Child Safety Policy

PART I – PRELIMINARY PROVISIONS

1. Introduction

Welcome to ConsulTOpen.

ConsulTOpen is committed to maintaining a safe, secure, respectful and supportive environment for every User, with the highest level of protection afforded to Minor Users accessing or using the Platform.

This Child Safety Policy ("Policy") establishes the child safeguarding standards, responsibilities, procedures and protective measures adopted by ConsulTOpen to protect Minor Users from abuse, exploitation, neglect, grooming, harassment, violence and every other form of harm that may arise in connection with the Platform.

The safety, dignity, wellbeing and best interests of every Minor User are fundamental priorities of ConsulTOpen.

Accordingly, every User, Parent, Legal Guardian, Consultant, Educational Institution and every other participant using the Platform shares a responsibility to protect Minor Users and to comply with this Policy.

This Policy applies to every interaction involving a Minor User, including without limitation:

• account registration;
• Parent or Legal Guardian consent;
• consultation bookings;
• consultations;
• messaging;
• Artificial Intelligence features;
• profile management;
• payments;
• subscriptions;
• educational services;
• career guidance;
• mental wellness services;
• mentorship programmes;
• community participation;
• future Platform features; and
• every other service offered through the ConsulTOpen Platform.

ConsulTOpen maintains zero tolerance for:

• child abuse;
• child exploitation;
• Child Sexual Abuse Material (CSAM);
• grooming;
• trafficking;
• sexual misconduct involving minors;
• harassment of Minor Users;
• emotional manipulation;
• unlawful collection or misuse of children's personal information;
• violence against Minor Users; and
• every other conduct that threatens the safety or wellbeing of a Minor User.

Every Minor User may access or use Platform services only after valid Parent or Legal Guardian consent has been obtained in accordance with the Parent Consent Policy and applicable law.

Nothing contained in this Policy limits any obligation imposed by applicable law relating to child protection or safeguarding.

This Policy forms an integral part of the legal and operational framework governing the ConsulTOpen Platform.

2. Purpose

The purpose of this Policy is to establish a comprehensive safeguarding framework for every service involving Minor Users on the ConsulTOpen Platform.

Without limitation, this Policy governs:

• child safeguarding standards;
• Parent or Legal Guardian consent requirements;
• consultant eligibility;
• professional boundaries;
• child-safe consultations;
• identity verification;
• age verification;
• safeguarding responsibilities;
• confidentiality involving Minor Users;
• reporting obligations;
• emergency response procedures;
• Artificial Intelligence safety;
• prohibited conduct;
• online safety;
• Platform monitoring;
• investigations;
• disciplinary measures;
• cooperation with authorities; and
• every other matter reasonably connected with protecting Minor Users.

This Policy is intended to:

• protect Minor Users from harm;
• promote child wellbeing;
• establish safe consultation practices;
• support responsible parental involvement;
• maintain professional boundaries;
• encourage responsible digital participation;
• protect Consultants;
• support Educational Institutions;
• strengthen Platform integrity;
• support compliance with applicable laws; and
• foster a safe environment for learning, mentoring and counselling.

3. Scope

This Policy applies to every individual or organisation involved in services relating to Minor Users through the ConsulTOpen Platform.

Without limitation, this Policy applies to:

• Minor Users;
• Parents;
• Legal Guardians;
• Consultants;
• schools;
• colleges;
• universities;
• coaching institutions;
• Educational Institutions;
• corporate organisations conducting programmes involving Minor Users;
• Platform personnel;
• contractors;
• service providers;
• authorised representatives;
• volunteers where applicable;
• beta participants; and
• every future participant using Platform services involving Minor Users.

This Policy applies irrespective of:

• consultation category;
• consultation format;
• subscription plan;
• communication method;
• geographical location;
• language;
• operating system;
• device used;
• payment method;
• Artificial Intelligence features; or
• future Platform technologies introduced by ConsulTOpen.

This Policy applies before, during and after every consultation or interaction involving a Minor User where the relevant conduct relates to the Platform.

Nothing contained herein prevents ConsulTOpen from implementing additional safeguarding measures whenever reasonably necessary to protect a Minor User.

4. Definitions

For the purposes of this Policy:

"Minor User" means any individual below eighteen (18) years of age unless a different definition is required under applicable law.

"Parent" means a biological or adoptive parent having lawful responsibility for a Minor User.

"Legal Guardian" means any individual or entity lawfully authorised to exercise responsibility for a Minor User.

"Consultant" means an individual approved by ConsulTOpen to provide professional services through the Platform.

"Educational Institution" means any school, college, university, coaching institution or other educational organisation facilitating services involving Minor Users.

"Platform" means the ConsulTOpen website, mobile applications, software, Artificial Intelligence systems and every related service operated by ConsulTOpen.

"Consultation" means any interaction between a User and a Consultant conducted through or facilitated by the Platform.

