Global Child Safety Standards & CSAE Compliance Policy

1. Mission statement & scope

RallyUp Solutions Private Limited ("The Company") is committed to providing a safe, inclusive, and secure digital environment for the global sports community. We maintain a zero-tolerance policy toward any content or behaviour that exploits, harms, or endangers minors.

This policy applies to all users, club administrators, and content creators across the Wingman Pro platform globally. It specifically addresses the prevention, detection, and reporting of Child Sexual Abuse Material (CSAM) and Child Sexual Abuse and Exploitation (CSAE).

2. Global regulatory alignment

Wingman Pro operates in strict accordance with international frameworks, including but not limited to:

• International: UN Convention on the Rights of the Child.
• India: Protection of Children from Sexual Offences (POCSO) Act (2012) and Information Technology Rules (2021).
• United States: 18 U.S.C. Section 2258A (mandatory reporting to NCMEC).
• European Union: Digital Services Act (DSA) and the European Strategy for a Better Internet for Kids (BIK+).
• United Kingdom: Online Safety Act (2023).

3. Prohibited content & conduct

Regardless of a user's geographic location, the following are strictly prohibited on Wingman Pro:

• CSAM: Any visual depiction (photographic, video, or AI-generated) of a minor engaging in sexually explicit conduct.
• Grooming: Any behavior intended to establish an emotional connection with a minor to lower their inhibitions for the purpose of sexual exploitation.
• Solicitation: Attempts to obtain private contact information, personal schedules, or explicit imagery from minors.
• Extortion (sextortion): Using sensitive information or imagery to threaten or coerce a minor.

4. Operational procedures & enforcement

4.1 Detection & monitoring

• Automated scanning: We utilize metadata analysis and automated keyword filtering to identify and block potentially harmful content on community walls and prediction leagues.
• Manual moderation: Our internal safety team performs periodic audits of high-activity club subdomains to ensure community guidelines are upheld.

4.2 In-app reporting

• Wingman Pro provides a native "Report" feature on every piece of user-generated content.
• Reporting flow: Users can select the three-dot menu on any post or profile and select "Report Child Safety Concern."
• SLA: Reports involving child safety are flagged as Priority 1 and reviewed by our safety team within 2 hours.

4.3 Enforcement actions

Upon confirmation of a violation:

• Immediate removal: Content is permanently purged from our production servers (Firebase).
• Permanent ban: The associated User ID, phone number, and device fingerprint are blacklisted across the RallyUp ecosystem.
• Data preservation: Evidence is encrypted and preserved for law enforcement, overriding standard data deletion requests in accordance with global legal mandates.

5. Mandatory reporting protocols

RallyUp complies with mandatory reporting requirements. Confirmed cases of CSAE/CSAM will be reported to the following authorities based on the jurisdiction of the user or the incident:

6. Contact information

The designated point of contact for Wingman Pro's child safety compliance is:

• Name: Dr. Sunil Acharya
• Title: Chief Compliance Officer
• Email: response@wingmanpro.tech