⚠️ MANDATORY LEGAL NOTICE: All persons with knowledge of any POCSO offence are required by law to report it. Failure to report is itself a criminal offence under POCSO Act 2012, Section 21. This is not discretionary. Every employee, contractor, vendor, and user of SeekhoBecho.com is bound by this obligation.
Table of Contents
- Purpose & Absolute Commitment
- Definitions & Legal Framework
- Absolute Prohibitions — Zero Tolerance List
- Mandatory Reporting Obligation (POCSO S.19)
- CSAM Detection & Response Protocol
- Age Verification Integration
- Minor Data Protection (DPDP Act 2023 S.9)
- Content Moderation for Child Safety
- Grooming Prevention Framework
- Staff Training & Awareness Requirements
- Gaming Segment Child Safety Controls
- EdTech Segment Child Safety Controls
- Evidence Preservation Protocol
- Law Enforcement Cooperation
- NCMEC / CyberTipline Reporting Process
- Survivor Support & Non-Retraumatisation
- Platform Design Standards (Safety by Design)
- Child Safety Governance & Review
- Accountability & Consequences
- Emergency Contacts & Reporting
1. Purpose & Absolute Commitment
The protection of children from sexual exploitation, abuse, grooming, and all forms of harm is the highest priority safety obligation of RLS Retail Private Limited ("Company"), operating SeekhoBecho.com at Plot-76-D, Phase IV, Udyog Vihar, Sector 18, Gurugram, Haryana – 122001. There is no business consideration, convenience, or circumstance that overrides the Company's child safety obligations under Indian law.
This Policy (v2.0) replaces all previous versions and establishes a comprehensive, enterprise-grade child safety framework consistent with: POCSO Act 2012, IT Act 2000, IT Rules 2021, BNS 2023, DPDP Act 2023, and international best practices for platform child safety.
Platform Position: SeekhoBecho.com is designed for users 18 years and above. The presence of any child on the Platform is strictly controlled. Any adult who misuses the Platform to harm, exploit, or abuse a child will face the full force of Indian criminal law, with the Company's active cooperation.
2. Definitions & Legal Framework
| Term | Definition | Legal Source |
|---|
| Child / Minor | Any person below the age of 18 years | POCSO Act 2012, S.2(d); DPDP Act 2023, S.9 |
| CSAM | Child Sexual Abuse Material — any image, video, audio, text, or AI-generated content that sexually depicts, exploits, or abuses a child | IT Act 2000 S.67B; POCSO Act 2012 S.13–15 |
| Grooming | Any act intended to establish trust, communication, or relationship with a child with the intent of sexual exploitation | POCSO Act 2012 S.11, S.12 |
| Sexual Offence (POCSO) | Penetrative sexual assault, sexual assault, sexual harassment, and using a child for pornographic purposes as defined in POCSO Act 2012 | POCSO Act 2012 S.3–15 |
| UGC | User-Generated Content — any content uploaded, posted, or transmitted by Platform users | IT Rules 2021 |
| Mandatory Reporter | Any person (including Platform employees, users, and the Company itself) who has knowledge of a POCSO offence | POCSO Act 2012 S.19 |
3. Absolute Prohibitions — Zero Tolerance List
The following are ABSOLUTE PROHIBITIONS on SeekhoBecho.com. NO exceptions. NO artistic or educational exemptions. NO context makes these permissible.
| Prohibited Content / Behaviour | POCSO / Legal Provision | Platform Action |
|---|
| CSAM — any image, video, audio, text, or AI-generated content sexually depicting or exploiting a minor | POCSO Act 2012 S.13, S.14, S.15; IT Act 2000 S.67B | Immediate removal + FIR + cybercrime report — no discretion |
| Content facilitating grooming of a minor — building trust/relationship with intent to sexually exploit | POCSO Act 2012 S.11, S.12 | Immediate removal + account termination + law enforcement |
| Content normalising, glorifying, or promoting sexual attraction to minors | POCSO Act 2012; IT Rules 2021 Rule 3(1)(b)(iv) | Immediate removal + account termination + FIR consideration |
| Content revealing the identity of a minor victim of sexual abuse | POCSO Act 2012 S.23 | Immediate removal + legal action against poster |
| Solicitation of sexual images or contact from minors | POCSO Act 2012 S.11; BNS 2023 | Immediate ban + mandatory FIR |
| Course content presenting sexual material accessible to minors | IT Rules 2021; POCSO Act 2012 | Course removal + creator ban + legal review |
| Using platform messaging to establish contact with minors for exploitation | POCSO Act 2012 S.11, S.12; BNS 2023 | Account termination + law enforcement referral |
| Any AI-generated content (text, image, video) depicting minors in sexual contexts | IT Act 2000 S.67B; POCSO Act 2012 | Immediate removal + account ban + FIR |
4. Mandatory Reporting Obligation (POCSO Section 19)
LEGAL REQUIREMENT — POCSO Act 2012, Section 19: Any person who has apprehension that any offence under POCSO Act is likely to be committed or has knowledge that such an offence has been committed shall report to the Special Juvenile Police Unit (SJPU) or local police. Failure to report is a criminal offence under POCSO Act 2012, Section 21.