"Child Sexual Abuse Material (CSAM)" means any image, video, recording, document or other material involving the sexual abuse, exploitation or sexual depiction of a Minor User, whether real or digitally created, to the fullest extent recognised under applicable law.

"Grooming" means behaviour intended to establish trust, emotional dependence or inappropriate relationships with a Minor User for exploitative or abusive purposes.

"Artificial Intelligence" or "AI" means any automated technology or intelligent software feature made available through the Platform.

Unless otherwise defined herein, capitalised terms shall have the meanings assigned to them in the Terms & Conditions or other applicable Platform Policies.

5. Applicability

Compliance with this Policy is mandatory for every person using the ConsulTOpen Platform where a Minor User is involved.

Every Minor User shall access or use Platform services only after valid Parent or Legal Guardian consent has been obtained in accordance with the Parent Consent Policy and applicable law.

This Policy applies from the moment:

• a Minor User account is created;
• Parent or Legal Guardian consent is requested;
• a Minor User accesses the Platform;
• consultations involving a Minor User are booked;
• Artificial Intelligence features are used by or for a Minor User;
• Platform communications involving a Minor User occur; or
• any other Platform service involving a Minor User is used.

Failure to comply with this Policy may result in:

• warnings;
• consultation cancellation;
• suspension of Platform features;
• temporary suspension;
• permanent termination of Platform access;
• reporting to competent authorities where required by applicable law;
• preservation of evidence;
• legal proceedings where appropriate; or
• any other lawful action reasonably considered necessary by ConsulTOpen.

6. Child-centred Principle

The safety, dignity, rights and best interests of every Minor User shall be the primary consideration in every decision made under this Policy.

Accordingly, ConsulTOpen shall endeavour to:

• prioritise child safety;
• promote child wellbeing;
• maintain safe consultation environments;
• implement appropriate safeguarding measures;
• minimise foreseeable risks;
• encourage responsible Parent or Legal Guardian participation;
• support lawful child protection practices;
• respect the rights of Minor Users;
• comply with applicable safeguarding obligations; and
• continuously strengthen child protection standards.

Where a conflict arises between commercial convenience and the safety or wellbeing of a Minor User, ConsulTOpen shall prioritise the protection and wellbeing of the Minor User to the fullest extent permitted by applicable law.

7. Relationship with Other Policies

This Child Safety Policy forms an integral part of the legal and operational framework governing the ConsulTOpen Platform.

This Policy shall be read together with:

• Terms & Conditions;
• Privacy Policy;
• Cookie & Data Retention Policy;
• Parent Consent Policy;
• User Code of Conduct;
• Consultant Terms & Conditions;
• Consultant Code of Conduct;
• Consultant Onboarding Handbook;
• Session Standards Policy;
• Refund Policy;
• Payout & Commission Policy;
• AI Usage Disclaimer;
• Recommendation Disclaimer;
• Career Guidance Disclaimer;
• Mental Wellness Disclaimer;
• Intellectual Property Policy;
• Community Guidelines;
• Grievance Redressal Policy; and
• every future Platform Policy published by ConsulTOpen.

Where any inconsistency exists between this Policy and another Platform Policy, the provision providing the greater protection to the Minor User shall prevail unless otherwise required by applicable law.

8. Acceptance

This Child Safety Policy constitutes an electronic record governing child safeguarding standards on the ConsulTOpen Platform.

Every User shall be deemed to have accepted this Policy by:

• accessing the Platform where a Minor User is involved;
• creating an account for or on behalf of a Minor User;
• providing Parent or Legal Guardian consent;
• booking consultations involving a Minor User;
• participating in consultations involving a Minor User;
• using Platform services involving a Minor User; or
• otherwise interacting with a Minor User through the Platform.

Consultants shall be deemed to have accepted this Policy upon:

• completing Consultant onboarding;
• accepting consultations involving Minor Users;
• providing services through the Platform; or
• otherwise participating in services involving Minor Users.

Electronic acceptance of this Policy shall have the same legal validity and enforceability as a handwritten signature to the fullest extent permitted by applicable law.

By accepting this Policy, every participant acknowledges that they have read, understood and agree to comply with the child safeguarding obligations established herein together with every other applicable Platform Policy.

PART II – ACCESS BY MINORS

9. Minimum Age Requirement

ConsulTOpen is committed to protecting Minor Users while ensuring that Platform services are accessed in a safe and responsible manner.

Every individual below eighteen (18) years of age shall be regarded as a Minor User for the purposes of this Policy unless otherwise required by applicable law.

Every Minor User may access or use the ConsulTOpen Platform only after valid Parent or Legal Guardian consent has been obtained in accordance with:

• this Child Safety Policy;
• the Parent Consent Policy; and
• applicable law.

Where valid Parent or Legal Guardian consent has not been obtained, ConsulTOpen may:

• refuse account creation;
• suspend account registration;
• restrict Platform access;
• disable Platform features;
• cancel consultations;
• suspend subscriptions;
• require additional verification; or
• take any other lawful safeguarding measure reasonably necessary.

