforce the "no Minors access" rule, we implement multi-layered, risk-based measures to prevent Minors from accessing the Services:
2.1 Mandatory Age Verification at Registration:
During account creation, users must confirm they are 18 years of age or older and provide their age range.
- Logic Checks: Automatically rejecting registrations where the selected age range indicates the user is under 18.
- Enhanced Verification (Future): We reserve the right to implement additional verification (e.g., third-party age verification services) for accounts flagged for suspicious activity.
- No "Parental Consent" Workaround: We do not offer any "parental consent" option to bypass the age verification — all users must independently confirm they meet the 18+ requirement.
2.2 Content Age Gates:
All features of the Services are locked behind the 18+ age verification. There are no "Minor-friendly" features, as the entire Services are designed for adult users.
2.3 Monitoring for Underage Use:
Our monitoring focuses on account-level data and user reports, not on scanning your private conversations. This includes:
- Account Data Analysis: Flagging accounts with suspicious registration information (e.g., an email address that clearly indicates a minor).
- User Report Integration: Prioritizing reviews of accounts reported by other users or parents as "likely Minors." This is our primary detection method.
3. Protection of Minor Data
We do not intentionally collect or process any personal data of Minors (under 18). Our "Privacy Vault" architecture (client-side encryption) means we do not have access to or store any `Interaction Data` (conversation history), `user set Core Memories`, or `Dynamic Memory Log` from any user, including any Minor who may have bypassed our age-gate.
If we confirm that an account is being used by a Minor, we will execute our Minor Data Emergency Removal Protocol:
- Immediate Account Termination: We will permanently terminate the Minor’s account to prevent all future access to our Services.
- Server-Side Data Deletion: We will immediately and permanently delete all data associated with that account that is stored on our servers. This is strictly limited to their core Account Information (e.g., email address, age range, and subscription status).
- Client-Side Data (Beyond Our Control): We have no technical ability to delete the data stored on the Minor's own device. This includes their encrypted conversation history, `Core Memories`, and `Dynamic Memory Log`. The termination of the account will render this data inaccessible, but it will only be permanently lost if the app is deleted from the device.
4. Content Safety for Minors
Since the Services are exclusively for adults, our safety measures are designed to prevent Minors from accessing the platform, rather than monitoring their content.
- AI Safety Guardrails: Our AI agents are programmed at a foundational level (via their System Instruction) to refuse the generation of illegal, harmful, or sexually explicit content, in line with our Content Policy.
- No Content Monitoring: We do not scan, filter, or read your private conversations for inappropriate topics. Our "Privacy Vault" architecture makes this technically impossible.
- Reporting Underage Exposure: Users or parents who believe a Minor has gained access to the Services must report it immediately using our Complaint & Content Removal Policy process.
5. Parental Rights and Controls
Since Minors are prohibited from using the Services, we do not grant parents "usage-related rights" (e.g., consent for Minors’ access). Instead, we encourage parents to assist in enforcing the "no Minors access" rule:
- Reporting Minor Use: Parents or legal guardians who discover their Minor child has accessed or attempted to use the Services may report this to us at `vip_service@linksouls.com`, providing:
- Proof of guardianship (e.g., birth certificate, legal guardianship document);
- Details of the Minor’s potential account (e.g., email address, device information);
- We will verify the report within 48 hours and initiate the Minor Data Emergency Removal Protocol (see Section 3) if confirmed.
- Preventing Minor Access at Home: Parents are responsible for monitoring their Minors’ online activities and preventing them from accessing adult-oriented platforms like the Services (e.g., using parental control tools on home devices).
- No Liability for Parental Negligence: We are not liable for Minors’ unauthorized access to the Services resulting from parental failure to implement reasonable monitoring or control measures.
6. Enforcement
We enforce the "no Minors access" rule with strict, consistent measures to deter violations:
- Immediate Account Termination for Minors: Upon confirming an account belongs to a Minor, we will terminate the account immediately—without prior warning—and delete all associated server-side data (see Section 3). No appeals will be accepted for minor accounts.
- Permanent Ban for Age Misrepresentation: Users who provide false age information (e.g., fake age range) to bypass verification will have their accounts permanently terminated—with no option to create a new account in the future.
7. Compliance with Laws
Our "no Minors access" policy is designed to comply with global and regional laws governing Minors’ protection and adult-oriented services:
- COPPA (U.S.): We extend COPPA’s protections (originally for under-13s) to all Minors under 18, prohibiting any data collection from this group and ensuring no Minors can use the Services—exceeding COPPA’s statutory requirements.
- GDPR (EU): We comply with GDPR Article 8 (Special Protection for Minors’ Data) by prohibiting the collection of Minors’ data and implementing immediate deletion protocols for server-side data.
- Regional Laws: We align with the principles of laws such as the German Youth Protection Act, the UK Age Appropriate Design Code, and Australia’s Privacy Act by implementing strict age-gating to prevent Minors from accessing our adult-oriented Services.
8. Changes to This Policy
We may update this Minors Access Restriction Policy to reflect legal changes or improvements to our protection measures. Material updates will be posted on our website with an updated "Effective Date."
9. Contact Us
For questions about this policy or to report underage use, contact our Child Protection Team at:
LinkSouls.AI
c/o Viswise Consulting Limited
Room 2705, 27th Floor, China Resources Building, 26 Harbour Road, Wan Chai, Hong Kong
Email: `vip_service@linksouls.com`