SPLURGE

CHILD SAFETY STANDARDS POLICY

Version: 1.0
Effective Date: August 2026
Last Updated: August 2026
Policy Owner: Splurge / Compliance & Trust & Safety
Applies To: All Splurge users, creators, professional users, moderators, employees, contractors, service providers, and visitors
Status: Draft for Legal and Regulatory Review

IMPORTANT NOTICE: This policy is a compliance and operational draft for legal review and does not constitute legal advice. Splurge should obtain qualified legal advice for the jurisdictions in which it operates, particularly regarding mandatory reporting, age requirements, child-protection laws, data protection, evidence preservation, and cooperation with law-enforcement or child-protection authorities.

1. PURPOSE

1.1

Splurge is committed to maintaining a safe digital environment and protecting children and young people from exploitation, abuse, grooming, sexual solicitation, inappropriate contact, and other forms of harm.

1.2

This Child Safety Standards Policy establishes the standards, prohibited conduct, reporting mechanisms, enforcement procedures, and organizational responsibilities that apply when child safety is implicated on the Splurge Platform.

1.3

The policy applies across all Splurge services and features, including:

• User profiles;

• Creator pages;

• Audio and video content;

• Live streams;

• Comments;

• Direct messages;

• Group or community features;

• Professional networking;

• Collaboration features;

• Marketplace or creator services;

• Wallet-related interactions where relevant to safety investigations;

• Links or content shared through the Platform; and

• Any other feature subsequently introduced by Splurge.

1.4

This policy is intended to operate alongside Splurge's Terms of Service, Community Standards, Privacy Policy, KYC & Identity Verification Policy, AML/CFT Compliance Policy, Data Protection Policy, Security Policy, and other applicable policies.

2. CHILD-SAFETY PRINCIPLES

Splurge applies the following principles:

1. Zero tolerance for child sexual exploitation and abuse.

2. Child safety takes priority over engagement, revenue, creator growth, or popularity.

3. Reports involving children are treated seriously and investigated promptly.

4. Users must not use Splurge to facilitate, encourage, organize, or conceal harm to children.

5. Splurge will take proportionate enforcement action where violations are identified.

6. Splurge will cooperate with lawful requests from competent authorities.

7. Personal information concerning children and safety reports will be handled carefully and in accordance with applicable data-protection requirements.

8. Splurge will continuously improve its safety systems as the Platform, threats, technology, and applicable laws evolve.

3. DEFINITIONS

For this policy:

3.1 Child / Minor

A child or minor means a person under the applicable legal age of majority or other legally defined age threshold in the jurisdiction concerned.Where different legal definitions apply, Splurge will apply the legally required standard.

3.2 Child Sexual Exploitation and Abuse (CSEA)

CSEA includes conduct involving the sexual exploitation, sexual abuse, sexual solicitation, grooming, trafficking, or sexualization of children.

3.3 Child Sexual Abuse Material (CSAM)

CSAM means material depicting, documenting, promoting, or otherwise facilitating the sexual abuse or exploitation of a child, as defined by applicable law.

3.4 Grooming

Grooming means conduct intended to build trust, emotional dependency, secrecy, or a relationship with a child for the purpose of sexual exploitation, abuse, trafficking, or other harmful conduct.

3.5 Sexual Solicitation

Sexual solicitation includes requests, invitations, inducements, or attempts to persuade a child to engage in sexual activity, provide sexualized material, or participate in sexual conversations.

3.6 Child-Safety Report

A child-safety report is a report concerning suspected abuse, exploitation, grooming, sexual solicitation, inappropriate contact, or other conduct presenting a significant risk to a child.

4. AGE REQUIREMENTS

4.1 Minimum Age

Splurge is not directed at children under 13.Splurge's existing Privacy Policy states that the Platform is not directed at children under 13 and that it does not knowingly collect personal data from children in violation of applicable law.

4.2 Age Requirements May Vary

Where applicable law establishes a higher minimum age for a particular service, feature, form of consent, or processing activity, Splurge will apply the higher legally required threshold.

