Safety & Child Protection Policy

Effective Date: [EFFECTIVE DATE] Last Updated: [LAST UPDATED] Version: 2.0

KidStarter's highest priority is the safety and wellbeing of children. This Policy applies globally to all Users and all content on the Service. It forms part of the Agreement (see Terms of Service).

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1. Core Safety Rules (All Markets)

1.1 No Identifying Information for Minors

Public content must not include any of the following for minors:

• Full last names;
• Home addresses, GPS coordinates, or directions;
• Phone numbers, personal email addresses, or instant messaging handles;
• Social media handles or usernames;
• Government-issued ID numbers (SSN, NIN, SIN, passport);
• School ID numbers or student numbers;
• Medical, psychological, or behavioral health information;
• Disciplinary or academic records;
• Class rosters, bus routes, or extracurricular schedules;
• Financial details about the student's family;
• Any combination of information that, taken together, could reasonably identify or locate the child.

1.2 No School Location Disclosure by Default

For Campaigns involving minors, the following are prohibited by default unless explicitly approved under a safety review with documented consent from both the guardian and the school:

• School name;
• School logo;
• School address;
• Campus photographs showing identifiable features;
• District-level identifiers that narrow location beyond the broad region.

1.3 Safe Images

• Preferred: Head-and-shoulders images, or images with neutral backgrounds.
• Avoid: Backgrounds showing classroom boards, rosters, name badges, student work with names, documents, mail, street signage, school signage, vehicles with license plates, or uniforms with visible school names.
• Platform Controls: KidStarter may: (a) blur or remove backgrounds automatically or manually; (b) crop images; (c) offer avatar or cartoonization options; (d) reject images that pose safety risks.
• No Exploitation: Images must not sexualize, objectify, degrade, or exploit minors in any way.

1.4 Prohibited Content — Zero Tolerance

The following are immediately removed and escalated to authorities:

• Child Sexual Abuse Material (CSAM): Any sexual or sexually suggestive content involving minors.
• Grooming: Any attempt to build a relationship with a minor for exploitation.
• Solicitation: Any request for direct contact with a minor, personal information from a minor, or private communication with a minor.
• Physical Abuse Content: Images or descriptions of physical abuse, severe punishment, or torture of minors.

1.5 Content Involving Distress

Campaign stories should focus on the educational need and positive impact, not on exploiting or sensationalizing a child's suffering, poverty, disability, or personal circumstances. KidStarter may edit or reject content that we determine could cause harm or distress to the Student if they were to see it.

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2. Platform Controls

KidStarter implements multiple layers of safety controls:

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3. Reporting

3.1 Report Safety Concerns

If you believe any content on the Service may endanger a child, or if you have any child safety concern, report it immediately:

• In-App: "Report" button on any Campaign, comment, or profile
• Email: [REPORT LINK OR EMAIL] — use subject line "URGENT: CHILD SAFETY" for immediate attention
• Phone (if available): [SAFETY HOTLINE, if applicable]

3.2 Emergency

If a child is in immediate danger, contact your local emergency services first (e.g., 911 in the US, 999 in the UK, 112 in the EU), then notify KidStarter.

3.3 Response Times

• Child safety reports: Triaged within 4 hours during business hours; as soon as reasonably possible outside business hours.
• Content removal for child safety: Immediate upon confirmation of risk; review occurs before reinstatement, not before removal.

3.4 Whistleblower Protections

KidStarter will not retaliate against any User or employee who reports a child safety concern in good faith. Reports may be made anonymously.

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4. Mandatory Reporting

4.1. KidStarter complies with all applicable mandatory reporting laws regarding child abuse, neglect, and exploitation.

4.2. Where KidStarter becomes aware of CSAM or has reasonable suspicion of child abuse or exploitation:

• US: We report to the National Center for Missing & Exploited Children (NCMEC) via CyberTipline and, where required, to local law enforcement.
• UK: We report to the Internet Watch Foundation (IWF), the National Crime Agency (NCA), and/or local police safeguarding teams.
• EU/EEA: We report to the relevant national authority (e.g., Europol, national hotlines under the INHOPE network) and cooperate with cross-border investigations.
• Canada: We report to the Canadian Centre for Child Protection and/or local police.

4.3. KidStarter preserves relevant data and evidence for law enforcement purposes in accordance with legal hold procedures.

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5. Regional Notes

5.1 United Kingdom

• We apply high-privacy defaults and age-appropriate design principles aligned with the ICO Children's Code (Age Appropriate Design Code).
• We comply with the UK Online Safety Act obligations as applicable, including duty of care to protect children from harmful content.
• We follow Department for Education (DfE) guidance on safeguarding children in educational settings.
• Staff handling child-related content undergo DBS checks or equivalent where required.

5.2 EU/EEA

• We follow GDPR data minimization, purpose limitation, and privacy-by-design principles.
• We comply with applicable national implementations of the Audiovisual Media Services Directive (AVMSD) and the Digital Services Act (DSA) regarding the protection of minors online.
• We conduct Data Protection Impact Assessments (DPIAs) for high-risk processing involving children's data.
• Where age of digital consent applies, we enforce the relevant threshold (13–16 depending on Member State).

5.3 United States

• We design the Service so verified adults manage Campaigns — children do not interact directly with the Service.
• If we obtain actual knowledge of collecting personal information directly from children under 13, we apply COPPA-aligned parental notice and verifiable consent, and provide parents with access and deletion rights.
• We comply with applicable state child privacy laws, including California's AADC (AB 2273) and similar legislation.
• We report CSAM to NCMEC as required under 18 U.S.C. § 2258A.

5.4 Canada

• We follow PIPEDA meaningful consent and reasonable-purpose principles.
• We provide guardian access, correction, and deletion pathways.
• We comply with provincial child welfare reporting obligations.
• We report child exploitation material to the Canadian Centre for Child Protection.

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6. Staff and Volunteer Safety Standards

6.1. All KidStarter staff and contractors who have access to Campaign content involving minors, private Student data, or moderation functions are subject to:

• background checks as permitted by applicable law;
• mandatory child safety training (initial and annual refresher);
• code of conduct requirements;
• confidentiality and data protection obligations.

6.2. Staff who violate child safety policies are subject to immediate disciplinary action, up to and including termination and reporting to authorities.

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7. Enforcement

7.1. Violations of this Policy may result in:

• Immediate content removal;
• Campaign pause or permanent removal;
• Account suspension or permanent ban;
• Forfeiture of undisbursed funds;
• Reporting to payment processors;
• Reporting to law enforcement and child protection authorities;
• Preservation of evidence for legal proceedings.

7.2. For child exploitation and grooming violations, enforcement is immediate and permanent with no warning and no appeal.

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8. Policy Review

This Policy is reviewed at least annually and updated to reflect changes in law, regulation, technology, and best practices. Material changes are communicated to Users.

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9. Contact

Safety Reports: [REPORT LINK OR EMAIL] Privacy Inquiries: [PRIVACY EMAIL] General Support: [SUPPORT EMAIL]