Nothing contained herein prevents ConsulTOpen from implementing stricter safeguarding measures where reasonably necessary to protect Minor Users.

10. Minor User Accounts

Minor User accounts shall be created, maintained and used only in accordance with applicable Platform Policies.

Without limitation:

• valid Parent or Legal Guardian consent shall be obtained before activation where

required;

• account information shall be accurate;
• identity verification procedures shall be completed where applicable;
• Minor Users shall not impersonate another individual;
• account credentials shall be kept secure;
• Platform access shall be used only for lawful purposes;
• Minor Users shall comply with Platform Policies;
• Parents or Legal Guardians shall cooperate with reasonable safeguarding procedures;

and

• ConsulTOpen may implement additional safeguards for Minor User accounts

whenever reasonably necessary.

Minor User accounts remain subject to ongoing verification throughout their use of the Platform.

11. Parent or Legal Guardian Consent

Valid Parent or Legal Guardian consent is mandatory before a Minor User may access or use Platform services.

Consent shall be obtained in accordance with the Parent Consent Policy and applicable law.

Without limitation, Parent or Legal Guardian consent may be required for:

• account creation;
• consultation bookings;
• subscriptions;
• Artificial Intelligence features;
• messaging;
• educational services;
• career guidance services;
• mental wellness services;
• profile management;
• payments;
• future Platform features; and
• every other service involving a Minor User.

ConsulTOpen reserves the right to verify, refuse, suspend or revoke consent where safeguarding concerns, fraud or legal compliance issues reasonably arise.

12. Parent or Legal Guardian Responsibilities

Parents or Legal Guardians play a central role in protecting Minor Users while they use the Platform.

Accordingly, Parents or Legal Guardians should:

• provide accurate information;
• complete consent procedures honestly;
• supervise Minor Users where appropriate;
• encourage responsible Platform usage;
• protect account credentials;
• cooperate with safeguarding procedures;
• promptly report safety concerns;
• encourage respectful behaviour;
• comply with applicable law;
• comply with Platform Policies; and
• act in the best interests of the Minor User.

Nothing contained herein transfers legal parental responsibilities to ConsulTOpen.

13. Educational Institution Responsibilities

Educational Institutions facilitating services involving Minor Users shall ensure that all necessary permissions, approvals and Parent or Legal Guardian consents required under applicable law have been obtained before facilitating Platform services.

Without limitation, Educational Institutions shall:

• cooperate with safeguarding procedures;
• provide accurate information;
• cooperate with verification procedures;
• support child protection measures;
• encourage responsible Platform usage;
• promptly report safeguarding concerns;
• comply with applicable law;
• comply with Platform Policies; and
• cooperate with ConsulTOpen where reasonably necessary.

ConsulTOpen reserves the right to request reasonable evidence that the necessary permissions have been obtained before providing services involving Minor Users.

14. Identity & Age Verification

ConsulTOpen reserves the right to verify the identity and age of Minor Users, Parents, Legal Guardians and other participants whenever reasonably necessary.

Verification may include:

• OTP verification;
• government-issued identification where reasonably necessary;
• Parent or Legal Guardian verification;
• supporting documentation;
• Educational Institution verification where applicable;
• visual verification where appropriate;
• additional security verification;
• account verification;
• payment verification; and
• any other lawful verification procedure reasonably adopted by ConsulTOpen.

Failure to complete required verification procedures may result in restricted access to Platform services.

15. Age Misrepresentation

No User shall knowingly misrepresent the age of a Minor User or any other participant.

Without limitation, Users shall not:

• falsely claim to be an adult;
• falsely claim to be a Minor User;
• submit false dates of birth;
• provide forged identity documents;
• conceal age information;
• assist another person in misrepresenting age;
• create accounts using inaccurate age information; or
• otherwise deceive ConsulTOpen regarding age.

Age misrepresentation may result in:

• account suspension;
• consultation cancellation;
• termination of Platform access;
• additional verification requirements;
• reporting to competent authorities where required by applicable law; or
• any other lawful safeguarding action reasonably considered necessary by

ConsulTOpen.

PART III – SAFE CONSULTATIONS

16. Child Safety Standards

Every consultation involving a Minor User shall be conducted in a manner that prioritises the safety, dignity, wellbeing and best interests of the Minor User.

Without limitation:

• every consultation shall be conducted professionally;
• Consultants shall maintain appropriate professional boundaries;
• interactions shall remain respectful and age-appropriate;
• safeguarding measures shall be followed at all times;
• Platform Policies relating to Child Safety shall apply throughout the consultation;
• the Minor User's welfare shall remain the primary consideration;
• Users shall cooperate with reasonable safeguarding procedures;
• Parents or Legal Guardians shall cooperate where their participation is required; and
• every participant shall contribute to maintaining a safe consultation environment.

No commercial, operational or personal interest shall override the safety of a Minor User.

