Child Safety Policy

1.1 Purpose

This Child Safety Policy explains Tool-O's commitment to protecting children and young people from harm while using or interacting with the Platform.

The purpose of this Policy is to establish standards that promote child safety, prevent exploitation and support compliance with applicable child protection laws.

1.2 Objectives

This Policy seeks to:

• promote child safety;

• prevent exploitation and abuse;

• prohibit harmful conduct involving children;

• establish reporting expectations;

• support responsible Platform use;

• protect vulnerable persons;

• comply with applicable legal obligations.

1.3 Scope

This Policy applies to:

• all Users;

• User Accounts;

• Platform communications;

• User Generated Content;

• listings;

• photographs and videos;

• Bookings;

• all interactions occurring through or in connection with the Platform.

1.4 Guiding Principles

Tool-O administers this Policy in accordance with the following principles:

• child safety;

• respect;

• accountability;

• prevention;

• cooperation with lawful authorities;

• continuous improvement.

1.5 Relationship with Other Policies

This Policy should be read together with the:

• Terms of Use;

• Trust & Safety Policy;

• Community Guidelines;

• User Generated Content Policy;

• Messaging and Communications Policy;

• Marketplace Enforcement Policy;

• Privacy Policy;

• all other Platform policies.

1.6 Updates

Tool-O may amend this Child Safety Policy from time to time.

The latest version published on the Platform replaces all previous versions.

2.1 Minimum Age Requirements

The Tool-O Platform is intended for use by individuals who satisfy the minimum age requirements set out in the Terms of Use.

Persons who do not meet the applicable minimum age requirements must not create a User Account or use the Platform except where expressly permitted by applicable law and these Terms.

2.2 Zero Tolerance

Tool-O maintains a zero-tolerance approach towards:

• child exploitation;

• child abuse;

• child sexual abuse material;

• grooming;

• trafficking involving children;

• coercion of children;

• exploitation of vulnerable minors;

• any unlawful conduct involving children.

Any such conduct may result in immediate enforcement action.

2.3 Prohibited Conduct

Users must not use the Platform to:

• exploit children;

• communicate inappropriately with children;

• solicit personal information from children for unlawful purposes;

• distribute harmful material involving children;

• facilitate child exploitation;

• threaten, harass or intimidate children;

• encourage unlawful activity involving children;

• otherwise place children at risk.

2.4 Child Sexual Abuse Material

Users must not upload, share, store, transmit, distribute or otherwise make available any material that:

• depicts child sexual abuse;

• promotes child exploitation;

• facilitates child abuse;

• contains links to child exploitation material;

• otherwise violates applicable child protection laws.

Tool-O may immediately remove such material and take any action considered appropriate, including reporting the matter to relevant authorities where required or permitted by law.

2.5 Grooming and Exploitation

Users must not engage in behaviour that may reasonably be considered to involve:

• grooming;

• manipulation;

• coercion;

• exploitation;

• inappropriate communications;

• attempts to establish unlawful relationships with children;

• encouraging children to participate in unlawful or harmful activities.

2.6 Reporting Child Safety Concerns

Users who become aware of suspected child exploitation, abuse or other child safety concerns connected with the Platform should report the matter to Tool-O as soon as reasonably practicable using the reporting mechanisms provided on the Platform.

Reports should include sufficient information to enable appropriate assessment where reasonably possible.

2.7 Investigation and Enforcement

Where Tool-O becomes aware of suspected child safety concerns, it may:

• investigate the matter;

• restrict or suspend affected Accounts;

• remove relevant content;

• preserve relevant records;

• report information to competent authorities where required or

permitted by law;

• take any other action considered reasonably necessary to protect

children or the Platform.

2.8 Confidentiality

Information relating to child safety reports will be handled as confidentially as reasonably practicable, subject to:

• applicable law;

• safeguarding obligations;

• law enforcement requirements;

• the protection of children;

• the protection of other Users;

• Platform security.

2.9 User Cooperation

Users are expected to cooperate with reasonable requests made by Tool-O during investigations involving suspected child safety concerns, provided such cooperation is consistent with applicable laws.

2.10 Commitment to Child Protection

Tool-O is committed to maintaining a Platform that does not tolerate conduct which places children at risk and will take reasonable steps to promote child safety, prevent exploitation and support appropriate legal compliance.

3.1 Child Safety Measures

Tool-O may implement reasonable measures designed to promote child safety, including:

• User reporting mechanisms;

• content moderation;

• account enforcement measures;

• safety monitoring;

• identity verification processes where applicable;

• cooperation with competent authorities where legally required or

permitted.

3.2 Detection of Harmful Content

Tool-O may use manual review, automated systems or a combination of both to identify content or behaviour that may indicate:

• child exploitation;

• grooming;

• child sexual abuse material;

• trafficking;

• unlawful communications involving children;

• other child safety risks.

