Child Safety Policy

This Child Safety Policy applies to all users of the WaldorfMinds platform — the mobile application (iOS and Android) and the website at waldorfminds.org — and to all members of the WaldorfMinds team. It describes the measures we have put in place to protect users under the age of 18 from harm, exploitation, abuse, and inappropriate contact.

This Policy is intended to comply with applicable child protection legislation, including EU Regulation 2021/1232 on combating the sexual abuse and sexual exploitation of children, and with the child safety requirements of the Apple App Store and Google Play Store. It should be read together with our Privacy Policy, Terms of Service, and Community Guidelines.

WaldorfMinds is open to users aged 14 and above. Users under the age of 14 are not permitted to create an account.

During registration, users are required to provide their year of birth. The Platform does not permit completion of registration for users whose stated year of birth indicates an age below 14.

Users between the ages of 14 and 15 must have obtained the consent of a parent or legal guardian before registering. By completing registration, users in this age group confirm that such consent has been obtained. Parents and guardians may contact privacy@waldorfminds.org to enquire about or request the deletion of their child’s account.

While we do not currently implement technical age verification beyond self-declaration, we take misrepresentation of age seriously. Accounts where there is credible evidence that the stated age is false — particularly where a user appears to be under 14 — will be suspended or deleted without notice. Users who become aware of an account belonging to a user under 14 are encouraged to report it using the in-app reporting tools or by contacting privacy@waldorfminds.org.

The safety of younger users is built into the design and architecture of the Platform, not only into its rules. The following technical restrictions apply to all users under the age of 18:

3.1 Private messaging restrictions

• Users registered as under 18 are restricted by default to private messaging with other users registered as students.
• Private messaging between users under 18 and adult users registered in other account categories — including parents, teachers, alumni, and organisations — is disabled by default at the account level.
• This restriction is enforced at the system level and cannot be overridden by the minor user through any setting or action within the Platform.

3.2 Account type and visibility

• Users who register as students and indicate they are under 18 are assigned a minor account type that carries the above restrictions automatically.
• Any change to account type that would affect communication permissions for a minor account is subject to review.

The following conduct is strictly prohibited on WaldorfMinds. Violations may result in immediate and permanent removal from the Platform, preservation of evidence, and referral to law enforcement authorities without delay.

4.1 Child sexual abuse material (CSAM)

The sharing, uploading, soliciting, distributing, or otherwise making available of child sexual abuse material in any form — including photographs, videos, illustrations, and written descriptions — is absolutely prohibited. This prohibition applies regardless of whether the material is presented as fictional, artistic, educational, or historical.

WaldorfMinds will report any discovered or credibly reported CSAM to the relevant national authorities and, where applicable, to the National Centre for Missing and Exploited Children (NCMEC) or its European equivalents, in accordance with mandatory reporting obligations.

4.2 Grooming and predatory behaviour

Grooming — the process of establishing a relationship of trust, dependency, or affection with a minor for the purpose of exploitation, abuse, or manipulation — is prohibited in any form. Indicators of grooming behaviour include, but are not limited to:

• Attempts to isolate a minor from their peers, parents, or other trusted adults
• Requests to communicate outside the Platform on private channels
• Offering gifts, favours, special attention, or preferential treatment to a minor
• Encouraging a minor to keep communication secret
• Gradually introducing sexual or inappropriate topics into conversation with a minor
• Requesting photographs or personal information from a minor

4.3 Sexual content involving minors

• Sending, sharing, or soliciting sexually explicit or sexually suggestive content involving or directed at any user under the age of 18 is strictly prohibited.
• This includes text messages, images, videos, and links to external content.

4.4 Solicitation of personal information

• Soliciting personal contact information — including phone numbers, home addresses, school addresses, or social media accounts not on the Platform — from users under 18 is prohibited.

4.5 Circumvention of safety restrictions

• Attempting to circumvent the messaging restrictions described in Section 3 — including by encouraging a minor to change their account settings, by using third-party platforms to establish contact, or by any other means — is prohibited.

