Child Safety and Child Sexual Exploitation Prevention Policy

1. Purpose and scope

1.1 The purpose of this policy is to prevent ActorOS being used for child sexual exploitation or abuse, to state clearly what is prohibited, and to set out how reports are received, assessed and acted upon.

1.2 This policy applies to every user of ActorOS, to all content and communications on the service, and to conduct that takes place off the service where it is facilitated, arranged or continued through ActorOS.

1.3 This policy forms part of, and is to be read with, the Terms of Service and the Privacy Policy. Where this policy and another ActorOS policy differ on a child-safety matter, this policy prevails.

1.4 This policy is not a claim of certification. Nothing in it asserts that ActorOS has been approved, certified, registered or found compliant by any court, regulator or authority. It records the standards we set for ourselves and the controls we operate.

2. Definitions

In this policy:

• Child means a person below the age of eighteen years.
• CSAE means child sexual exploitation and abuse, including the conduct described in section 5.
• CSAM means child sexual abuse material — any visual, audio or textual depiction of a child engaged in, or presented in the context of, sexually explicit conduct, whether recorded, drawn, edited, computer-generated or otherwise synthesised, and irrespective of whether any real child was involved in its production.
• Grooming means conduct directed at a child, or at a person believed to be a child, that is intended to build trust, dependence or secrecy for the purpose of sexual exploitation or abuse.
• Talent means a user who lists themselves on ActorOS; Finder means a user who searches for and contacts Talent.
• We, us and ActorOS mean Rudraayaan AI Technologies Private Limited.
• Competent authority means a court, police authority, Special Juvenile Police Unit, statutory commission or other authority lawfully entitled to make the request in question.

3. Adults-only requirement

3.1 Minimum age

ActorOS is available only to persons who are eighteen years of age or older. A person below eighteen may not create, hold, operate or use an ActorOS account, whether in their own name or through another person.

3.2 No accounts for children

An account may not be created for a child by a parent, guardian, relative, agent, manager, casting professional or anyone else. ActorOS does not offer a minors’ tier, a guardian-managed account, or any supervised mode.

3.3 No representation of children

A user may not use ActorOS to represent, promote, market, submit or list a child, whether as Talent, in a portfolio, in a post, in a casting listing or in a message.

3.4 No child casting

ActorOS is not a channel for the casting of children. Engagement of children in the entertainment industry in India is a regulated activity carrying statutory conditions and permissions, and it belongs with the parties and processes that carry those obligations — not with an open self-listing platform. Casting listings that seek performers below eighteen are prohibited and may be removed.

3.5 Effect of a breach

Where we identify an account that appears to belong to, or to be operated on behalf of, a child, we may restrict or disable that account and remove the associated listing and content. Information relating to the account is handled in accordance with sections 11 and 14; it is not automatically destroyed, because we may be required or permitted to preserve it.

4. Age declaration and age assurance

4.1 What we require

The eighteen-and-over requirement in section 3 binds every user of ActorOS without exception. A user who lists themselves as Talent additionally declares a date of birth, which is required before a profile can be published. That declaration is a representation to us under the Terms of Service, and giving a false date of birth is a breach of those Terms.

4.2 Where the check is enforced

Age is derived from the declared date of birth on our servers, in the database, and not in the application on your device. A declared date of birth indicating an age below eighteen is refused at the database level: the record cannot be written at all, rather than being written and then hidden. A profile cannot be published without a date of birth, and cannot be published with one that indicates a person under eighteen. Changing, repackaging or intercepting the mobile application does not defeat this, because the application is not where the decision is taken.

4.3 What age assurance we do not claim

We do not require documentary proof of age at registration, and we do not claim that a declared date of birth is verified. Age assurance on ActorOS is a combination of a binding declaration, server-side derivation and refusal, and report-led review. We may introduce stronger age-assurance measures, and we may require evidence of age from an individual user where we consider it reasonably necessary.

4.4 Reporting a user you believe is under eighteen

Because a declaration is not proof, reports matter. If you believe a user of ActorOS is under eighteen, tell us through the child safety report form. You do not need to be certain.

4.5 Age shown publicly

A published profile displays an age in years. It does not display a date of birth publicly. The field-level split between what is public and what is withheld is set out in Privacy Policy, section 3.

