Community Safety & Child Protection Policy and Platform Risk Disclosure

Skulearn

COMMUNITY SAFETY &

CHILD PROTECTION POLICY

Effective Date: 17 February 2026

Operator: Skulearn Pty Ltd | Reg. No. 2025/920955/07 | skulearn.com Registered Address: 417 Pretorius Street, Arcadia, Pretoria, South Africa General Enquiries : hello@skulearn.com

Legal Notices: admin@skulearn.com

Governing Law: Republic of South Africa (see Clause 20 for cross-border users) Applies To: All Users of Skulearn.com worldwide

Language: English. Translations are for convenience only; this English version prevails.

THIS POLICY FORMS PART OF SKULEARN'S GLOBAL TERMS OF SERVICE. BY USING THE PLATFORM YOU AGREE TO BE BOUND BY IT IN FULL.

PLATFORM RISK DISCLOSURE STATEMENT FOR PARENTS & GUARDIANS

1. PURPOSE & SCOPE

1.1 Skulearn Pty Ltd ("Skulearn", "we", "us") is committed to providing a safe, inclusive, and age-appropriate environment for all users of skulearn.com, particularly for users under the age of 18 ("Minor Users").

1.2 This Policy applies to all users of the Platform worldwide, including Learners, Coaches, Instructors, parents, guardians, and visitors. It forms part of the Skulearn Terms of Service and must be read alongside the Privacy Policy and the Terms of Service.

1.3 Where local law in a user's jurisdiction imposes more stringent child protection standards, those standards apply in addition to this Policy.

2. CORE SAFEGUARDING PRINCIPLE

2.1 The safety, dignity, and wellbeing of Minor Users is Skulearn's highest operational priority. No commercial, reputational, or operational consideration will take precedence over the protection of a child using the Platform.

2.2 Skulearn operates on a principle of minimal data collection and maximum protection for Minor Users, consistent with applicable law in all jurisdictions in which the Platform operates, including but not limited to South African child protection law, the EU General Data Protection Regulation (GDPR), the UK Children's Code, the US Children's Online Privacy Protection Act (COPPA), and equivalent legislation globally.

3. ELIGIBILITY & PARENTAL CONSENT

3.1 The Platform is accessible to users aged 13 and above. Users under 13 are not permitted to register or use the Platform.

3.2 Users under 18 (or the applicable age of majority in their jurisdiction) must obtain verifiable parental or guardian consent before registering on the Platform.

3.3 By providing consent on behalf of a Minor User, the parent or guardian:

Accepts the Terms of Service and this Policy on the Minor User's behalf
Accepts responsibility for supervising the Minor User's activities on the Platform
Confirms that the Minor User understands the Platform's community conduct rules
Agrees to be notified by Skulearn of any safeguarding concern involving the Minor User

3.4 Skulearn may request verification of parental consent and may suspend or restrict Minor User accounts where consent cannot be confirmed.

4. PROHIBITED CONDUCT

The following conduct is strictly prohibited on the Platform and may result in immediate account termination, reporting to relevant authorities, and/or legal action:

4.1 Grooming behaviour of any kind, including any attempt to develop an inappropriate personal relationship with a Minor User.

4.2 Soliciting, sharing, or facilitating the sharing of sexually explicit, suggestive, or ageinappropriate content involving or directed at minors.

4.3 Harassment, bullying, or intimidation of any user, including via private messaging features.

4.4 Hate speech or content that discriminates on any protected ground including race, gender, sexuality, religion, disability, or national origin.

4.5 Any attempt to solicit, collect, or encourage a Minor User to share personal contact information, home address, school details, or location data off-platform.

4.6 Any attempt to move a Minor User's communication off the Platform to unmonitored channels.

4.7 Sharing or distributing another user's personal information without that user's explicit consent.
4.8 Impersonating any person, organisation, or authority on the Platform.

4.9 Any conduct that exploits, endangers, or is harmful to any user, with particular regard to vulnerable or Minor Users.

5. OBLIGATIONS OF COACHES & INSTRUCTORS

All Coaches and Instructors approved to operate on the Platform agree, as a condition of their engagement, to:

5.1 Deliver services exclusively through Platform-sanctioned channels and not to solicit offplatform contact with Minor Users.
5.2 Refrain from collecting personal contact information directly from Minor Users.
5.3 Ensure all content and communications are age-appropriate and consistent with their professional obligations under applicable law.

5.4 Report any safeguarding concern involving a Minor User to safeguarding@skulearn.com immediately, and to the relevant statutory authority where required by the law of the applicable jurisdiction.

5.5 Cooperate fully with any safeguarding investigation initiated by Skulearn or a statutory authority.

5.6 Breach of any of the above obligations constitutes grounds for immediate account suspension, permanent termination, and referral to relevant authorities, regardless of jurisdiction.

6. PLATFORM MODERATION

6.1 Skulearn employs a combination of automated moderation tools and human review to monitor public community spaces on the Platform.

6.2 Private coaching sessions are not actively monitored in real time. However, Skulearn reserves the right to review session records where a complaint has been made, a safeguarding concern has been raised, or where required by law.

