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CHILD SAFEGUARDING & PRIVACY POLICY

CHILD SAFEGUARDING & PRIVACY POLICY

Global Safety Standards for Online 1:1 Instruction

  1. Introduction & Scope

At Language Cosmos (operated by Katarzyna Pietrzyk, registered in Warsaw, Poland, Tax ID/NIP: 5060103172), the protection, safety, and well-being of our minor students are our absolute priorities. This global Child Safeguarding & Privacy Policy outlines our strict procedures for ensuring a premium, completely secure, and digitally sound learning environment.

This policy is designed to align with major international frameworks for child safety and data protection in cyberspace, including but not limited to:

  • The United States Children’s Online Privacy Protection Act (COPPA).
  • The European Union General Data Protection Regulation (EU GDPR) regarding age-appropriate processing thresholds.
  • The Australian National Principles for Child Safe Organisations and State-specific Child Safety Legislations.
  • The New Zealand Children’s Act 2014 & Privacy Act 2020.

Scope: This policy applies to all brand owners, management, and independent contractors (hereinafter referred to as 'Mentors’ or 'Tutors’) delivering 1:1 online live instructional services to students under the age of 18 (minors).

  1. Verification & Safer Recruitment (Global Standards)

To maintain our premium educational standards and ensure student safety, Language Cosmos enforces a strict vetting protocol for all prospective Mentors before they are authorized to hold private online sessions with minors:

  • Criminal History Screening: Mentors are required to undergo a comprehensive background check and submit a valid Certificate of Good Conduct or Criminal Record Clearance from their respective country of residence, including local equivalents such as the Working with Children Check (WWCC) where applicable.
  • Sex Offender Registry Checks: Mentors operating or registered from Poland are cross-referenced against the official government database (Rejestr Sprawców Przestępstw na Tle Seksualnym).
  • Identity & Professional Auditing: We conduct professional references and academic verification to ensure character alignment with our core values of empathy, digital excellence, and high-end instructional methods.
  1. Code of Conduct for Live Online 1:1 Interactions

All live learning sessions are strictly conducted on a 1:1 basis (one mentor to one student). This architecture removes risks associated with peer-to-peer bullying or unmonitored digital interaction inside classrooms. Mentors must strictly adhere to the following digital boundaries:

  1. Digital Communication Boundaries
  • Authorized Channels Only: All virtual sessions must take place via official, encrypted video-conferencing channels authorized by Language Cosmos (e.g., Google Meet).
  • No Private Social Media: Mentors are strictly prohibited from soliciting, adding, or interacting with minor students on any private social media accounts (including Facebook, Instagram, TikTok, LinkedIn) or personal instant messaging apps (WhatsApp, Messenger, Telegram).
  • Parental Inclusion: Any instructional support, class materials, or administrative updates outside of the live lesson must involve the parent/legal guardian or be sent through the platform’s official infrastructure.
  1. Visual and Environmental Standards
  • Professional Presentation: Mentors must present a high-end, neutral digital background, free from personal clutter, and maintain business-casual or formal professional attire during all camera feeds.
  • Recording Restrictions: Mentors are absolutely forbidden from capturing screenshots, audio tracks, or video recordings of minor students without explicit, verifiable written consent from the parent or legal guardian, and subsequent structural clearance from the Administrator.
  • Appropriate Language: Mentors must ensure that their microphone feed and speech patterns are professional, encouraging, and entirely appropriate for corporate-level educational standard environments.
  1. International Data Privacy Compliance (COPPA & GDPR)

Language Cosmos treats child data privacy with exceptional rigor, implementing policies compliant with US COPPA, EU GDPR, and New Zealand frameworks:

  • Verifiable Parental Consent (COPPA): Our marketing, public web features, and purchase mechanisms are directed strictly to adults (parents/legal guardians). Language Cosmos does not knowingly collect personal information directly from children under the age of 13 (or under 16 within the EU) without verifiable parental consent.
  • Minimal Data Harvesting: Information gathered during enrollment (student name, target language level, parent email) is strictly used to deliver customized 1:1 instructional services. This data is never rented, sold, or shared with third-party data brokers or external marketers.
  • Parental Control Rights: Parents maintain the absolute right to request access to any data stored regarding their child, request immediate correction, or demand absolute deletion (’the right to be forgotten’) at any stage by emailing planetajezykow@gmail.com.
  1. Safeguarding Reporting & Emergency Protocols

While Language Cosmos operates fully in the cloud, our Mentors are trained to remain vigilant during live audio/video streams for indicators of child distress, abuse, or neglect outside the digital classroom environment.

  1. Addressing Internal Conduct Concerns

If a minor student or parent reports that a Mentor has made inappropriate comments, breached boundary guidelines, or caused emotional discomfort, Language Cosmos will execute the following steps immediately:

  • 1. Immediate Suspension: The accused Mentor will be instantly suspended from all active instructional classes with minor students pending an internal compliance review.
  • 2. Investigation & Reporting: The Administrator will launch a formal investigation. If credible evidence points to a breach of criminal law, the matter will be immediately escalated to the appropriate law enforcement authorities in both the jurisdiction of the school and the residence of the Mentor/student.
  1. External/Environmental Distress (On-Screen Observations)

If a Mentor witnesses active violence, high-level endangerment, or severe environmental crisis in the background of a student’s home stream during a live session:

  • 1. Emergency Termination: The Mentor is structurally empowered and instructed to terminate the live call immediately to protect the immediate dignity and safety of the student, and must log the incident with the school’s administration.
  • 2. Resource Coordination: The school administrator will evaluate the incident and, if necessary, coordinate with child welfare agencies or professional helplines in the student’s country of residence.
  1. International Support & Helplines

Minor students or parents seeking direct, confidential emotional support or guidance regarding safety issues may reach out to the following authorized national organizations:

  • United States: 988 (Suicide & Crisis Lifeline) or 1-800-422-4453 (Childhelp National Child Abuse Hotline).
  • Europe & United Kingdom: 116 111 (European Child Helpline – available for Germany, Netherlands, Luxembourg, and the UK).
  • Australia: 1800 55 1800 (Kids Helpline – darmowy, całodobowy).
  • New Zealand: 0800 54 33 54 (Kidsline).
  1. Independent Oversight and Annual Auditing

This document is subject to an independent performance and compliance review once every calendar year to align with changing digital regulations across North America, Europe, and the APAC region.

Global Implementation & Policy Effective Date: May 26, 2026

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