5. Prohibited conduct and content

5.1 The following are strictly prohibited on ActorOS, without exception and irrespective of stated intent, claimed artistic purpose, claimed professional purpose or the consent of any person:

• Child sexual abuse material. Producing, seeking, soliciting, sharing, transmitting, storing, linking to, advertising or referring another person to CSAM.
• Sexualisation of children. Any depiction, description or presentation of a child in a sexualised manner, including sexualised posing, framing, captioning, commentary or tagging of otherwise ordinary images of a child.
• Grooming. Any attempt to develop a relationship of trust, dependence or secrecy with a child, or with a person believed to be a child, for a sexual purpose.
• Solicitation. Requesting, offering, arranging or attempting to arrange sexual contact with a child, or requesting sexual images or performances from a child.
• Sexual communication involving children. Directing sexual communication at a child, or engaging in sexual communication about an identifiable child.
• Off-platform facilitation. Using ActorOS — a profile, a post, a casting listing, a message or any other surface — to initiate, advertise, arrange, direct or continue any of the above elsewhere, including moving a conversation involving a child to another service.
• Synthetic and AI-generated sexual content involving children. Generating, editing, requesting, uploading or distributing computer-generated, AI-generated, edited or otherwise synthesised material that depicts a child in a sexualised manner, including material that alters an image of a real child and material that depicts a fictional child. Synthetic origin is not a defence and is treated identically to recorded material.
• Trafficking and exploitation. Recruiting, transporting, harbouring, advertising or offering any person, child or adult, for sexual exploitation, forced labour or any other exploitative purpose, including through a listing that presents itself as casting or audition work.
• Deceptive recruitment. Using a casting opportunity, audition, screen test, portfolio shoot or similar pretext to obtain intimate images, sexual contact, money or personal information from any person.
• Facilitating access. Assisting, instructing, encouraging or conspiring with another person to do any of the above, or attempting to evade this policy or our enforcement of it.

5.2 Conduct described in this section may also constitute a criminal offence under Indian law, including under the Protection of Children from Sexual Offences Act, 2012 and the Information Technology Act, 2000. Nothing in this policy limits the operation of that law.

6. Images, video and upload restrictions

6.1 You may upload photographs, an intro reel, showreel material and portfolio media only where every identifiable person in that media is an adult, and where each of them has agreed to appear on a professional talent profile that may be shown publicly.

6.2 You may not upload media depicting a child, including a member of your own family and including a child you say you represent. This applies to family photographs, group photographs, behind-the-scenes material and archive material from work you did as a child.

6.3 You may not upload media of a person who has not agreed to appear, and you may not upload media you do not have the right to use.

6.4 Media that appears to breach this section may be removed, and the account may be restricted, pending review.

7. Public profiles and casting listings

7.1 Non-generation, not concealment

Where a profile is marked as a minor profile, ActorOS does not generate a public web page for it. The public profile page is built by a database function that returns a record only where the profile is live, is not deleted and is not marked as a minor profile; where those conditions are not met the function returns nothing and the page returns “not found”. The profile is therefore not generated rather than generated-and-hidden, and a direct link, a shared URL or a request made outside the application does not produce the page.

7.2 Search and discovery

A profile marked as a minor profile is excluded from talent search and from public discovery on the same server-side basis.

7.3 Caches and copies

A public page that has already been generated may be served from our cache for a short period — presently up to approximately five minutes — after the underlying profile changes. Copies previously taken by search engines, other caches, archiving services or individuals are outside our control. This is stated plainly rather than promised away; see Privacy Policy, section 3.

7.4 Casting listings

A casting listing that seeks, describes or implies performers below eighteen years of age is prohibited and may be removed, and the account that posted it may be restricted.

8. How to report

8.1 Channels

8.2 What to tell us

So that a report can be acted on, please include, to the extent you can: the ActorOS @handle or profile URL concerned; where on ActorOS the material or conduct appears (profile, portfolio, post, message, casting listing); what you saw or what was said; when you saw it; and any context that would help us find it. You do not need to be certain, and you do not need to have investigated anything.

8.3 What not to send

Do not attach, upload, forward or re-transmit suspected child sexual abuse material to us, by any channel. Describe where it is; we will retrieve it from our own systems. Transmitting such material — including with the intention of reporting it — may itself be an offence under Indian law. Our report form deliberately accepts no attachments for this reason.

8.4 Emergency and priority handling

Child-safety reports are placed ahead of every other queue. Where a report indicates a risk to a specific, identifiable child, we prioritise it further and may take the interim measures in section 9.3 before the review concludes. If a child is in immediate danger, contact the police first; ActorOS is not an emergency service and cannot dispatch help.

8.5 Anonymous reports

You may report without giving your name or contact details. If you do not give us a way to reach you we cannot ask you for clarification or tell you the outcome, but the report is still assessed.

9. Triage, review and interim measures

9.1 Acknowledgement. Where a report is made through a channel that gives us a return address, we aim to acknowledge it within twenty-four hours.

