Minors Strict Exclusion Policy

This Policy is published pursuant to the following statutory and regulatory obligations:

The 18+ restriction arises from a convergence of multiple independent legal requirements, each of which independently mandates the exclusion of minors:

The Platform employs the following multi-layer verification architecture to enforce the 18+ restriction at every access point:

The following features are subject to technical access controls that prevent activation for any account whose age cannot be confirmed as 18+:

Upon discovery — whether through routine KYC review, fraud detection algorithms, third-party report, or any other means — that an account has been or is being operated by a person under the age of 18, the Company shall take the following actions immediately and without prior notice:

1. Account Suspension (Immediate): The account is suspended pending investigation. All features become inaccessible to the account holder.
2. Service Termination: All subscription services, gamification access, and Pearl Economy features are permanently terminated. No refund is payable.
3. Pearl Balance Forfeiture (Permanent): All Pearl balances in all wallets — regardless of source (earned, recharged, referral, or prize credits) — are permanently and irrevocably forfeited. No restoration under any circumstance.
4. Prize Forfeiture (Permanent): Any unclaimed, pending, or in-transit prizes are permanently forfeited. Any prizes already delivered cannot be recalled but constitute unlawful receipt by a minor — legal responsibility rests with the parent/guardian.
5. Subscription Termination Without Refund: The subscription is terminated without refund of any amount, including subscription fees, Pearl Recharge amounts, or add-on fees. No pro-rated refund is available.
6. Data Deletion (DPDP Act 2023, Section 9): All personal data of the minor is deleted from the Company's systems within the timelines prescribed under Section 9 of the DPDP Act, 2023, retaining only the data required for statutory compliance purposes (fraud records, legal hold data).
7. Notification (where appropriate): Where the Company has contact details for a parent or guardian, the Company may notify them of the account discovery. The Company is under no obligation to provide this notification.
8. Legal Action (where fraud is evident): Where the minor's access was facilitated by fraudulent use of an adult's identity documents, PAN, or Aadhaar, the Company reserves the right to file a complaint under BNS 2023 against the facilitating adult.

Section 9 of the Digital Personal Data Protection Act, 2023 ("DPDP Act") imposes specific obligations on Data Fiduciaries when processing personal data of children (persons under 18). The Company's compliance framework for minor personal data is as follows:

The Company's obligations under Section 9 of the DPDP Act reinforce the practical necessity of the 18+ absolute exclusion policy. Processing a minor's data without verifiable parental consent is a violation of the DPDP Act, exposing the Company to regulatory action by the Data Protection Board of India. The absolute 18+ restriction is therefore both a legal compliance measure and a child safety imperative.

Parents and guardians of persons under 18 bear the following obligations in connection with the SeekhoBecho Platform:

• Supervise device access: Ensure that minors under their care do not access devices on which an adult's SeekhoBecho account is active, or attempt to use an adult's credentials to register;
• Protect identity documents: Never share PAN cards, Aadhaar cards, bank account details, or OTPs with minors. These documents can be misused to create accounts on age-restricted platforms;
• Report minor accounts: If a parent or guardian becomes aware that a minor has created a SeekhoBecho account using their own or borrowed identity documents, they should report it immediately to grievance@seekhobecho.com with subject line "Minor Account Report — Urgent";
• Supervise digital spending: If a minor has access to a parent's payment methods, supervise online transactions. Unauthorised Pearl Recharge by a minor using a parent's payment method is not refundable.

The Company commits to the following design principles to ensure the Platform remains adult-oriented and does not inadvertently attract minor users:

• No minor-targeted gamification: Game designs, prize structures, and engagement mechanics are designed for adult commercial participants — not children. No feature uses characters, themes, or mechanics designed to appeal specifically to persons under 18;
• SeekhoBecho Doll — Adult Promotional Context: Pearl Fairy and Celestial Prince (the SeekhoBecho Doll mascots) are brand ambassadors for an adult commerce platform. Their physical toy manifestation is a promotional prize — not a children's toy product marketed to minors;
• No income promises to minors: The Platform's marketing does not target or appeal to school students, college students below 18, or any minor demographic;
• Content moderation: User-generated content within community features is moderated for appropriateness. Content that could harm minors or that is directed at minors is removed;
• POCSO Act compliance: The Company maintains full compliance with the Protection of Children from Sexual Offences Act, 2012, the IT Rules, 2021, and the DPDP Act, 2023 on child safety. Any CSAM or child-harmful content detected on the Platform is reported to law enforcement and NCMEC immediately.

To report a suspected minor account, parental concern, or child safety issue: