Child Protection Policy

1. Our Commitment

We are dedicated to protecting all children and young people who use our platform. This policy applies to all users, teachers, students, parents, and staff members.

2. Minimum Age Requirements

Account ownership (pursuant to Art. 8 GDPR and Romanian Law 190/2018):

• Users must be 16 years or older to create an Account

• Users under 16 are not permitted to register or use the platform

• Users aged 16 or 17 remain minors; the safeguards for minors and the parent or legal guardian duties below apply to them

For the standard Account, Users declare that they meet the minimum age threshold of 16. Providing a date of birth is optional, and this flow does not include identity verification. The declaration confirms only the 16+ threshold; it does not prove age 18, full legal capacity, or eligibility for an adult-only product. Such a product requires the separate check shown for its flow.

3. Teachers, listings and paid products

Hola25 supports the following available flows:

• For tutoring listings, Hola25 publishes information and facilitates contact; the lesson and payment are arranged outside Hola25

• For paid products active on the platform, Hola25 facilitates booking or access and payment and applies the checks disclosed at checkout

• Professional, fiscal, identity or payment checks performed for a product do not amount to a guarantee of teaching quality or suitability for a particular child

• The parent must use the flow shown for the available product: direct contact for a listing, or the Hola25 checkout and product space for an active paid product

4. Parental guidance for users aged 16-17

Parents or legal guardians of Users aged 16 or 17 must:

• Ensure the minor understands the applicable Terms and safety rules

• Personally review teacher announcements and contact details before reaching out to any teacher

• Assess the teacher's qualifications and suitability for the child; product-level checks are not a pedagogical or safety guarantee

• Supervise online or in-person lessons, including those arranged from a listing and those booked through Hola25

• Approve any in-person meeting location and arrangements

• Review lesson history and communications

• Report inappropriate conduct immediately

• Teach the child about online safety

5. Safe communication guidelines

Recommendations for safer interactions involving minors:

• Communication should remain professional and focused on the declared activity (skill-sharing, tutoring, etc.)

• Parents/guardians should be aware of all conversations and arrangements between a minor and a teacher contacted via the platform

• Note: Hola25 does NOT actively monitor private communications that take place off-platform after a teacher is contacted

• Social media connections between teachers and minor students are discouraged

6. Online lesson safety

Sessions arranged from tutoring listings take place through tools selected by the teacher and student. Recording through the Live Lesson Service, as defined in the Hola25 Terms and Conditions, is a mandatory characteristic of live lessons booked in Hola25 and is separately accepted by the buyer before checkout; that acceptance proves notice, while the processing grounds are those stated in the Privacy Policy. Only enabled audio, video, and screen content is captured; the camera may remain off where the room permits, and private background and bystanders should be protected. The teacher and participants authorised for a segment may access the file under the product rules; authorised Hola25 personnel may review it only for safety, refunds, or disputes. A technical error may prevent the recording from starting, continuing, synchronising, or being saved. Processing may take time, and there may be offsets of a few seconds, gaps, interruptions, or incomplete files. Hola25 does not guarantee exact synchronisation, completeness, or availability of a recording. The status shown in the room is the applicable status; if the product requires recording and the system cannot confirm it, the lesson may be stopped and there may be no playable file. Report any problem without delay through the support channel. Joining the lesson and accepting recording does not authorise public or advertising use. That requires separate express permission from every identifiable person and, for a minor, their parent or legal guardian where applicable. The ability to access, play back, internally review, or publish the file through Hola25 expires automatically no later than 90 days after the lesson, and the file becomes unavailable. After expiry, the periodic process attempts deletion through the applicable managed storage authority — the Live Lesson Service or Private Recording Storage. If the applicable service does not confirm deletion, the operation is retried and escalated without restoring access in the meantime. For video lessons with minors, we recommend:

• Parental presence is strongly recommended

• Lessons should take place in common areas, not bedrooms

• Teachers should maintain professional appearance and behavior

• No participant should record or share a lesson without a valid legal basis, advance notice to every participant and every authorization required by law

• Screen sharing should be limited to educational content

7. In-Person Lesson Safety

For face-to-face lessons:

• For every in-person lesson involving a child, a parent, legal guardian, or another responsible adult designated by them remains on the premises

• The first meeting takes place in a shared or observable space

• The parent or legal guardian must know the exact lesson time and location

• The Teacher must not transport the child or arrange a private closed-door meeting alone

• The Teacher must communicate the planned curriculum and methods for the lesson to the parent or legal guardian

8. Prohibited Behaviors

The following are strictly prohibited:

• Any form of physical, emotional, or sexual abuse

• Inappropriate, sexual, or threatening comments, gestures, or behavior

• Requesting money, identity documents, passwords, intimate images, an exact home address, or other personal information unrelated to the lesson

• Moving a conversation with a minor to a private channel hidden from the parent/legal guardian or not approved for the relevant flow

• Sharing or requesting personal photos unrelated to education, or taking any photo or recording without the authorisations required by law

• Meeting minors outside of scheduled lessons

• Offering gifts or favors to minors

• Discussing personal or romantic matters with minors

• Content inappropriate for the child's age

9. Reporting Concerns

How to report:

1. Email: contact@hola25.com

2. In-platform: Use the report option on a teacher's profile or announcement

3. Emergency: In case of immediate danger, contact local authorities (112 in Romania) or the Child Helpline (116 111 in Romania)

Access to reports is restricted to authorised personnel. We assess reports according to risk and may disclose information where law or the immediate protection of a child requires it.

10. Investigation and Action

Upon receiving a report:

• We may suspend involved accounts while assessing a report, where warranted by the risk

• Authorised personnel handle the report; information may be disclosed in the circumstances stated above

• Where appropriate, we notify relevant authorities and cooperate with law enforcement

• Confirmed serious violations may result in permanent account bans

Consequences for violations

Depending on risk, available evidence, and applicable law, violations of this Child Protection Policy may result in:

• A warning for a confirmed minor violation

• Account restriction or temporary or permanent suspension for a serious or repeated violation

• For abuse or immediate danger, content removal, evidence preservation, reporting to authorities, and a permanent Account ban where required by the risk and law

11. Data Protection for Minors

We process data of minors with enhanced protection measures:

• Each processing purpose must rely on the legal basis stated in the Privacy Notice; parental authorization is recorded where the law or the account flow requires it

• Minimal data collection - only what is necessary for lessons

• Mobile advertising is disabled in the current release; the iPhone app contains neither the advertising SDK nor the ATT permission

• Parents can exercise data rights for the child account, subject to legal retention duties and protection of other users

12. Teacher conduct expectations

All Users who activate a Teacher Profile must:

• Follow our Terms and Conditions and Content Policy

• Follow the duties in this Child Protection Policy whenever engaging with a child

• Apply child-safety requirements to both off-platform lessons arising from listings and paid lessons booked on Hola25

Hola25 does not currently certify teaching quality. Any professional, fiscal, identity or payment checks disclosed for a paid product do not replace the parent's suitability review.

13. Policy Updates

We publish the date and version of each update. Material changes follow the notice and, where required, acceptance mechanism stated in the Terms and Conditions.

14. Contact

For questions about child safety:

Email: contact@hola25.com