9.2 Triage. Every child-safety report is assessed for severity and for whether it indicates a risk to an identifiable child. Assessment is carried out by a trained member of our team; child-safety reports are not closed by automated processing alone.

9.3 Interim measures. Where a report is credible on its face, we may, before completing the review and without prior notice, take one or more of the following steps: restrict or disable the account concerned; remove or make inaccessible the content concerned; suspend the ability to send messages; unpublish the public profile page; and preserve the relevant records under section 11. These are precautionary measures taken to protect users and are not a finding against the account holder.

9.4 Review. We review the report, the material and the account history, and decide what action, if any, is warranted. Where the outcome is finely balanced we resolve it in favour of child safety.

9.5 Outcome. Where we have a return address and it is appropriate to do so, we tell the reporter that the report has been closed. We do not disclose what action was taken against another person’s account, because that information belongs to that person and to any authority seised of the matter.

10. Enforcement measures

10.1 Where we determine that this policy has been breached, we may, in our reasonable discretion and to the extent permitted by applicable law, take any one or more of the following measures:

• remove, restrict or make inaccessible the content concerned;
• unpublish or refuse to generate the public profile page;
• restrict specific features, including messaging and search visibility;
• suspend the account, temporarily or pending review;
• terminate the account;
• decline to provide the service to the same person in future, and restrict other accounts that we reasonably believe are operated by or on behalf of the same person, where doing so is lawful;
• preserve the relevant records in accordance with section 11;
• refer the matter to a competent authority in accordance with section 12.

10.2 Proportionality. The measure taken reflects the seriousness of the breach, what the review established and the account’s history. Confirmed CSAE is treated as the most serious category of breach on ActorOS and will ordinarily result in termination of the account.

10.3 Not a finding of guilt. An enforcement decision is a decision about the use of our service under our contract with the user. It is not a criminal charge, a conviction or any judicial determination, and it does not purport to establish that any person has committed an offence. ActorOS does not determine criminal guilt. Where conduct may be criminal, that is a matter for a competent authority, and section 12 applies.

11. Preservation of evidence and records

11.1 Where a child-safety report is received, or where we identify possible CSAE ourselves, we may place the relevant records under preservation. Records under preservation are not deleted by ordinary processes, including a user’s own account-deletion request and our routine retention purges.

11.2 Records that may be preserved include the account record and registration details, the reported content and its storage location, message records relating to the matter, access and activity logs, device and network information collected in the ordinary course, and the report itself with our handling record.

11.3 Records are retained for the period required or permitted by applicable law, or for as long as reasonably necessary in connection with an actual or anticipated investigation, proceeding, request from a competent authority, or the establishment, exercise or defence of a legal claim — whichever is longer. They are then deleted.

11.4 This is deliberately an exception to deletion. Deleting your ActorOS account removes your account and content as described on that page. It does not, and cannot, require us to destroy information we are required or permitted by law to preserve. Section 4 of the account-deletion page and section 8 of the Privacy Policy say the same thing, and they are to be read together with this section.

11.5 Preserved material is held under restricted access as described in section 13 and is not used for any purpose other than those in this policy.

12. Reporting to authorities and cooperation

12.1 Reporting. Where we form the view that content or conduct on ActorOS may involve an offence against a child, we report the matter to the appropriate authority where we are required to do so under applicable law, and we may do so where we are permitted to do so.

12.2 Indian law. Indian law imposes obligations to report apprehended or committed offences against children, including under the Protection of Children from Sexual Offences Act, 2012, and provides for penalties where a person who is required to report fails to do so. Offences relating to the depiction of children in sexually explicit acts are also dealt with under the Information Technology Act, 2000. We take the position that a report of suspected child sexual exploitation is to be made to the appropriate authority promptly, and we do not treat the question of whether a particular duty is engaged as a reason to delay.

12.3 Cooperation. We cooperate with lawful requests from courts, police authorities, Special Juvenile Police Units, statutory commissions and other competent authorities, and we comply with orders that are binding on us. Requests are handled under section 17.

12.4 Notice to the user. Where we disclose information to a competent authority, we do not notify the account holder where notification is prohibited by law, where we are directed not to, or where we reasonably believe that notification would risk harm to a child, the destruction of evidence or the obstruction of an investigation.

12.5 What we do not claim. We do not claim membership of, accreditation by, or a reporting arrangement with any organisation that we do not in fact have.

13. Confidentiality

13.1 The identity of a child, and information from which a child may be identified, is treated as confidential. We do not publish it, and we disclose it only to a competent authority or where the law otherwise requires.