17. Consultant Eligibility

Only Consultants approved by ConsulTOpen may provide services involving Minor Users.

Before providing consultations involving Minor Users, Consultants may be required to:

• complete identity verification;
• complete KYC verification;
• accept the Consultant Terms & Conditions;
• accept the Consultant Code of Conduct;
• accept this Child Safety Policy;
• complete Consultant onboarding;
• satisfy professional qualification requirements;
• complete child safeguarding training where required by ConsulTOpen;
• comply with applicable law; and
• satisfy every other eligibility requirement reasonably prescribed by ConsulTOpen.

ConsulTOpen reserves the right to restrict, suspend or prohibit any Consultant from providing services involving Minor Users where safeguarding concerns arise.

18. Child Safeguarding Training

ConsulTOpen may require Consultants to complete child safeguarding education or training before providing consultations involving Minor Users.

Such training may include:

• recognising safeguarding concerns;
• child protection principles;
• appropriate communication with minors;
• professional boundaries;
• recognising grooming behaviour;
• responding to safeguarding disclosures;
• crisis identification;
• emergency escalation procedures;
• confidentiality involving Minor Users;
• applicable legal obligations; and
• every other safeguarding topic considered appropriate by ConsulTOpen.

Failure to complete required safeguarding training may result in ineligibility to provide consultations involving Minor Users.

PART IV – PROHIBITED CONDUCT

19. Parent or Legal Guardian Participation

Parents or Legal Guardians play an important role in safeguarding Minor Users while using the Platform.

Where appropriate or required by applicable law or Platform Policy, Parents or Legal Guardians may:

• book consultations;
• provide consent;
• participate in consultations;
• observe consultations where appropriate;
• communicate with Consultants through authorised Platform channels;
• receive information reasonably necessary to support the Minor User, subject to

applicable law;

• assist with consultation preparation;
• withdraw consent in accordance with the Parent Consent Policy; and
• cooperate with safeguarding procedures.

Nothing contained herein limits the professional judgment of the Consultant or the legal rights of the Minor User under applicable law.

20. One-on-one Consultations

One-on-one consultations involving Minor Users are permitted only where appropriate safeguarding requirements have been satisfied.

Without limitation:

• valid Parent or Legal Guardian consent shall be obtained;
• the Consultant shall be eligible to work with Minor Users;
• consultations shall be conducted exclusively through authorised Platform channels;
• Platform Policies shall continue to apply;
• recording shall remain subject to the Recording Restrictions contained in this Policy;
• safeguarding obligations shall remain in force throughout the consultation;
• Parents or Legal Guardians may participate where appropriate or reasonably

necessary; and

• ConsulTOpen may implement additional safeguards whenever reasonably necessary.

ConsulTOpen reserves the right to suspend or discontinue consultations where safeguarding concerns arise.

21. Safe Communication Standards

Communication involving Minor Users shall remain respectful, age-appropriate and professionally appropriate at all times.

Without limitation, Users and Consultants shall:

• communicate politely;
• use age-appropriate language;
• avoid offensive language;
• avoid inappropriate humour;
• avoid intimidation;
• avoid emotionally manipulative communication;
• encourage respectful discussion;
• avoid discriminatory remarks;
• maintain professional tone; and
• comply with every applicable Platform Policy.

Communication shall never be used to exploit, manipulate or emotionally pressure a Minor User.

22. Appropriate Consultation Environment

Consultations involving Minor Users should take place in an environment that supports privacy, safety and effective communication.

Participants should, where reasonably possible:

• minimise distractions;
• maintain appropriate lighting;
• ensure stable internet connectivity;
• participate from a safe location;
• minimise background noise;
• protect confidential discussions;
• avoid inappropriate surroundings;
• maintain professional behaviour; and
• cooperate with reasonable safeguarding measures.

Users shall avoid participating from environments that may reasonably compromise the safety or wellbeing of a Minor User.

23. Professional Boundaries

Consultants shall maintain appropriate professional boundaries throughout every interaction involving Minor Users.

Without limitation, Consultants shall not:

• encourage emotional dependency;
• establish inappropriate personal relationships;
• request personal favours;
• engage in flirtatious behaviour;
• make inappropriate personal comments;
• seek private meetings outside the Platform;
• encourage secrecy;
• exploit a position of trust;
• provide services outside their professional competence; or
• otherwise compromise professional boundaries.

Maintaining appropriate professional boundaries is essential to safeguarding Minor Users.

24. Confidentiality During Minor Consultations

Consultants shall respect the confidentiality of Minor Users to the fullest extent permitted by applicable law.

Without limitation:

• confidential information shall be protected;
• consultation discussions shall not be unnecessarily disclosed;
• Platform confidentiality requirements shall apply;
• Parents or Legal Guardians shall receive information only where appropriate, lawful or

necessary;

• applicable Privacy Policies shall continue to apply; and
• safeguarding considerations shall always take priority where required.