4.3 Age Misrepresentation

Users must provide accurate age information when creating or maintaining an account.A user must not:

• Falsify their age;

• Use another person's identity to bypass age restrictions;

• Assist a child in circumventing applicable age restrictions;

• Encourage another person to falsify age information; or

• Use technical or other methods to evade age-safety controls.

4.4 Age Verification

Where appropriate and legally permitted, Splurge may use reasonable measures to determine or verify a user's age.Age-verification measures may include:

• Date-of-birth information;

• Identity verification;

• Account-risk signals;

• Technical indicators;

• Third-party age-verification services; or

• Other proportionate methods permitted by law.

Splurge will seek to minimize unnecessary collection of personal information when implementing age-assurance measures.

5. ZERO-TOLERANCE CSEA STANDARD

Splurge strictly prohibits the use of its Platform to facilitate or participate in child sexual exploitation or abuse.Users must not create, upload, distribute, request, solicit, transmit, promote, advertise, sell, trade, link to, or otherwise facilitate CSEA or CSAM.This prohibition applies regardless of whether the conduct occurs:

• Publicly or privately;

• Through a live stream;

• Through direct messages;

• Through comments;

• Through external links;

• Through creator collaborations;

• Through paid or unpaid interactions; or

• Through any other Splurge feature.

6. PROHIBITED CHILD-SAFETY CONDUCT

The following conduct is prohibited.

6.1 Sexual Exploitation of Children

Users must not sexually exploit, abuse, or facilitate the exploitation or abuse of a child.

6.2 CSAM

Users must not:

• Upload CSAM;

• Request CSAM;

• Share CSAM;

• Distribute CSAM;

• Offer CSAM;

• Sell or trade CSAM;

• Store CSAM using Splurge services;

• Provide links intended to facilitate access to CSAM; or

• Encourage another person to obtain or distribute CSAM.

6.3 Sexual Solicitation of Minors

Users must not sexually solicit a minor or attempt to persuade a minor to:

• Engage in sexual activity;

• Send sexualized images or videos;

• Participate in sexual conversations;

• Perform sexual acts during a live stream;

• Meet for sexual purposes; or

• Provide other sexually exploitative material.

6.4 Grooming

Users must not engage in grooming or behavior designed to establish inappropriate trust, secrecy, emotional dependency, or access to a child for exploitative purposes.

6.5 Sexualized Content Involving Minors

Users must not sexualize children through:

• Images;

• Videos;

• Audio;

• Livestreams;

• Captions;

• Comments;

• Usernames;

• Profile descriptions;

• Messages;

• Artwork or generated content; or

• Other media.

6.6 Trafficking and Commercial Exploitation

Users must not use Splurge to facilitate:

• Child trafficking;

• Commercial sexual exploitation of children;

• Sexual services involving minors;

• Recruitment of minors for exploitation;

• Transportation of minors for exploitation; or

• Financial transactions connected to child exploitation.

6.7 Facilitation

Users must not provide instructions, contacts, locations, payment arrangements, transportation arrangements, or other assistance intended to facilitate child exploitation or abuse.

7. ADULT-MINOR INTERACTIONS

7.1

Adults are responsible for maintaining appropriate boundaries when interacting with minors.

7.2

Users must not use Splurge's communication or creator features to establish inappropriate relationships with minors.

7.3

Particular concern may arise where an adult:

• Requests secrecy from a minor;

• Attempts to move a minor into an exploitative relationship;

• Requests personal or intimate information;

• Requests sexualized content;

• Offers money or valuable items in exchange for sexualized activity;

• Attempts to arrange an inappropriate physical meeting;

• Uses threats or manipulation;

• Repeatedly contacts a minor after being asked to stop; or

• Encourages a minor to hide communications from parents, guardians, teachers, or other trusted adults.

Such conduct may result in immediate enforcement action.

8. LIVE-STREAMING SAFETY

Because Splurge supports live-streaming and creator interactions, additional safeguards may apply to live content.

8.1

Users must not use live streams to expose children to sexual, exploitative, abusive, or otherwise inappropriate conduct.

8.2

Creators must not encourage, pressure, manipulate, or permit minors to participate in sexually exploitative or inappropriate live content.

