Child Safety Standards

This policy sets out our zero-tolerance commitment to preventing and responding to any form of child sexual abuse and exploitation (CSAE) through or on the BantuSphere Super App (the "App"), including the Dating feature.

It applies to:

• All users of the App (regardless of age or location)
• All content uploaded, shared, transmitted, stored or accessed via the App and related infrastructure
• All behaviour, communications and interactions within the App, whether in private messages, public postings or any user-generated content

We are committed to compliance with – and often exceeding – global regulatory obligations, industry best-practice (including those of Google Play's Child Safety Standards) and applicable laws in the jurisdictions where we operate (including but not limited to the UK, Zimbabwe, EU/EEA).

We strictly prohibit the use of the App for any CSAE-related purpose. This includes, without limitation:

• Creation, possession, distribution, transmission or sharing of CSAM
• Grooming of minors for sexual purposes
• Sextortion involving children
• Trafficking or facilitating trafficking of minors for sexual purposes
• Depicting or encouraging minors in sexualised contexts (including via AI-generated content)

Any user who violates this policy is subject to immediate suspension or termination of account, removal of offending content, and, where appropriate, referral to law enforcement or child-protection authorities.

We adopt the higher standard where there is any conflict between applicable laws and our policy.

Since the App includes a Dating feature, we recognise heightened risk of misuse. Therefore:

• We strictly enforce age limits: users must be 18+ to access the Dating feature. Minors are forbidden from using or being matched via the Dating feature.
• We prohibit minors from creating accounts intended for dating or from mis-representing their age.
• We monitor for patterns of behaviour indicative of grooming, misuse or attempts to target minors.

We require users of the Dating feature to acknowledge and accept our Community Standards and this CSAE policy.

We deploy additional safety-checks (age verification, behavioural monitoring, reporting prompts) appropriate to the risks inherent in a dating service.

We maintain review, detection and moderation protocols for user-generated content and user interactions. This includes automated tools, human review and escalation of high-risk cases.

We consider ambiguous or potentially suspect content (even if not clearly illegal) and may act proactively (remove content, suspend account) while investigations proceed.

We retain logs and relevant metadata in accordance with applicable data protection laws to enable investigations and reporting where required.

We require users to confirm they are at least 18 years old before accessing the Dating feature.

We deploy reasonable verification measures (e.g., identity/age checks, third-party verification services) to reduce the risk of minors mis-representing their age.

We monitor profiles and activity for signs of under-age usage or age-misrepresentation and may suspend accounts while verification is pending.

Every user must comply with our Community Standards which prohibit inappropriate interaction with minors, sexualised content involving minors, grooming behaviour, or any act that endangers the safety of children.

Profile photos, user names, status messages, chat messages or other content may not depict, reference or target minors in a sexual or exploitative manner.

We encourage users to report inappropriate behaviour and remind them of their obligation to act responsibly when interacting with other users.

We provide regular training to all moderation, safety and product-teams on recognising signs of CSAE, grooming, sextortion and trafficking of minors.

We maintain internal policies and protocols for evidence preservation, escalation, cooperation with law-enforcement, and data protection when minors are involved.

We review our processes periodically (at least annually) to ensure alignment with regulatory developments and industry best practices.

We implement appropriate technical safeguards (for example: automated scanning of image uploads, heuristics for suspicious behaviour, limits on children-targeted content, metadata monitoring) to detect and prevent CSAE misuse.

We minimise data collection from minors and ensure any personal data is processed in accordance with our Privacy Policy, data-protection obligations (e.g., GDPR, Zimbabwean data protection law) and safe-storage standards.

We ensure that user-generated content is stored, deleted, or archived in compliance with legal retention obligations and that access is controlled and logged.

We have appointed a designated Child Safety Contact who is authorised to receive notices, regulation/authority requests or platform-related enforcement communications.

This person has authority to coordinate with legal, product, moderation and platform teams, and to liaise with authorities and platform operators (e.g., Google Play).

Any violation of this policy will result in one or more of the following:

• Immediate removal of offending content
• Suspension or permanent termination of the user's account
• Referral of the user to law enforcement or child-protection authorities
• Blocking of device or account identifiers
• Cooperation with authorities to freeze or investigate offending behaviour

We reserve the right to take interim action (e.g., temporary suspension) while an investigation is underway.

We provide clear guidance in the App, help-centre or onboarding process about safe conduct, recognizing grooming behaviour, and how to report concerns. We encourage users to:

• Protect their personal information
• Do not share intimate content with unknown users
• Avoid meeting offline without prior verification
• Report any suspicious behaviour immediately