Confidentiality shall never be interpreted as preventing lawful action necessary to protect a Minor User.

25. Exceptions to Confidentiality

Confidentiality may be limited where disclosure is reasonably necessary to:

• protect a Minor User;
• prevent serious harm;
• respond to an emergency;
• comply with applicable law;
• comply with mandatory reporting obligations;
• comply with court orders;
• cooperate with law enforcement;
• cooperate with child protection authorities;
• investigate safeguarding concerns; or
• otherwise protect the safety, rights or wellbeing of a Minor User.

Where reasonably practicable, disclosures shall be limited to the minimum information necessary for the relevant purpose.

PART V – PROHIBITED CONDUCT

26. Grooming

ConsulTOpen maintains zero tolerance for grooming of Minor Users.

Users and Consultants shall not engage in any conduct intended to build inappropriate trust, emotional dependence or influence over a Minor User for exploitative purposes.

Without limitation, grooming includes:

• establishing inappropriate personal relationships;
• encouraging secrecy;
• isolating a Minor User from trusted adults;
• offering inappropriate gifts;
• manipulating emotions;
• making inappropriate promises;
• repeated personal communication unrelated to consultations;
• attempting to normalise inappropriate behaviour; or
• any similar conduct.

Any suspected grooming may result in immediate suspension and reporting to the appropriate authorities where required by law.

27. Sexual Exploitation

Users shall not engage in any conduct that sexually exploits, encourages the exploitation of or endangers a Minor User.

This prohibition applies regardless of whether the conduct occurs directly, indirectly, online or offline.

28. Sexual Harassment

Users shall not engage in any form of sexual harassment involving Minor Users.

This includes, without limitation:

• sexually explicit language;
• inappropriate comments;
• unwanted advances;
• requests of a sexual nature;
• sexually suggestive communication;
• obscene material; or
• any conduct reasonably considered sexually inappropriate.

29. Abuse

Users shall not engage in physical, emotional, psychological, verbal or any other form of abuse involving Minor Users.

Abusive behaviour is strictly prohibited and may result in immediate removal from the Platform.

30. Emotional Manipulation

Users shall not manipulate, coerce, pressure or emotionally exploit Minor Users.

Without limitation, Users shall not:

• induce guilt;
• create emotional dependency;
• threaten abandonment;
• manipulate decisions;
• pressure a Minor User into secrecy; or
• exploit emotional vulnerability.

31. Requests for Secrecy

No User or Consultant shall encourage a Minor User to keep secrets from a Parent, Legal Guardian or appropriate authority where doing so may compromise the Minor User's safety or wellbeing.

Requests for secrecy intended to conceal inappropriate conduct are strictly prohibited.

32. Exchange of Personal Information

Users and Consultants shall not exchange unnecessary personal information with Minor Users.

Without limitation, prohibited exchanges include:

• personal phone numbers;
• home addresses;
• private email addresses;
• personal social media accounts;
• personal messaging accounts; or
• any other unnecessary personal contact information.

33. Off-platform Communication

Communication with Minor Users shall occur only through authorised ConsulTOpen communication channels unless otherwise expressly authorised by ConsulTOpen or required by applicable law.

Users and Consultants shall not:

• communicate through personal WhatsApp;
• communicate through Telegram;
• communicate through Instagram;
• communicate through personal email;
• communicate through private messaging applications; or
• otherwise bypass authorised Platform communication systems.

34. Gifts, Money & Personal Favours

Users and Consultants shall not:

• offer inappropriate gifts to Minor Users;
• request gifts;
• request money;
• provide financial incentives;
• request personal favours; or
• otherwise establish inappropriate financial or personal relationships with Minor Users.

35. Child Sexual Abuse Material (csam), Child Images & Media

ConsulTOpen maintains zero tolerance for Child Sexual Abuse Material (CSAM) and any exploitative material involving Minor Users.

Users shall not:

• upload;
• store;
• transmit;
• create;
• distribute;
• request;
• access;
• promote; or
• otherwise use CSAM or exploitative material involving minors through the Platform.

Users shall also not upload inappropriate images or videos involving Minor Users that violate applicable law or Platform Policies.

Where CSAM or similar material is detected or reasonably suspected, ConsulTOpen may immediately:

• remove the material;
• suspend or terminate relevant accounts;
• preserve relevant evidence;
• report the matter to law enforcement or competent authorities where required by law;

and

• take every other lawful safeguarding measure considered necessary.

36. Harmful or Illegal Content

Users shall not expose Minor Users to content that is unlawful, harmful, exploitative or otherwise inappropriate.

Without limitation, prohibited content includes:

• obscene material;
• violent content;
• exploitative material;
• illegal drugs;
• criminal instruction;
• self-harm encouragement;
• extremist material; or
• any other content reasonably considered harmful to minors.

37. Violence & Dangerous Behaviour

Users shall not threaten, encourage or engage in violent or dangerous behaviour involving Minor Users.