8.3

Splurge may:

• Monitor publicly available live content using automated and human moderation systems;

• Receive and review user reports;

• Interrupt or terminate live streams;

• Remove content;

• Restrict accounts;

• Suspend or permanently terminate accounts; and

• Escalate serious cases where legally required or appropriate.

8.4

Creators are responsible for complying with Splurge's Community Standards and Child Safety Standards when operating live streams.

9. MESSAGING AND COMMUNICATION SAFETY

9.1

Splurge may apply safety controls to messaging and communication features to reduce risks involving minors.

9.2

Where legally permitted and reasonably necessary, Splurge may investigate communications associated with credible reports of child exploitation, abuse, grooming, or other serious safety violations.

9.3

Users must not use private communications as a means of circumventing Splurge's safety rules.

9.4

A user's expectation of privacy does not authorize conduct that violates applicable law or Splurge's safety policies.

10. REPORTING CHILD-SAFETY CONCERNS

Splurge encourages users to report suspected child exploitation, abuse, grooming, or other serious child-safety concerns.Reports may concern:

• A user;

• A profile;

• A live stream;

• A video;

• An image;

• A message;

• A comment;

• A link;

• A creator;

• A transaction; or

• Other activity on the Platform.

10.1 Reporting Channels

Splurge should provide accessible reporting mechanisms through available Platform interfaces and support channels.A report should, where possible, include:

• The username or account involved;

• The relevant content or feature;

• The approximate date and time;

• A description of the concern; and

• Any relevant information that can assist investigation.

10.2 Emergency Situations

If a child appears to face immediate physical danger, users should contact the appropriate emergency or child-protection authority in their jurisdiction.Splurge will cooperate with lawful emergency requests from competent authorities.

11. HANDLING OF CHILD-SAFETY REPORTS

11.1 Prioritization

Reports involving suspected child sexual exploitation, abuse, grooming, or imminent danger to a child will receive heightened priority.

11.2 Initial Assessment

Splurge may assess:

• The nature of the alleged conduct;

• The age of persons involved, where known;

• The severity and credibility of the report;

• Whether content remains accessible;

• Whether there is an ongoing risk;

• Whether additional accounts may be involved; and

• Whether escalation is legally required or appropriate.

11.3 Immediate Protective Measures

Where appropriate, Splurge may immediately:

• Remove or restrict access to content;

• Disable an account;

• Restrict messaging;

• Restrict live-streaming;

• Restrict creator features;

• Prevent further contact between accounts;

• Preserve relevant information; or

• Take other proportionate safety measures.

12. CONTENT REMOVAL

Splurge may remove or restrict content that violates this policy.Content may be removed when it:

• Depicts or facilitates child sexual exploitation or abuse;

• Solicits sexualized material involving a minor;

• Promotes grooming;

• Facilitates trafficking;

• Encourages exploitation;

• Contains sexualized depictions of minors; or

• Creates a serious child-safety risk.

Removal may occur before or after an investigation depending on the circumstances.

13. ACCOUNT ENFORCEMENT

Depending on the severity and circumstances of a violation, Splurge may:

1. Remove violating content;

2. Issue a warning;

3. Restrict an account;

4. Disable specific features;

5. Suspend an account;

6. Permanently terminate an account;

7. Restrict associated accounts;

8. Preserve relevant records;

9. Prevent re-registration where technically and legally appropriate; and/or

10. Refer or report the matter to competent authorities where required or appropriate.

Serious CSEA violations may result in immediate permanent account termination without prior warning.

14. LAW-ENFORCEMENT AND CHILD-PROTECTION COOPERATION

14.1

Splurge may cooperate with law-enforcement agencies, courts, child-protection authorities, regulators, and other competent authorities where required by law or where legally permitted and appropriate.

14.2

Where applicable, Splurge may respond to:

• Valid legal orders;

• Subpoenas;

• Court orders;

• Lawful government requests;

• Emergency requests concerning imminent threats;

• Child-protection investigations; and

• Other legally recognized requests.

14.3

Splurge will assess requests in accordance with applicable law and will disclose only information that it is legally permitted or required to disclose.