6.3 Skulearn may, at its absolute discretion: remove or restrict content that violates this Policy or the Terms of Service; suspend or permanently terminate user accounts; escalate concerns to law enforcement or child protection authorities in any relevant jurisdiction; and take any other action reasonably necessary to protect user safety.

6.4 Skulearn cannot guarantee the complete elimination of harmful content or conduct from any digital platform. Users and parents are encouraged to use the reporting tools available and to report concerns promptly.

7. REPORTING MECHANISM

7.1 Any user, parent, or guardian who becomes aware of conduct that may endanger a Minor User or that violates this Policy must report it immediately to:

GENERAL CONCERNS: hello@skulearn.com

SAFEGUARDING REPORTS /LEGAL NOTICES: admin@skulearn.com

7.2 Reports involving Minor Users are treated as the highest priority and will be acknowledged within 24 hours on business days.

7.3 Users may report content or accounts directly through the Platform's in-built reporting tools, where available.

7.4 Where Skulearn has reason to believe that a child is in immediate danger, it will report the matter to the relevant statutory child protection authorities and, where appropriate, law enforcement, in the relevant jurisdiction.

7.5 Skulearn will not disclose the identity of a reporting person without their consent, except where required to do so by law or a binding order of a competent authority.

8. INCIDENT RESPONSE

8.1 Upon receiving a safeguarding report or becoming aware of a potential child protection concern, Skulearn will:

Acknowledge receipt within 24 hours on business days
Conduct an initial assessment within 48 hours
Take interim protective action (including account suspension) where there is an immediate risk
Notify relevant authorities where required by applicable law
Complete a full review and communicate an outcome to the reporting person where appropriate and legally permissible

8.2 Skulearn reserves the right to suspend any account immediately and without prior notice where it has a reasonable basis to believe that a safeguarding risk exists, pending investigation.

9. DATA PROTECTION FOR MINOR USERS

9.1 Personal information of Minor Users is processed with enhanced care and subject to the following specific protections:

Only data reasonably necessary for Platform access and parental oversight is collected from or in respect of Minor Users
Minor User data is not used for targeted advertising or marketing profiling
Parents and guardians may request access to, correction of, or deletion of their child's personal data by contacting privacy@skulearn.com
Cross-border transfers of Minor User data are subject to enhanced safeguards in accordance with applicable law

9.2 Skulearn complies with applicable child data protection legislation in all operating jurisdictions, including POPIA (South Africa), GDPR and the UK Children's Code (EU/UK), and COPPA (United States).

10. PLATFORM RISK DISCLOSURE FOR PARENTS & GUARDIANS

IMPORTANT NOTICE TO PARENTS AND GUARDIANS - PLEASE READ BEFORE GRANTING CONSENT

Skulearn is designed to be a safe, positive, and enriching environment for young people. However, as with all digital platforms, certain inherent risks exist. We are committed to transparency. Before granting consent for your child to use the Platform, please consider the following:

10.1 Educational Nature. Skulearn provides structured educational content, life skills guidance, and personal development resources. The Platform does not provide accredited academic qualifications, clinical therapy, medical advice, or guaranteed personal or professional outcomes.

10.2 Gamified Simulation. The life-path simulation game presents fictional career and life scenarios. Game outcomes are illustrative and educational only. They do not represent predictions, guarantees, or professional assessments of your child's future.

10.3 Independent Coaches & Instructors. Coaches and Instructors on the Platform are independent professionals, not employees of Skulearn. Skulearn vets and approves participants but does not supervise individual sessions in real time. If you have concerns about any professional interaction, please contact safeguarding@skulearn.com immediately.

10.4 Community Interaction. The Platform includes community features where users may interact. While Skulearn employs moderation tools and conduct rules, no digital environment can be made entirely risk-free. We encourage parents to engage with their child about their Platform activity and to use the reporting tools available.

10.5 Data Processing. Personal information relating to your child is processed in accordance with Skulearn's Privacy Policy and applicable data protection law. Please review the Privacy Policy at skulearn.com before consenting.

10.6 Internet Safety. General internet safety risks - including exposure to inappropriate external content, phishing, and contact from unknown individuals - are not unique to Skulearn. We encourage parents to implement appropriate device-level parental controls in addition to Platform safeguards.

10.7 Parental Role. We encourage active and ongoing parental engagement. Skulearn is a complement to, not a substitute for, parental oversight and guidance.

By granting consent for a Minor User to access the Platform, the parent or guardian confirms that they have read and understood this Risk Disclosure Statement.

11. POLICY UPDATES

11.1 Skulearn may update this Policy from time to time to reflect changes in applicable law, Platform operations, or safeguarding best practice. Material updates will be communicated to registered users and parents by email.

11.2 The current version of this Policy is always available at skulearn.com. Continued use of the Platform constitutes acceptance of the current version.

12. CONTACT

skulearn.com

Registered Address: 417 Pretorius Street, Arcadia, Pretoria, South Africa General Enquiries : hello@skulearn.com Legal Notices: admin@skulearn.com

2026 - skulearn.com