Where conduct presents an immediate risk to a Minor User, ConsulTOpen may suspend the consultation, restrict Platform access and initiate safeguarding procedures.

PART VI – DIGITAL SAFETY

38. Responsible AI Usage for Minors

Artificial Intelligence ("AI") features made available through the Platform shall be used responsibly, ethically and safely when interacting with or assisting Minor Users.

AI features shall not be intentionally used to:

• generate harmful content;
• generate sexual content involving Minor Users;
• encourage dangerous behaviour;
• facilitate academic dishonesty;
• manipulate Minor Users;
• bypass safeguarding measures;
• harass Users;
• encourage self-harm or violence;
• provide unlawful instructions; or
• otherwise engage in unlawful or unsafe conduct.

Users acknowledge that:

• AI is an assistive technology;
• AI-generated outputs may contain inaccuracies or omissions;
• AI does not replace professional advice;
• AI should not be relied upon during emergencies;
• AI recommendations should be evaluated responsibly; and
• AI usage remains subject to the AI Usage Disclaimer.

ConsulTOpen may suspend, restrict or discontinue AI access where reasonably necessary to protect Minor Users.

39. Online Safety

Users shall take reasonable measures to protect Minor Users while using digital services.

Without limitation, Users should:

• protect login credentials;
• avoid sharing unnecessary personal information;
• report suspicious activity;
• use secure internet connections;
• maintain updated software;
• avoid interacting with suspicious accounts;
• protect Minor Users from phishing attempts;
• protect Minor Users from online scams;
• encourage responsible online behaviour; and
• comply with Platform security requirements.

Online safety is a shared responsibility of Parents, Legal Guardians, Consultants, Minor Users and ConsulTOpen.

40. Privacy Protection

ConsulTOpen is committed to protecting the privacy of every Minor User.

Personal information relating to Minor Users shall be collected, processed, stored, used and disclosed only:

• in accordance with applicable law;
• in accordance with the Privacy Policy;
• for lawful purposes;
• where reasonably necessary for Platform services;
• where appropriate consent has been obtained; or
• where otherwise permitted or required by law.

Every participant shall respect the privacy rights of Minor Users.

41. Platform Monitoring

To protect Minor Users and maintain Platform integrity, ConsulTOpen reserves the right to monitor Platform activity where reasonably necessary.

Monitoring may include:

• account activity;
• consultation activity;
• Platform communications;
• uploaded content;
• reports submitted by Users;
• security events;
• technical logs;
• safeguarding alerts;
• fraud detection activities; and
• any other lawful monitoring reasonably necessary to protect Minor Users.

Monitoring shall be conducted in accordance with applicable law, the Privacy Policy and other applicable Platform Policies.

42. Recording Restrictions

Consultations involving Minor Users shall not be recorded without obtaining every consent required under:

• applicable law;
• the Parent Consent Policy;
• the Session Standards Policy; and
• other applicable Platform Policies.

Unauthorised recording is strictly prohibited.

Where recording is lawfully permitted:

• every required consent shall first be obtained;
• every participant shall be informed that recording is taking place;
• recordings shall remain confidential;
• recordings shall not be publicly distributed without lawful authority; and
• every applicable confidentiality obligation shall continue to apply.

43. Reporting Child Safety Concerns

Every User is encouraged to immediately report any concern relating to the safety or wellbeing of a Minor User.

Reportable concerns include, without limitation:

• grooming;
• abuse;
• exploitation;
• Child Sexual Abuse Material (CSAM);
• harassment;
• inappropriate communication;
• identity concerns;
• threats;
• violence;
• emotional manipulation;
• unlawful conduct; or
• any other safeguarding concern.

Reports should be submitted honestly, promptly and in good faith through the authorised reporting channels provided by ConsulTOpen.

ConsulTOpen shall review safeguarding reports as promptly as reasonably practicable.

44. False Reports

Users shall not knowingly submit false, malicious or fabricated child safeguarding reports.

Without limitation, Users shall not:

• intentionally fabricate allegations;
• misuse safeguarding procedures;
• submit fraudulent complaints;
• harass another User through false reporting;
• retaliate against another participant through false allegations; or
• otherwise abuse the reporting process.

Nothing contained herein shall discourage genuine safeguarding reports made honestly and in good faith, even where an investigation ultimately determines that no Policy violation occurred.

ConsulTOpen shall investigate safeguarding reports fairly, confidentially and in accordance with applicable law.

PART VII – SAFEGUARDING & ENFORCEMENT

45. Mandatory Reporting

ConsulTOpen is committed to complying with applicable child protection laws and safeguarding obligations.

Where a Consultant, User or ConsulTOpen reasonably believes that a Minor User may be experiencing:

• abuse;
• neglect;
• exploitation;
• Child Sexual Abuse Material (CSAM);
• grooming;
• trafficking;
• serious violence;
• imminent danger;
• unlawful activity; or
• any circumstance presenting a significant risk to the safety or wellbeing of a Minor

User,

ConsulTOpen may take appropriate safeguarding action, including reporting the matter to the relevant authorities where authorised or required by applicable law.

