CHILD SAFETY AND WELLBEING POLICY

Effective from August 30, 2025

 

  1.                   INTRODUCTION
    1.             This Child Safety and Wellbeing Policy (hereinafter referred to as the Policy) declares that the owner of the SENS mobile app and (or) the web version of the SENS app (hereinafter referred to as the Service) specified in clause 1.8 of the Public Agreement (hereinafter referred to as the Owner) prioritizes the safety and wellbeing of minors (children) (hereinafter referred to as the Child or Children) and describes the mechanisms and solutions applied to achieve this goal.
    2.             This Policy applies to all and any employees of the Owner and (or) its contractors whose activities associated with the Service, as well as all and any Users of the Service, including, but not limited to, Users who do not meet the requirements of the Public Agreement, who have gained access to the functions and (or) content of the Service in violation of the established rules.
    3.             The Service, according to clause 3.1.2 of the Public Agreement, is not intended for and is prohibited from use by Children.
    4.             Despite the circumstances set out in clause 1.3 of this Policy, the Owner prioritizes Child safety and shall take measures provided for by this Policy and (or) applicable law when anyone raises concerns about child safety related to the use of the Service. The Owner will maintain and model a culture of Child safety in the course of ensuring the operation and (or) use of the Service.
    5.             The Owner encourages all and any Users and other persons related to the operation and /or use of the Service to report issues related to the Child safety.
  2.                   TERMS AND DEFINITIONS
    1.             The following terms and definitions are used in this Policy:
      1.       Child (Children) – a person(s) who has (have) not reached the age of majority (18 years), with the exception of cases of emancipation (a minor obtaining full legal capacity in the manner prescribed by applicable law);
      2.       Inappropriate treatment of Children means:
  1.                  a sexual offence, including an act of a sexual nature committed against a Child;
  2.               any other crime committed against a Child in accordance with the applicable criminal law;
  3.             physical violence against a Child;
  4.             causing serious emotional and (or) psychological harm to a Child;
    1.       Harm – damage to the health, safety and (or) wellbeing of a Child, including as a result of Inappropriate treatment by adults or by other Children. Harm includes and implies equally physical, moral, sexual and (or) psychological harm. Harm may be the result of a single action or event, or it may also be cumulative, that is, it may occur as a result of a series of actions or events over a certain period of time;
    2.       Incident – any action and (or) inaction that may potentially negatively affect the safety and wellbeing of Children, including Inappropriate treatment of Children;
    3.       Complaint – any statement made by a User and (or) another person made in the manner prescribed by this Policy, related to the Inappropriate treatment of Children and one or more of the following issues:
  1.                  the operation of the Service and (or) its functions;
  2.               content posted on the Internet using the Service;
  3.             the Inappropriate treatment of Children by the Owner;
  4.             the Inappropriate treatment of Children by a User, including, Users who do not meet the requirements of the Public Agreement, who have gained access to the functions and (or) content of the Service in violation of the established rules;
  5.                the registration and (or) authorization of a Child as a User;
  6.             the incorrect solution of a previously raised issue related to an Incident;
  7.           general concern regarding Child safety.
    1.             All other terms that are not provided for in this Policy are used in the meaning provided for in the Public Agreement or Privacy Policy.
    2.             Unless otherwise provided by this Policy, the Public Agreement or the Privacy Policy, the interpretation of terms shall be carried out in accordance with the current legislation and common practice.
  1.                   THE ROLE OF THE OWNER
    1.             The Owner and its team responsible for developing and maintaining the Service are responsible for creating and maintaining a strong culture of Child safety, as well as for effective development and implementation of this Policy and practical actions in accordance with applicable legislation and global practice.
    2.             The Owner is obligated to:
      1.       ensure effective management of the safety and wellbeing of Children, including the development and implementation of this Policy and applicable procedures and practices under it;
      2.       model a culture of Child safety that encourages the active participation of Users in ensuring Child safety;
      3.       reinforce high standards of respectful behavior between Users;
