EU Regulation 2021/1232 disclosure

EU Regulation 2021/1232 ("temporary derogation from the ePrivacy Directive") allows providers of certain interpersonal communication services to voluntarily detect, report, and remove online child sexual abuse material (CSAM) and to detect solicitation of children. It is an opt-in legal basis — providers must explicitly disclose if they use it.

What we do

Bluumme does not currently use the voluntary derogation under Regulation (EU) 2021/1232.

Concretely:

• We do not operate any automated CSAM hash-matching system on private messages (DMs).
• We do not scan the textual content of private messages for grooming patterns.
• We do not rely on the Article 3(1) derogation as a legal basis for processing message content.

Why this disclosure exists

Even though we don't use the derogation, EU users have a right to know whether a service does — Apple, Google and EU regulators expect transparency on this point in app submissions.

What we do do for safety

• User-driven reporting. Every post, comment and DM has a Report button. Reports go to a human reviewer (currently the founder, Emir Atay) and are actioned within 24 hours.
• Account suspension and removal for users who post or share child sexual abuse material, as required under Article 6 of the EU Digital Services Act (DSA).
• Mandatory reporting to authorities. Where a report involves apparent CSAM, the content is preserved and reported to the German Bundeskriminalamt (BKA) and to NCMEC where required.
• No persistent storage of plaintext DMs beyond what is needed to deliver them. Server-side text content of private messages is retained only for delivery and abuse-investigation purposes, and is deleted in line with our Privacy Policy.

When this might change

If Bluumme ever introduces automated CSAM detection (for example by integrating Apple's PhotoDNA or a similar industry-standard tool), this page and our Privacy Policy will be updated before activation, and EU users will be notified in-app. Until then, the statement above is the canonical answer.

Contact

Questions about this disclosure or about a specific moderation decision: hello@bluumme.com.

For child safety concerns specifically (e.g. you believe content involving a minor is hosted on Bluumme), please mark the email subject "CHILD SAFETY" so it is escalated immediately.

Last updated: 14 May 2026