15. EVIDENCE PRESERVATION

15.1

Where Splurge reasonably believes that information may be relevant to a child-safety investigation or legal proceeding, it may preserve relevant records in accordance with applicable law and internal retention procedures.

15.2

Preserved information may include, where legally permitted and necessary:

• Account information;

• Content metadata;

• Relevant uploaded content;

• Reports;

• Moderation records;

• Relevant transaction records;

• Device or technical information;

• Relevant communications or communication metadata; and

• Investigation records.

15.3

Evidence preservation will be subject to applicable privacy, data-protection, security, and retention requirements.

16. PRIVACY AND CHILD-SAFETY INVESTIGATIONS

Splurge recognizes that child-safety investigations may involve sensitive information.

16.1

Personal information collected or reviewed for safety investigations will be handled in accordance with applicable data-protection requirements.

16.2

Access to investigation information should be restricted to authorized personnel with a legitimate business, safety, legal, or compliance need.

16.3

Splurge will apply appropriate technical and organizational safeguards to protect safety-related information.

16.4

Splurge's Privacy Policy provides that the Platform uses security measures including encryption, role-based access controls, multi-factor authentication for privileged and financial functions, logging and monitoring, and periodic security testing.

17. FALSE REPORTS AND ABUSE OF REPORTING SYSTEMS

Splurge encourages good-faith reporting.Users must not intentionally:

• Submit fabricated child-safety allegations;

• Impersonate a child or parent to manipulate an investigation;

• Submit reports to harass another user;

• Attempt to obtain another person's private information through a report; or

• Abuse reporting mechanisms to interfere with legitimate Platform activity.

Good-faith reports will not be penalized merely because an investigation does not substantiate the allegation.

18. MODERATION AND DETECTION

Splurge may use a combination of:

• Automated detection;

• Human moderation;

• User reports;

• Account-risk signals;

• Content review;

• Pattern analysis;

• Safety investigations; and

• Other reasonable trust-and-safety mechanisms.

Automated systems may assist in identifying potentially harmful content or behavior but do not eliminate the need for appropriate human review.Where an automated system produces a significant decision, applicable rights to human review and contest may apply. Splurge's Privacy Policy already recognizes human review rights for certain significant automated decisions.

19. STAFF AND MODERATOR RESPONSIBILITIES

Personnel responsible for Trust & Safety, moderation, customer support, compliance, security, or relevant Platform operations should:

• Understand this policy;

• Treat child-safety reports seriously;

• Follow established escalation procedures;

• Maintain confidentiality;

• Avoid unnecessary access to sensitive material;

• Document material enforcement decisions;

• Escalate urgent cases promptly; and

• Receive appropriate training for their responsibilities.

Where personnel may encounter highly sensitive child-safety material, Splurge should establish appropriate procedures for exposure minimization, secure handling, escalation, and employee wellbeing.

20. THIRD-PARTY SERVICE PROVIDERS

Splurge may use third-party service providers for services such as:

• Hosting;

• Content delivery;

• Analytics;

• Security;

• Identity verification;

• Customer support;

• Moderation;

• Fraud detection; and

• Communications.

Where third parties process personal information on behalf of Splurge, Splurge will apply appropriate contractual, technical, and organizational safeguards consistent with applicable law.Splurge's Privacy Policy contemplates third-party providers for payment processing, KYC/AML, hosting, analytics, communications, and related services.

21. TRAINING AND AWARENESS

Splurge should provide appropriate child-safety and safeguarding training to employees and contractors whose responsibilities may involve:

• Content moderation;

• Trust & Safety;

• Customer support;

• Compliance;

• Security;

• Creator management;

• Community management; or

• Child-safety investigations.

Training should address:

• Recognizing grooming indicators;

• Identifying child-safety risks;

• Handling reports;

• Escalation procedures;

• Evidence preservation;

• Privacy requirements;

• Appropriate communication with affected users; and

• Applicable legal obligations.