| Who Must Report | What to Report | When | Where |
|---|
| Any SeekhoBecho employee, contractor, vendor | CSAM, grooming activity, or any POCSO offence discovered on the Platform | Immediately upon discovery — no delay | Cyber Crime Portal + Local Police SJPU + compliance@seekhobecho.com |
| Platform Users | Any content or behaviour violating POCSO provisions | Immediately upon discovery | In-app Report function + cybercrime.gov.in |
| Company (as platform operator) | All confirmed CSAM and POCSO offences detected on Platform | Within 24 hours of detection | Cyber Crime Portal (cybercrime.gov.in) + Local SJPU + CERT-In (if applicable) |
5. CSAM Detection & Response Protocol
| Step | Action | Responsible | Timeline |
|---|
| 1. Detection | CSAM or suspected grooming detected via: automated scanning, user report, or staff review | Content Moderation / AI system | Immediate |
| 2. Content Removal | Content removed from platform immediately and access disabled | Moderation Team / Automated | Within 1 hour of detection |
| 3. Evidence Preservation | Content, metadata, uploader details preserved — DO NOT destroy. Legal hold activated. | Technology Team | Simultaneously with removal |
| 4. Internal Escalation | Escalate to Founder, Compliance Officer, and Legal counsel | First Responder | Within 1 hour of detection |
| 5. Law Enforcement Report | File report on Cyber Crime Portal (cybercrime.gov.in) and notify local SJPU | Compliance Officer | Within 24 hours — MANDATORY |
| 6. Account Action | Preserve account details; do NOT alert the offender; account suspended pending investigation | Technology Team | Immediately |
| 7. Documentation | Full incident documented in Child Safety Incident Log | Compliance Officer | Within 24 hours |
Critical Rule: Do NOT alert the offender. Do NOT delete evidence. Do NOT discuss the case publicly. Evidence must be handed to law enforcement intact.
6. Age Verification Integration
6.1 Registration Gate: All users must declare they are 18+ at registration. Declaration is legally binding and creates contractual liability for false declarations.
6.2 Enhanced Verification Triggers: Additional age verification is triggered when: (a) User profile signals minor status (date of birth entered); (b) Behavioural pattern analysis suggests minor activity; (c) Prize winner (cash payout) — mandatory KYC including age verification; (d) Course Creator monetisation — KYC required.
6.3 DPDP Act 2023, Section 9 Compliance: If a minor is identified on the Platform, verifiable parental consent is required before any personal data is processed for that minor. Absent such consent, the minor's account is suspended and data processing ceases.
6.4 Gaming Segment: Pearl Recharges and any paid features require payment method verification. Payment methods are an indirect age gate — most payment instruments require the holder to be 18+.
7. Minor Data Protection (DPDP Act 2023 Section 9)
7.1 Per DPDP Act 2023, S.9(3): The Company does NOT track, monitor, behaviorally target, or serve personalised advertising to any identified minor user under any circumstances.
7.2 AI recommendation systems, marketing algorithms, and behavioural analytics are configured to exclude minor accounts from personalisation pipelines.
7.3 Parental consent mechanism: When a minor account is identified, a guardian consent workflow is initiated. The minor's access is suspended until verifiable parental consent is obtained. This is consistent with DPDP Act 2023 S.9(1).
7.4 Minor personal data — if inadvertently collected — is processed with the highest data minimisation standards, retained for the minimum legally required period, and deleted upon reaching the applicable retention limit or upon parental withdrawal of consent.
8. Content Moderation for Child Safety
8.1 All User-Generated Content (UGC) is subject to automated pre-screening for: known CSAM hash values (reference database); nudity/sexual content detection; grooming language pattern detection using NLP models.