Consultants shall comply with every lawful safeguarding and reporting obligation applicable to their profession.

Nothing contained herein prevents any person from immediately contacting emergency services where reasonably necessary to protect a Minor User.

46. Crisis & Emergency Situations

ConsulTOpen is not an emergency response service.

Where a Minor User appears to be experiencing:

• suicidal thoughts;
• self-harm;
• abuse;
• severe psychological distress;
• violence;
• medical emergencies;
• immediate danger;
• trafficking; or
• any other emergency,

Users and Consultants should immediately contact:

• local emergency services;
• the nearest hospital;
• law enforcement authorities;
• Parent or Legal Guardian where appropriate;
• child protection authorities where applicable; or
• another appropriate emergency support service.

Consultants shall not delay emergency intervention where immediate action is reasonably necessary to protect a Minor User.

47. Immediate Safety Measures

Where ConsulTOpen reasonably believes that a Minor User faces an immediate safeguarding risk, ConsulTOpen may immediately implement protective measures.

Such measures may include:

• suspending consultations;
• restricting Platform access;
• temporarily suspending User or Consultant Accounts;
• preventing further communication;
• preserving relevant information;
• initiating safeguarding procedures;
• contacting Parents or Legal Guardians where appropriate;
• contacting emergency responders where appropriate;
• notifying competent authorities where authorised or required by law; and
• taking every other lawful action reasonably necessary to protect the Minor User.

Immediate protective action may be taken without prior notice where delay could increase the risk of harm.

48. Internal Escalation Procedures

ConsulTOpen may maintain internal safeguarding procedures for reviewing and responding to child protection concerns.

Without limitation, safeguarding matters may be escalated for:

• review by authorised personnel;
• identity verification;
• collection of relevant information;
• consultation with appropriate internal teams;
• legal review;
• emergency assessment;
• risk assessment;
• regulatory compliance;
• coordination with competent authorities; and
• implementation of additional safeguarding measures.

Internal safeguarding procedures shall be conducted confidentially to the fullest extent reasonably practicable.

49. Cooperation with Authorities

ConsulTOpen may cooperate with:

• law enforcement agencies;
• child protection authorities;
• judicial authorities;
• regulatory authorities;
• educational institutions where appropriate;
• emergency responders;
• governmental agencies; and
• every other competent authority authorised under applicable law,

where such cooperation is reasonably necessary to:

• protect a Minor User;
• investigate safeguarding concerns;
• prevent unlawful conduct;
• comply with legal obligations;
• respond to lawful requests;
• protect Platform integrity; or
• safeguard public safety.

Nothing contained herein requires disclosure of information except where authorised or required by applicable law.

50. Evidence Preservation

Where ConsulTOpen becomes aware of conduct involving child abuse, exploitation, CSAM or other serious safeguarding concerns, ConsulTOpen may preserve relevant information for lawful investigative purposes.

Without limitation, preserved information may include:

• account information;
• consultation records;
• communication records;
• uploaded content;
• payment records;
• identity verification records;
• technical logs;
• IP address information where lawfully collected;
• device information where lawfully collected; and
• any other information reasonably necessary for safeguarding, legal compliance or

investigation.

Evidence shall be preserved, retained, disclosed and securely handled in accordance with applicable law, the Privacy Policy and internal data governance procedures.

51. Investigations

ConsulTOpen may investigate any suspected violation of this Policy.

Investigations may include:

• review of consultation records;
• review of communications;
• review of uploaded content;
• review of Platform activity;
• identity verification;
• consultation with relevant parties;
• technical analysis;
• safeguarding assessment;
• legal review; and
• any other lawful investigative measure reasonably necessary.

Every User and Consultant shall cooperate honestly with lawful investigations.

52. Corrective Action

Where ConsulTOpen reasonably determines that a violation of this Policy has occurred, appropriate corrective action may be taken.

Corrective action may include:

• educational guidance;
• verbal warnings;
• written warnings;
• mandatory safeguarding training;
• temporary restrictions on Platform features;
• cancellation of consultations;
• removal of content;
• additional verification requirements;
• suspension;
• permanent termination; or
• any other lawful safeguarding measure reasonably considered necessary.

Corrective action shall always be proportionate to the seriousness of the conduct and the risk posed to Minor Users.

53. Suspension

ConsulTOpen reserves the right to immediately suspend any User or Consultant Account where reasonably necessary to protect Minor Users.

Suspension may occur where:

• safeguarding concerns exist;
• grooming is reasonably suspected;
• abuse is reasonably suspected;
• CSAM is identified or reasonably suspected;
• identity verification fails;
• safeguarding obligations are breached;
• unlawful conduct is reasonably suspected;
• Platform security is compromised; or
• continued Platform access presents a material risk to Minor Users.

