CHILD PROTECTION AND REPORTING POLICY

1. What this policy is

1.1 Young players use the KARDO App to enter tournaments and to play games with other players. This policy sets out what we prohibit, how to report a concern about a child, and what we do when a concern is reported.

1.2 What this policy is not. We are a platform. We do not supervise games or tournaments; we are not present at venues, and we do not conduct background checks on players, tournament organisers or venue staff. We do not represent that anyone using the KARDO App has been vetted by us. Parents and guardians should assume that other adults on the KARDO App are unknown to us, and should supervise their child accordingly.

1.3 Statutory basis. This policy gives effect to our obligations under sections 19 and 21 of the Protection of Children from Sexual Offences Act, 2012 (reporting of offences, and the offence of failing to report), section 67B of the Information Technology Act, 2000, and Rules 3(1)(b) and 3(2)(b) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (informing users of prohibited content, and removing certain content within 24 hours).

1.4 In this policy, a “Child” is anyone under eighteen (18) years of age, and “Guardian” means a parent or lawful guardian.

2. What is prohibited

These rules bind every user of the KARDO App, including tournament organisers, officials and adult players. Breach is grounds for immediate and permanent removal, and for referral to the police.

• Any sexual act, advance, remark, image or conversation directed at a Child, whatever the Child appears to consent to or claims their age to be.
• Grooming — building a relationship with a Child, on or off the KARDO App, for the purpose of abuse or exploitation.
• Arranging to meet a Child alone, or in a private or unobserved place, through anything arranged on the KARDO App.
• Contacting a Child through a personal or private channel obtained from the KARDO App.
• Photographing or filming a Child without their Guardian’s consent, or sharing any such image.
• Publishing, transmitting or storing material that depicts a Child in a sexually explicit manner, or that is otherwise harmful to a Child. This is a criminal offence under section 67B of the Information Technology Act, 2000.
• Harassing, bullying, threatening or humiliating a Child.
• Misstating your own age, or a Child’s age, on the KARDO App.

3. How to report a concern

3.1 Anyone — a Child, a Guardian, a player, an organiser, an employee or a bystander — may report a concern about a child’s safety by emailing safeguarding@kardo-app.com, calling +91-7338303939, or using “Report a safety concern” in the KARDO App.

3.2 You do not need proof, and you do not need to be certain. A concern is enough. You may report anonymously, although contact details help us act on it.

3.3 Reports about a child’s safety are not handled through the ordinary support queue. They go to the person named at the top of this policy.

3.4 Please report the same day the concern arises. If a child is in immediate danger, contact the police on 112 or Childline on 1098 first.

4. What we do when a concern is reported

4.1 Report to the authorities. Where a report discloses knowledge or apprehension that a sexual offence has been committed against a Child, we report it to the Special Juvenile Police Unit or the local police without delay, as sections 19 and 21 of the POCSO Act, 2012 require. We do not conduct our own investigation in place of reporting, and we do not wait to satisfy ourselves that the report is well founded before reporting it.

4.2 Suspend as a precaution. Where a concern relates to an adult’s conduct towards a Child, we may suspend that account or listing immediately pending the outcome. Suspension is a precaution and is not a finding against anyone.

4.3 Remove content. We remove content that is harmful to a Child on becoming aware of it. Where a complaint concerns content showing a person in a sexual act, in nudity, or in impersonated form without their consent, we remove or disable access to it within 24 hours, as Rule 3(2)(b) of the IT Rules, 2021 requires. We act on a lawful order of a court or authorised government agency within 36 hours.

4.4 Preserve records and cooperate. We preserve the account records, messages and logs relevant to the concern, and cooperate with the police and any other authority conducting an inquiry.

4.5 Tell the Guardian. We inform the Child’s Guardian, unless doing so would place the Child at greater risk or prejudice an investigation.

4.6 No silencing. We will not ask a Child, a Guardian or anyone reporting a concern to keep it confidential, and we will not make any settlement conditional on their doing so. Retaliation against a person who reports a concern in good faith is grounds for removal or, for an employee, disciplinary action.

5. Young players’ accounts

5.1 A person under 18 cannot enter a contract under Indian law, so an account for a young player is held by a Guardian, who is responsible for it. At registration, we collect the Guardian’s name, mobile number and email address — all three are mandatory.

5.2 How the account is opened. We send a one-time password to the Guardian’s mobile number. Entering it is the Guardian’s acceptance of the Terms and Conditions, the App Privacy Policy and this Policy, and the account is not activated until then. We then email the Guardian a copy of the Terms and our policies, with a record of the account opened. If the Guardian did not authorise it, they may object within five (5) working days, and we will close the account and erase the data.

5.3 Notice of each entry. We email the Guardian each time the young player enters a tournament, joins or hosts a game, or enrols in any other activity. The Guardian has one (1) working day to decline, and may withdraw the young player at any time before or after the event. Where an entry is made less than one working day before the event begins, participation is held until the Guardian confirms.

5.4 Guardian control. A Guardian may refuse or reverse any entry, correct the account information, withdraw any consent given, close the account, and switch the account to require their express approval before every entry. An adult may exchange messages with a Junior Account only where the Guardian has given express consent for that in the account settings, and only through the KARDO App. Consent may be withdrawn at any time, and any message sent through the KARDO App may be reviewed by us if a safety concern is reported. A Junior Account is not publicly discoverable.

5.5 Guardians: please supervise. Because we do not vet players, organisers or venues, we ask Guardians to accompany or arrange supervision for a young player — particularly for a first meeting with players they have not met — to talk to their child about what is and is not acceptable behaviour from an adult, and to report anything that concerns them.

6. Records, accountability and review

6.1 The Designated Safeguarding Officer named at the top of this policy is responsible for receiving reports, making any report required to the authorities, and deciding on suspension. They may act without commercial approval.

6.2 We keep a record of every concern reported: the date, what was reported, what we did, any report made to the authorities, and the outcome. These records are held securely with restricted access, for 10 years or until the Child concerned reaches 25, whichever is later.

6.3 This policy is reviewed annually, after any reported concern, and before we launch coaching, venue booking or in-app payments — each of which changes the risk and will require this policy to be expanded.

6.4 This policy is published in the KARDO App and on our website, and is given to every Guardian when an account for a young player is created.

7. Contact

Report a concern: safeguarding@kardo-app.com, +91-7338303939.
Other complaints: grievance@kardo-app.com.

Sporting Mile Technologies Private Limited, BHIVE Premium HSR Campus B, No. 112, AKR Tech Park, Krishna Reddy Industrial Area, Bengaluru, Karnataka 560068, India.