Child Safety Policy

OUR COMMITMENT TO CHILD SAFETY

Arson Pixelz (Private) Limited (“Arson Pixelz”) builds technology for young people. The protection of children who use the platform (the “Platform”) is an organisational priority and a legal obligation. This Policy sets out how Arson Pixelz protects children, promotes responsible AI use in educational settings, and meets its obligations under Zimbabwean law.

For the purposes of this Policy, a “child” is any person under the age of 18, consistent with the definition in section 3 of the Cyber and Data Protection Act [Chapter 12:07] of Zimbabwe (“DPA”) and the Children’s Act [Chapter 5:06] of Zimbabwe.

PARENTAL AND GUARDIAN CONSENT

2.1 No child under the age of 18 may register for or access the Platform without the explicit prior written consent of their parent or legal guardian, in terms of section 26 of the DPA and regulation 10(5)(a) of SI 155 of 2024.

2.2 Arson Pixelz makes reasonable efforts to verify that consent has been given or authorised by the parent or legal guardian of the child before access is granted, taking into account available technology, in terms of regulation 10(5)(b) of SI 155 of 2024.

2.3 Parental consent may be withdrawn at any time. Upon withdrawal, the child’s account will be deactivated and their personal data handled in accordance with our Privacy Policy.

PROTECTION OF CHILDREN’S PERSONAL DATA

3.1 We process children’s personal data only for the educational purposes described in our Privacy Policy, and strictly in accordance with the data minimisation principle. We do not collect more data than is necessary for the operation of the Platform.

3.2 We do not subject children’s data to automated decision-making that produces legal or similarly significant effects concerning them, in terms of regulation 10(5)(f) of SI 155 of 2024.

3.3 We conduct regular data protection impact assessments for all processing activities involving children’s personal data, in terms of regulation 10(5)(d) of SI 155 of 2024.

3.4 We apply data protection by design and by default when developing and operating features that process children’s data, in terms of regulation 10(5)(e) of SI 155 of 2024.

3.5 We will never sell, share for advertising purposes, or use for commercial profiling any personal data belonging to a child.

CONTENT SAFETY AND AI SAFEGUARDS

4.1 The system is designed and configured to operate exclusively within the scope of ZIMSEC-aligned academic content. Responses outside this scope are filtered and blocked.

4.2 The Platform incorporates content safety filters that are designed to prevent the generation of harmful, violent, sexually explicit, abusive, discriminatory, or otherwise age-inappropriate content.

4.3 The generation, storage, distribution, or facilitation of child sexual abuse material (CSAM) is absolutely prohibited and constitutes a serious criminal offence. Any indication of CSAM on or through the Platform will result in immediate reporting to the Zimbabwe Republic Police and relevant authorities, account termination, and preservation of evidence.

4.4 Arson Pixelz monitors the Platform for misuse and reviews flagged content promptly. Our AI safety systems are continuously reviewed and updated to respond to emerging risks.

RESPONSIBLE AI FOR YOUNG LEARNERS

is designed to support, not to replace, teachers, textbooks, and classroom learning. We present AI as a learning tool and actively discourage over-reliance.

5.2 Every AI response carries a reminder that it should be verified against authoritative sources. We design our system prompts to encourage critical thinking and independent learning.

5.3 We prohibit the use of the Platform for academic dishonesty and make this expectation clear to learners through the Student Acceptable Use Policy.

5.4 We provide age-appropriate explanations of how AI works, its limitations, and why human judgment, teacher guidance, and curriculum study remain essential.

STAFF AND SAFEGUARDING

6.1 All Arson Pixelz personnel who have access to the Platform or to children’s data are subject to appropriate background screening and receive training on child safeguarding and data protection obligations.

6.2 Arson Pixelz designates a responsible person internally to oversee compliance with this Policy and to receive and act on safeguarding concerns.

REPORTING CONCERNS

7.1 Any learner, parent, guardian, teacher, or member of the public who has a concern about child safety in connection with the Platform should report it immediately to support@kurai.io

7.2 All reports are treated with urgency and confidentiality. We will acknowledge receipt promptly and take appropriate action, including referral to authorities where required.

7.3 Concerns may also be reported to the Zimbabwe Republic Police in respect of child rights matters.

POLICY REVIEW

This Policy will be reviewed at least annually and updated as required to reflect changes in Zimbabwean law, technological developments, and evolving best practice in child online safety.

Arson Pixelz (Private) Limited (Registration No. 82248A0122026) | 2476 Cowdray Park, Zimbabwe | support@kurai.io | www.kurai.io

Pending Data Controller under the Cyber and Data Protection Act [Chapter 12:07] of Zimbabwe