8.2 IT Rules 2021 SLA: Content violating child safety provisions must be removed within 24 hours of detection or notification (IT Rules 2021, Rule 3(2)(b)). There is no longer SLA for child safety content — it is the Platform's shortest mandatory response window.
8.3 Human Review: All automated child safety flags are reviewed by a trained human moderator within 2 hours. Human review is final for content removal decisions in child safety cases.
8.4 Proactive Detection: The Platform implements proactive content scanning, not just reactive moderation. Periodic audits of course content, community posts, and messaging are conducted for child safety compliance.
9. Grooming Prevention Framework
9.1 The Platform's messaging features include: (a) Age-gap flagging — messaging system alerts if significant age differences are detected between interacting users; (b) Keyword detection for grooming language patterns; (c) Private messaging restrictions — adult users cannot initiate private contact with unverified-age accounts; (d) Blocking and reporting tools accessible from all messaging interfaces.
9.2 Content that establishes the following patterns is flagged for human review: requests to move conversation off-platform, requests for personal information (address, phone) from an age-uncertain account, offering gifts or incentives to young users, instructions to keep conversation secret.
9.3 Gaming Segment specific: In-game chat features restrict unsolicited adult-to-minor messaging. Tournament matching systems include age-range filters for competitive events.
10. Staff Training & Awareness Requirements
10.1 Mandatory Training: All employees and contractors with access to user-generated content or user data must complete child safety training within 30 days of joining and annually thereafter. Training covers: identifying CSAM and grooming indicators, mandatory reporting obligations under POCSO, evidence preservation procedures, survivor-sensitive communication, and DPDP Act minor protection requirements.
10.2 Content Moderation Team: Personnel moderating content receive enhanced child safety training including: trauma-informed moderation practices, psychological support access, escalation protocols, and POCSO legal obligations. Content moderation personnel must never be exposed to CSAM without formal law enforcement liaison protocols in place.
10.3 Psychological Support: Staff exposed to child safety incidents are offered psychological support and can report incidents without fear of retaliation. The Company provides a confidential support channel for staff distressed by content moderation duties.
10.4 Training Records: All child safety training completions are recorded and retained for 5 years. Non-compliance with mandatory training results in access restriction until training is completed.
11. Gaming Segment Child Safety Controls
11.1 All gaming activities on SeekhoBecho.com are designed for users 18 and above. Age verification at account registration serves as the primary gate.
11.2 Pearl Recharge — the primary paid feature in the Gaming Segment — requires payment instrument use. Most Indian payment instruments (credit cards, UPI, debit cards) require the account holder to be 18+, providing an additional practical age control.
11.3 Cash prize winners undergo mandatory KYC verification which confirms age as part of the process. Prizes are withheld and accounts investigated if KYC reveals the prize winner is a minor.
11.4 Tournament chat and community features in the Gaming Segment are monitored for child safety violations per Section 9 (Grooming Prevention) requirements.
12. EdTech Segment Child Safety Controls
12.1 Course creators must: (a) Declare whether their course content is suitable for all ages or restricted to 18+; (b) Comply with age-appropriate content standards for any course marked as suitable for minors; (c) Not create courses that mix educational content with age-restricted content.
12.2 Courses containing: sexual health content, graphic violence, drug/substance content, or any content not suitable for minors — must be marked 18+ and access-controlled accordingly.
12.3 Course Creators who produce content that violates child safety provisions — including POCSO violations — face immediate course removal, account termination, payout forfeiture, and law enforcement referral.
13. Evidence Preservation Protocol
13.1 When a child safety incident is detected, the following evidence is immediately preserved in a secure, tamper-evident format: (a) Offending content (hash + file); (b) Uploader/poster IP address, device ID, account ID; (c) Timestamp and platform location of content; (d) Any communications associated with the account; (e) All prior activity of the offending account.
13.2 Evidence must NOT be deleted, modified, or shared with the offender. Evidence is maintained under legal hold until law enforcement confirms it is no longer needed.
13.3 Evidence format: Preserved in a manner that is admissible in Indian courts — consistent with IT Act 2000 provisions for electronic evidence (S.65B certification where required).
14. Law Enforcement Cooperation
14.1 The Company will cooperate fully and promptly with: (a) Special Juvenile Police Units (SJPU); (b) Cyber Crime cells of state and central police; (c) INTERPOL National Central Bureau (India) for cross-border cases; (d) Any court order or judicial authority.
14.2 Response to law enforcement requests: acknowledged within 24 hours; disclosure timeline per applicable legal provisions and court orders; legal counsel engaged for all law enforcement disclosures.