54. Termination

ConsulTOpen may permanently terminate any User or Consultant Account where continued access to the Platform is inconsistent with the safety, wellbeing or rights of Minor Users.

Termination may occur following:

• confirmed child safety violations;
• grooming;
• child exploitation;
• CSAM;
• repeated safeguarding breaches;
• serious misconduct;
• unlawful activity;
• repeated Policy violations;
• failure to comply with safeguarding requirements; or
• any other conduct reasonably considered incompatible with child safety.

Termination shall not affect any legal rights or obligations accrued before termination.

55. Appeals

Where permitted by ConsulTOpen, Users or Consultants whose Accounts have been suspended or terminated under this Policy may submit an appeal through the authorised grievance or support channels.

Appeals should:

• identify the relevant decision;
• explain the grounds for appeal;
• provide supporting information where available; and
• be submitted within any applicable time period communicated by ConsulTOpen.

Submission of an appeal does not automatically suspend or reverse the original safeguarding decision.

ConsulTOpen shall review appeals fairly, impartially and in accordance with applicable law while ensuring that the safety and best interests of Minor Users remain the primary consideration.

PART VIII – GENERAL PROVISIONS

56. Continuous Improvement

ConsulTOpen is committed to continuously strengthening its child safeguarding framework.

Accordingly, this Policy may be reviewed and improved based upon:

• developments in child protection practices;
• changes in applicable law;
• regulatory guidance;
• judicial decisions;
• technological developments;
• Artificial Intelligence advancements;
• safeguarding best practices;
• Consultant feedback;
• User feedback;
• operational experience;
• audit findings;
• risk assessments; and
• any other factor reasonably relevant to child protection.

57. Policy Amendments

ConsulTOpen reserves the unrestricted right to amend, revise, supplement, replace or update this Child Safety Policy whenever reasonably necessary.

Material amendments may be communicated through:

• Website notices;
• Dashboard notifications;
• Email;
• SMS;
• WhatsApp;
• Push notifications;
• In-app notifications; or
• any other electronic communication channel considered appropriate by ConsulTOpen.

Where reasonably necessary, ConsulTOpen may implement additional safeguarding measures immediately to protect Minor Users.

Continued use of the Platform following the effective date of an amendment shall constitute acceptance of the revised Policy.

58. Severability

If any provision of this Policy is held to be invalid, unlawful or unenforceable by a competent authority, the remaining provisions shall remain valid and enforceable.

Where reasonably possible, the affected provision shall be interpreted or modified to most closely reflect its original safeguarding purpose while remaining legally enforceable.

59. No Waiver

Failure or delay by ConsulTOpen to exercise any right under this Policy shall not constitute a waiver of that right.

Any waiver shall be valid only if expressly made in writing by an authorised representative of ConsulTOpen.

60. Relationship with Other Policies

This Child Safety Policy forms an integral part of the legal and operational framework governing the ConsulTOpen Platform.

This Policy shall be read together with:

• Terms & Conditions;
• Privacy Policy;
• Cookie & Data Retention Policy;
• Parent Consent Policy;
• User Code of Conduct;
• Consultant Terms & Conditions;
• Consultant Code of Conduct;
• Consultant Onboarding Handbook;
• Session Standards Policy;
• Refund Policy;
• Payout & Commission Policy;
• AI Usage Disclaimer;
• Recommendation Disclaimer;
• Career Guidance Disclaimer;
• Mental Wellness Disclaimer;
• Intellectual Property Policy;
• Community Guidelines;
• Grievance Redressal Policy; and
• every future Platform Policy published by ConsulTOpen.

Where any inconsistency exists between this Policy and another Platform Policy, the provision providing the greater protection to Minor Users shall prevail unless otherwise required by applicable law.

61. Contact Information

For child safety concerns, safeguarding reports, complaints or questions relating to this Policy, Users may contact ConsulTOpen through the following authorised channels:

Support Email: support@consultopen.com

Legal Email: consultopen1@gmail.com

Founder & Grievance Officer: Abhinav Saini

Official Email: abhinav@consultopen.com

Contact Number: +91 9717972908

Registered Office:

House No. 20, First Floor, Khasra No. 630, Pahari Colony, Ghitorni Enclave, New Delhi – 110030, India

Official Website:

https://consultopen.com

ConsulTOpen shall use commercially reasonable efforts to review child safety communications as promptly as reasonably practicable, recognising that safeguarding concerns may require immediate attention.

62. Effective Date

This Child Safety Policy shall become effective on the Effective Date specified in the Document Control section.

By accessing, using, administering or participating in any ConsulTOpen service involving a Minor User, every User, Parent, Legal Guardian, Consultant, Educational Institution and other relevant participant acknowledges that they have read, understood and agree to comply with this Child Safety Policy together with every other applicable Platform Policy.

Nothing contained in this Policy shall limit any rights, obligations or remedies available under applicable law or under any other binding agreement between the relevant participant and ConsulTOpen.