22. CHILD-SAFETY BY DESIGN

Splurge will seek to incorporate child-safety considerations into the design and development of new features.Before launching features that could materially increase child-safety risks, Splurge should consider:

• Age-related risks;

• Contact risks;

• Messaging risks;

• Live-streaming risks;

• Content risks;

• Discovery and recommendation risks;

• Privacy implications;

• Abuse and exploitation scenarios;

• Reporting mechanisms;

• Moderation capacity; and

• Appropriate safety controls.

Where processing is likely to create significant risks to individuals, Splurge's existing Privacy Policy contemplates appropriate data-protection impact assessments.

23. THIRD-PARTY LINKS AND OFF-PLATFORM ACTIVITY

Splurge may allow users to share links or information that can direct users to external websites or services.Splurge does not control third-party platforms.However, users must not use Splurge to facilitate child exploitation by directing other users to:

• CSAM;

• Child-trafficking services;

• Sexual exploitation services involving minors;

• Grooming environments; or

• Other unlawful child-exploitation resources.

Where such activity is identified, Splurge may take enforcement action and, where appropriate, escalate the matter to competent authorities.

24. COMMERCIAL AND CREATOR ACTIVITIES

Creators and professional users must not use Splurge's creator, marketplace, networking, promotional, or payment-related features to facilitate child exploitation.Prohibited conduct includes:

• Recruiting minors for sexual exploitation;

• Offering financial incentives for sexualized material from minors;

• Arranging exploitative meetings;

• Promoting child sexual services;

• Using creator collaborations to facilitate exploitation; or

• Using Platform payments or financial features to facilitate child exploitation.

Financial activity associated with suspected criminal conduct may also be reviewed under Splurge's AML/CFT and fraud-prevention procedures.

25. SAFETY OF MINORS WHO USE THE PLATFORM

Where minors are legally permitted to use particular Splurge services, Splurge may apply additional safety measures appropriate to the feature and jurisdiction.These may include:

• Privacy restrictions;

• Messaging restrictions;

• Discovery restrictions;

• Content controls;

• Age-based feature limitations;

• Reporting and blocking tools;

• Safety notices;

• Moderation controls; and

• Additional parental or guardian controls where legally required or technically available.

Splurge will not knowingly collect children's personal information in violation of applicable law.

26. PARENTAL AND GUARDIAN CONCERNS

Parents and legal guardians who believe a child is being harmed through Splurge may submit a report through Splurge's designated reporting or support channels.Where legally appropriate, Splurge may:

• Review the report;

• Restrict relevant content or accounts;

• Provide information about available safety controls;

• Preserve relevant records; and

• Cooperate with competent authorities.

Splurge may need to verify the identity and authority of a person requesting information concerning another user's account before disclosing information.

27. INTERNATIONAL COMPLIANCE

Splurge operates on a global basis and recognizes that child-protection obligations vary between jurisdictions.Splurge will seek to comply with applicable child-safety, child-protection, privacy, cybersecurity, online-safety, and mandatory-reporting laws in jurisdictions where it operates.Where legal requirements conflict or materially differ, Splurge will seek appropriate legal advice and apply the legally required standard.

28. DATA RETENTION

Child-safety investigation information will be retained only for as long as reasonably necessary for:

• Safety investigations;

• Enforcement;

• Legal obligations;

• Law-enforcement cooperation;

• Dispute resolution;

• Security;

• Regulatory compliance; or

• Other legitimate purposes permitted by law.

Where records must be retained for a longer period due to a legal obligation, that obligation will take precedence over ordinary deletion schedules.Splurge's Privacy Policy states that it maintains separate data-retention procedures and recognizes that certain financial, KYC, and AML records may require extended retention.

29. TRANSPARENCY

Splurge may publish periodic information concerning its child-safety and Trust & Safety efforts where appropriate.Such information may include aggregated statistics concerning:

• Reports received;

• Content removed;

• Accounts restricted or terminated;

• Enforcement actions;

• Safety improvements; and

• Law-enforcement requests.

Splurge will not publish information that would unnecessarily identify victims, children, reporters, or individuals involved in confidential investigations.