14.3 The Company does not require a court order to proactively report CSAM to law enforcement. POCSO Act Section 19 creates an obligation to report regardless of formal law enforcement request.
15. NCMEC / CyberTipline Reporting
15.1 For CSAM confirmed on the Platform, in addition to Indian law enforcement: (a) Report filed on India's Cyber Crime Portal (cybercrime.gov.in — National Cyber Crime Reporting Portal); (b) CERT-In notified where applicable per CS-03; (c) Where content involves cross-border distribution, INTERPOL reporting considered in coordination with legal counsel.
15.2 Reporting does not require prior approval from any internal authority — the Compliance Officer has direct authority and mandatory obligation to file reports immediately upon confirmation.
16. Survivor Support & Non-Retraumatisation
16.1 The Platform's response to child safety incidents prioritises the safety and dignity of the child. Actions taken must not: (a) Re-publish or redistribute CSAM even for "evidence" purposes — preserve in secure isolation; (b) Reveal the identity of the child victim publicly or to unauthorised personnel; (c) Contact the child or their family in a manner that could cause further harm — law enforcement leads this contact.
16.2 Staff engaged in child safety incident response are provided with: immediate access to psychological support; permission to step back from the investigation if personally affected; mandatory debrief after handling significant incidents.
17. Platform Design Standards (Safety by Design)
17.1 Child safety is integrated into Platform design — not added as an afterthought: (a) Age verification integrated into registration flow (not skippable); (b) All UGC upload flows include content policy warnings; (c) Reporting buttons on all content and messaging interfaces; (d) Parental controls documented and accessible (for platforms where minor access is permitted with parental consent); (e) No "dark patterns" that encourage minors to remain on the Platform beyond healthy limits.
17.2 Product reviews: All new features involving user interaction, messaging, or UGC undergo mandatory child safety review before launch. Child safety team input is a blocking requirement for feature approval.
18. Child Safety Governance & Review
18.1 This Policy is reviewed: (a) Annually for scheduled review; (b) Within 30 days of any significant child safety incident; (c) Within 60 days of any amendment to POCSO Act, IT Rules 2021, or DPDP Act 2023 affecting child safety.
18.2 Child Safety Incident Log: All child safety incidents logged with: date, type, action taken, law enforcement notified, outcome. Log reviewed by Founder quarterly. Log retained 10 years.
18.3 Annual child safety self-assessment against: POCSO Act requirements, IT Rules 2021 intermediary obligations, DPDP Act 2023 minor protections, and industry best practices. Assessment outcome drives policy updates.
19. Accountability & Consequences
| Actor | Violation | Consequence |
|---|
| Platform User | Uploading, sharing, or soliciting CSAM | Immediate account termination + mandatory FIR + full law enforcement cooperation |
| Platform User | Grooming behaviour | Account termination + law enforcement referral + legal action |
| Employee / Contractor | Failure to report POCSO violation (POCSO S.21) | Immediate employment termination + FIR (POCSO S.21 makes failure to report a criminal offence) |
| Employee / Contractor | Mishandling CSAM (sharing, not preserving) | Termination + criminal liability (IT Act S.67B) |
| Course Creator | Creating or distributing CSAM via course content | Course removal + account ban + all earnings forfeited + mandatory FIR |
20. Emergency Contacts & Reporting
REPORT CSAM IMMEDIATELY: cybercrime.gov.in | Cyber Crime Helpline: 1930 | compliance@seekhobecho.com (subject: "URGENT: CHILD SAFETY")
Child Safety Compliance (Internal)
compliance@seekhobecho.com
Subject: "URGENT: CHILD SAFETY" — 24/7 monitoring for P1
Grievance Officer — IT Rules 2021
grievance@seekhobecho.com
User reports of child safety violations
National Cyber Crime Portal
cybercrime.gov.in
Helpline: 1930 | Available 24/7 | CSAM reports
CERT-In (Cyber incidents)
incident@cert-in.org.in
1800-11-4949 | For cyber-facilitated POCSO offences
Address: RLS Retail Private Limited, Plot-76-D, Phase IV, Udyog Vihar, Gurugram, Haryana – 122001 | GSTIN: 06AAJCR4683G1Z3
Legal Basis: POCSO Act 2012 (S.3–23) | IT Act 2000 (S.67B) | IT Rules 2021 (Rule 3) | BNS 2023 | DPDP Act 2023 (S.9) | Consumer Protection Act 2019