4.6 Arranging in-person meetings

• Attempting to arrange in-person meetings with users under 18 through the Platform, without the explicit prior knowledge and consent of that user’s parent or guardian, is prohibited.

All content published on WaldorfMinds must be appropriate for a community that includes users as young as 14. In particular:

• No sexually explicit or sexually suggestive content of any kind is permitted on the Platform, regardless of the ages of the users involved
• No content that depicts, describes, solicits, or facilitates the sexual abuse or exploitation of minors may be shared, even if framed as fictional, artistic, satirical, or educational
• No content that promotes, glorifies, or provides detailed information about self-harm, suicide, eating disorders, or dangerous substance use may be shared, in recognition of the particular vulnerability of younger users to such content
• Content that could be used to psychologically manipulate or coerce younger users is not permitted

6.1 In-app reporting

Every user of the Platform has access to in-app tools to report content, messages, or user behaviour that raises safety concerns. These tools are designed to be accessible and easy to use. Reports can be submitted anonymously.

Reports involving potential harm to a minor are assigned the highest priority in our moderation queue and are reviewed as a matter of urgency.

6.2 Direct reporting

Users may also report child safety concerns directly to privacy@waldorfminds.org. We commit to acknowledging receipt of all such reports and to responding with urgency. Reports submitted by email are treated with strict confidentiality.

6.3 Mandatory reporting to authorities

Where reported content or conduct constitutes or credibly suggests a criminal offence against a minor — including the presence of CSAM, grooming behaviour, or sexual solicitation of a minor — WaldorfMinds will report the matter to the appropriate law enforcement authorities without delay and without prior notification to the reported user.

In such cases, WaldorfMinds will cooperate fully with law enforcement investigations, including by preserving and providing relevant data in accordance with applicable legal requirements.

Upon receipt of a report involving potential harm to a minor, WaldorfMinds commits to the following response protocol:

• Acknowledging receipt of the report within 24 hours
• Reviewing the reported content or conduct as a matter of urgency
• Taking immediate protective action where the risk is credible, including removal of the content and suspension of the reported account pending investigation
• Preserving all relevant evidence — including account information, messages, and content — in a manner suitable for potential law enforcement referral
• Reporting the matter to law enforcement where required or where the circumstances warrant
• Notifying the reporting user of the outcome of their report to the extent permitted by applicable law and confidentiality obligations

WaldorfMinds applies heightened data protection standards to users under the age of 18, consistent with the requirements of the GDPR, applicable Italian data protection law, and the Children’s Online Privacy Protection principles:

• We do not use the personal data of users under 18 for profiling, behavioural analytics, or advertising purposes
• We do not share the personal data of users under 18 with third parties beyond what is strictly necessary for the operation of the Platform and the delivery of functional services
• Profile information of users under 18 is not made publicly searchable outside the Platform
• Parents and guardians of users aged 14 to 15 may contact privacy@waldorfminds.org to request a copy of the data held about their child, to request corrections, or to request deletion of the account

All members of the WaldorfMinds team who have access to user data, moderation tools, or platform systems are made aware of this Child Safety Policy and of their obligations under it prior to being granted such access.

The protection of minors is a shared responsibility across the entire team. Any team member who encounters content or behaviour that may constitute harm to a minor — in the course of their work on the Platform — is required to escalate the matter to the project coordination team immediately.

No team member may access, view, or retain data relating to a minor beyond what is strictly necessary for the performance of their role.

This Child Safety Policy is reviewed at least annually and updated as necessary to reflect changes in applicable law, technological developments, Platform features, and evolving best practices in child online safety.

Significant updates to this Policy will be communicated to users through the Platform. The date of the most recent revision appears at the top of this document.

To report a child safety concern, to ask questions about this Policy, or to request information about your child’s account, please contact:

privacy@waldorfminds.org
Associazione non riconosciuta WaldorfMinds
Via Gioberti 67, 50121 Firenze, Italy

All child safety reports are treated as the highest priority and handled with urgency and confidentiality.