      4.       facilitate regular professional training for the Owner's employees and (or) other members of the team responsible for developing and maintaining the Service, in order to deepen their understanding of Child safety and cultural safety issues, as well as the prevention of and response to Inappropriate treatment of Children;
      5.       create and provide an environment and functionality within the Service that allows for the submission of a Complaint and (or) other concerns regarding Child safety and wellbeing;
      6.       conduct a risk assessment related to the Child safety and wellbeing, based on the results of which applicable methods and practices under this Policy shall be supplemented and (or) amended;
      7.       report Incidents to local law enforcement agencies in cases where the relevant Incident raises concerns and (or) assumptions about the existence of elements of a crime in accordance with applicable law, immediately;
      8.       respond to Complaints in a timely manner.
    3.             The owner appoints a person responsible for the safety and wellbeing of Children: [position, contact e-mail] (hereinafter referred to as the Responsible Person).
    4.             The Responsible Person independently and (or) with the support of the Owner's legal service:
      1.       is the first person to be contacted for Child safety issues and coordination of responses to Child safety Incidents.
      2.       handles Complaints and (or) other requests concerning the Child safety and (or) wellbeing;
      3.       develops and implements this Policy;
      4.       makes proposals for amendments and (or) additions to this Policy;
      5.       manages the Owner's employees who moderate content posted on the Internet using the Service, and gives mandatory instructions regarding ensuring the Child safety and (or) wellbeing;
      6.       is responsible for monitoring the Owner's compliance with this Policy. Any member of the Owner's team must contact the Responsible Person if they have any doubts about the Owner's compliance with this Policy;
      7.       is responsible for informing Users about this Policy and bringing it to the attention of Users and (or) other persons planning to use the Service.
    5.             The Owner undertakes to review this Policy at least once a year.
  2.                   SUBMISSION OF COMPLAINTS AND REQUESTS
    1.             Users, employees of the Owner and (or) other persons who have any concerns regarding the Child safety and (or) wellbeing associated with the operation and (or) use of the Service may at any time submit Complaints and (or) other requests, including questions, suggestions, and feedback, to the contact email address of the Responsible Person specified in clause 3.3 of this Policy.
    2.             All complaints related to the Inappropriate treatment of Children and (or) other requests related to Child safety will be treated seriously, regardless of whether they come from a User, an employee of the Owner, or another person, an adult or a Child, and whether they concern the behavior of an adult or a Child. All complaints and issues related to Child safety will receive an immediate and thorough response.
    3.             The response time for Complaints and (or) other requests regarding the Child safety and wellbeing received by the Owner shall not exceed 10 (ten) calendar days. This period may be extended, but for no more than 30 (thirty) calendar days, if additional investigation is required.
    4.             If the information contained in the Complaint suggests that the Incident described contains elements of a crime in accordance with applicable law, the Owner undertakes to submit the Complaint to local law enforcement agencies immediately.
    5.             If a User is found to be in violation of the Public Agreement or the Privacy Policy regarding the Child safety and wellbeing, as well as this Policy and (or) applicable law in this area, the Owner has the right to immediately, without prior notice and (or) consent, suspend and (or) delete such User's account and (or) content posted by them at its own discretion and assessment.
    6.             All Complaints and (or) other requests related to Child safety, Incidents, and information about Harm caused to Children shall be recorded in the Owner's internal incident reporting system. All information, data, and other content that may assist in an investigation based on a Complaint shall be retained as part of the investigation record. Such information shall be retained even if the investigation does not confirm the details reflected in the Complaint. The retention period for such information is 10 (ten) years from the date of recording the last information, data, content and (or) actions taken in connection with the Complaint.
    7.             The Owner undertakes to ensure the confidentiality of information about Complaints, except in cases where this is necessary for the proper response to a Complaint or for prioritizing Child safety. The Owner may need to provide information about Incidents or Complaints to external authorities to comply with the law or to ensure the prioritization of safety.