13.2 The identity of a reporter is treated as confidential and is not disclosed to the person reported. It may be disclosed to a competent authority where required.

13.3 Access to child-safety reports and to preserved material is restricted to the smallest number of personnel necessary to handle the matter, and every access is logged.

13.4 Personnel who handle such matters are instructed not to download, copy, forward or retain suspected CSAM outside the controlled systems in which it already sits.

14. Handling and retention of report data

14.1 Information you give us in a report is used to assess and act on the report, to keep a record of how it was handled, to prevent recurrence, and to respond to a competent authority. It is not used for marketing and is not sold.

14.2 A report and its handling record are retained for the period required or permitted by applicable law, and in any event for as long as reasonably necessary for the purposes in clause 14.1. Reports that are not substantiated are retained for a shorter period than those that are, unless a preservation obligation applies.

14.3 The general position on personal data — what we collect, on what basis, who processes it for us, and your rights — is set out in the Privacy Policy. Where a preservation obligation under section 11 applies, it prevails over a request for erasure, to the extent of that obligation and for its duration.

15. False or malicious reports

15.1 A report made in good faith that turns out to be mistaken has no consequence for the reporter. We would rather assess a hundred mistaken reports than miss one real child.

15.2 A report that is knowingly false, or that is made to harass, silence or gain an advantage over another user, is a breach of the Terms of Service and may itself result in enforcement measures under section 10 against the reporter, and may be reported to a competent authority.

16. Appeals

16.1 If your content was removed or your account was restricted, suspended or terminated under this policy, you may ask us to review that decision by writing to support@actoros.in with “Appeal” in the subject line, within thirty days of the decision. Tell us your @handle and why you say the decision was wrong.

16.2 An appeal is considered by a person who was not responsible for the original decision, where our size makes that possible. We aim to respond within fifteen days.

16.3 Where a matter has been referred to a competent authority, or where an investigation or proceeding is on foot, we may defer the appeal until that has concluded, and we may decline to restore content or access while it continues.

16.4 Nothing in this section limits your right to raise a grievance with our Grievance Officer (section 18) or to pursue any remedy available to you under applicable law.

17. Legal process requests

17.1 Requests from a competent authority for preservation of information, disclosure of information, or removal of content should be sent to support@actoros.in and addressed to the Grievance Officer, Rudraayaan AI Technologies Private Limited, at the address in section 18.

17.2 To allow us to act, a request should identify the issuing authority and the officer making it, cite the provision under which it is made, identify the account or content precisely (@handle, profile URL, or the identifiers we have supplied in an earlier response), and state what is required and by when.

17.3 On receipt of a valid preservation request we preserve the identified records under section 11 pending the disclosure process.

17.4 We disclose information where we are legally required to do so, and we may disclose it where we are legally permitted to do so and consider it reasonably necessary to prevent or address harm to a child. We may seek clarification of a request, and we may decline a request that is not lawfully made.

17.5 Where content is required to be removed or access to it disabled by an order of a court or by a lawful direction of an appropriate government agency, we act on it within the time the law requires.

18. Contact and points of contact

18.1 Child-safety point of contact

Our designated point of contact for child-safety matters, including for app stores, child-protection organisations, regulators and law enforcement, is:

Child Safety Point of Contact
Rudraayaan AI Technologies Private Limited
Krishna Nagar Colony, Ameenpur, Medak, Telangana 502032, India
support@actoros.in

18.2 Grievance Officer

Complaints about our handling of a report, about content on ActorOS, or about our compliance with our policies may be made to our Grievance Officer, whose details are published in Privacy Policy, section 13. The Grievance Officer is also the point of contact for requests from authorities under section 17.

18.3 General support

Non-urgent matters and everything that is not a child-safety concern go through ActorOS support.

19. Relationship to our other policies

This policy sits with the Terms of Service (which contain the binding rules of use and our enforcement rights), the Privacy Policy (which governs personal data, including section 14 of that policy on child safety, legal compliance and preservation), the account-deletion page (which describes what deletion does and what survives it), and support.

20. Amendment, versioning and review

20.1 We may amend this policy. The version number and effective date at the top of this page are updated when we do, and the previous version ceases to apply from the new effective date.

20.2 This policy is reviewed at least once every twelve months, and additionally whenever the product changes in a way that affects a control described in it, or whenever the applicable law changes.

20.3 Where an amendment materially changes what is expected of users, we bring it to users’ attention in the application.

21. Governing law

This policy is governed by the laws of India and is to be read consistently with the Terms of Service, including the jurisdiction clause in those Terms. Nothing in this policy limits any obligation imposed on us, or any right conferred on you or on a child, by applicable law.