Detection measures may not identify every instance of prohibited conduct.

3.3 Removal of Content

Tool-O may remove, restrict, disable access to or preserve any content that it reasonably believes:

• breaches this Policy;

• endangers children;

• violates applicable law;

• promotes child exploitation;

• facilitates unlawful conduct;

• presents a significant safety risk.

Removal may occur without prior notice where reasonably necessary.

3.4 Account Restrictions

Where Tool-O reasonably believes that a User has engaged in conduct contrary to this Policy, Tool-O may:

• suspend the User Account;

• permanently terminate the Account;

• restrict Platform access;

• disable messaging functionality;

• remove listings;

• cancel Bookings;

• preserve relevant evidence;

• take any other action reasonably necessary to protect children or the

Platform.

3.5 Reporting to Authorities

Where required or permitted by applicable law, Tool-O may report suspected child exploitation or other child safety concerns to:

• law enforcement agencies;

• child protection authorities;

• regulatory bodies;

• other competent government authorities.

Tool-O may disclose information where reasonably necessary to comply with legal obligations or protect children.

3.6 Preservation of Information

Tool-O may preserve relevant information relating to suspected child safety incidents, including:

• Account information;

• communications;

• listings;

• uploaded content;

• activity records;

• transaction records;

• technical logs;

• other relevant Platform information.

Information may be retained in accordance with the Data Retention Policy and applicable laws.

3.7 User Responsibilities

Users must:

• comply with this Policy;

• avoid conduct that may place children at risk;

• promptly report suspected child safety concerns;

• cooperate with reasonable investigations;

• refrain from uploading prohibited material;

• comply with applicable child protection laws.

3.8 Education and Awareness

Tool-O may periodically review and improve its child safety practices by:

• reviewing reported incidents;

• monitoring emerging risks;

• improving moderation processes;

• updating internal procedures;

• strengthening Platform safeguards;

• reviewing applicable legal obligations.

3.9 No Tolerance for Circumvention

Users must not attempt to circumvent any child safety measures implemented by Tool-O, including by:

• creating replacement Accounts;

• concealing identity;

• using false information;

• bypassing enforcement actions;

• facilitating prohibited conduct through other Users.

Attempts to circumvent child safety measures may result in additional enforcement action.

3.10 Commitment to Ongoing Protection

Tool-O is committed to maintaining policies, procedures and operational practices that support the safety of children and minimise the risk of exploitation, abuse and other harmful conduct on or through the Platform.

4.1 Governance

Tool-O is responsible for administering this Child Safety Policy and may maintain internal procedures to support the prevention, detection, reporting and management of child safety risks on the Platform.

4.2 Compliance

Tool-O seeks to comply with applicable child protection laws, online safety legislation, regulatory requirements and lawful directions issued by competent authorities.

Nothing in this Policy limits Tool-O's ability to take immediate action where reasonably necessary to protect children or comply with applicable legal obligations.

4.3 Policy Review

Tool-O may periodically review this Policy to reflect:

• legislative changes;

• regulatory guidance;

• emerging online safety risks;

• technological developments;

• operational experience;

• industry best practices;

• lessons learned from child safety incidents.

4.4 Continuous Improvement

Tool-O may periodically review its child safety procedures to improve:

• safeguarding practices;

• content moderation;

• reporting mechanisms;

• investigation procedures;

• enforcement measures;

• Platform safety.

4.5 Cooperation with Authorities

Where required or permitted by applicable law, Tool-O may cooperate with:

• law enforcement agencies;

• child protection authorities;

• online safety regulators;

• government agencies;

• courts;

• other competent authorities.

Such cooperation may include preserving or disclosing information as required or permitted by law.

4.6 Relationship with Other Policies

This Child Safety Policy should be read together with the:

• Terms of Use;

• Trust & Safety Policy;

• Community Guidelines;

• User Generated Content Policy;

• Messaging and Communications Policy;

• Marketplace Enforcement Policy;

• Privacy Policy;

• all other Platform policies.

Where there is any inconsistency, the Terms of Use prevail to the extent permitted by applicable law.

4.7 Contact

Questions regarding this Child Safety Policy or reports relating to child safety concerns may be submitted to Tool-O using the contact details published on the Platform.

4.8 Policy Updates

Tool-O may amend this Child Safety Policy from time to time.

The latest version published on the Platform replaces all previous versions.

4.9 Commitment

Tool-O is committed to fostering a Platform that promotes the safety, wellbeing and protection of children by maintaining appropriate safeguards, responding responsibly to reported concerns and continually improving its child safety practices.

4.10 Final Statement

Protecting children is a fundamental priority for Tool-O.

By maintaining strong child safety standards, encouraging responsible reporting, cooperating with competent authorities and enforcing this Policy where appropriate, Tool-O seeks to minimise risks to children and support a safe, trusted and responsible online marketplace.

END OF CHILD SAFETY POLICY