30. POLICY ENFORCEMENT

Violations of this policy may result in immediate action.The severity of enforcement may consider:

• The seriousness of the conduct;

• Whether a child was harmed or placed at risk;

• Whether the conduct was intentional;

• Whether the user attempted to conceal the conduct;

• Whether the user has previously violated safety rules;

• Whether multiple users or children are affected;

• Whether criminal conduct may be involved; and

• Applicable legal obligations.

Nothing in this policy prevents Splurge from taking immediate action where necessary to protect a child.

31. APPEALS

Where appropriate, users may appeal enforcement decisions through Splurge's designated support or appeals process.However, Splurge may limit or suspend an appeal process where:

• Disclosure could compromise an investigation;

• The matter has been referred to law enforcement;

• Disclosure could expose a child to additional risk;

• The account has been terminated for severe abuse or exploitation; or

• Applicable law permits restriction of the relevant information.

32. PROHIBITION ON RETALIATION

Splurge prohibits retaliation against users who make good-faith child-safety reports.Users must not:

• Threaten a reporter;

• Harass a reporter;

• Attempt to identify a confidential reporter;

• Intimidate a witness; or

• Attempt to interfere with an investigation.

Retaliation may itself constitute a violation of Splurge's policies.

33. SECURITY OF CHILD-SAFETY SYSTEMS

Splurge will take reasonable technical and organizational measures to protect child-safety reporting and investigation systems.Such measures may include:

• Access controls;

• Authentication;

• Encryption;

• Logging;

• Monitoring;

• Secure storage;

• Restricted administrator access;

• Incident response procedures; and

• Periodic security reviews.

34. INCIDENT RESPONSE

Where Splurge identifies a significant child-safety incident, the relevant Trust & Safety, Compliance, Legal, Security, or Management personnel may coordinate an incident response.The response may include:

1. Identifying and containing the risk;

2. Protecting affected users;

3. Removing or restricting harmful content;

4. Preserving relevant evidence;

5. Assessing legal obligations;

6. Notifying appropriate authorities where required;

7. Reviewing related accounts or activity;

8. Documenting the response; and

9. Implementing corrective measures.

35. CONTINUOUS IMPROVEMENT

Splurge will periodically review its child-safety controls based on:

• User reports;

• Safety incidents;

• Enforcement outcomes;

• Emerging abuse patterns;

• Regulatory developments;

• Security assessments;

• Product changes;

• Feedback from relevant stakeholders; and

• Lessons learned from investigations.

The Platform may introduce additional controls where reasonably necessary to address emerging child-safety risks.

36. RELATIONSHIP WITH OTHER SPLURGE POLICIES

This policy should be read together with:

• Splurge Terms of Service;

• Splurge Community Standards;

• Splurge Privacy Policy;

• Splurge Data Protection Policy;

• Splurge KYC & Identity Verification Policy;

• Splurge AML/CFT Compliance Policy;

• Splurge Security & Responsible Disclosure Policy;

• Splurge Data Retention & Deletion Policy;

• Splurge Creator Agreement; and

• Other applicable Platform policies.

Where this policy establishes a stricter child-safety requirement, the stricter child-safety requirement will apply unless prohibited by applicable law.

37. CONTACT AND REPORTING

Child-safety concerns should be reported through Splurge's designated in-app reporting tools or official support channels.For general privacy matters, Splurge's current Privacy Policy identifies:Email: info@splurge.ngSplurge should establish and publish a dedicated child-safety reporting contact or mechanism before formally adopting this policy.Child Safety Contact: [TO BE DESIGNATED]Trust & Safety Contact: [TO BE DESIGNATED]Emergency / Law-Enforcement Contact: [TO BE DESIGNATED]

38. POLICY REVIEW

This policy will be reviewed periodically and may be updated to reflect:

• Changes in applicable law;

• Changes to the Splurge Platform;

• New child-safety risks;

• New moderation capabilities;

• Regulatory guidance;

• Industry standards; and

• Lessons learned from safety incidents.

Material changes may be communicated through the Platform or other appropriate channels.

39. EFFECTIVE DATE

This Child Safety Standards Policy becomes effective on the date specified below following approval by Splurge's authorized management and, where appropriate, legal or compliance review.Version: 1.0
Effective Date: August 2026
Policy Owner: Splurge / Compliance & Trust & Safety