Pingle Child Safety Standards

Pentagame Bilişim Limited Şirketi ("Pentagame", "we", "us") is the developer and operator of the Pingle: Check-in & Memories mobile application ("Pingle", the "App"). Pingle is a location-based social check-in and memory-sharing application — users save the venues they visit, leave 24-hour memories (photos and notes) at those venues and share them with friends. These Child Safety Standards describe the policies, controls and contact channels Pingle uses to prevent and respond to Child Sexual Abuse and Exploitation (CSAE) content, conduct and contact on our platform. These Standards are publicly available worldwide at this URL.

1. Zero-Tolerance Policy for CSAE

Pingle has a zero-tolerance policy toward Child Sexual Abuse and Exploitation. The following are strictly prohibited on the Pingle platform:

• Child Sexual Abuse Material (CSAM) in any form — images, videos, text, audio, drawings, AI-generated content or links.
• Sexually explicit content depicting, sexualizing or simulating minors (anyone under 18 years of age).
• Grooming behaviour, sextortion, coercion, or solicitation of minors.
• Promoting, normalising, glamorising, condoning or trading in CSAE material.
• Sharing personal information (including images) of minors for sexual purposes.
• Any conduct that endangers the safety, dignity or well-being of a child.

Violations result in immediate and permanent account termination, content removal, device-level ban, and where required by law, reporting to competent authorities including the U.S. National Center for Missing & Exploited Children (NCMEC), Türkiye's Bilgi Teknolojileri ve İletişim Kurumu (BTK), and INTERPOL where applicable.

2. Age Restriction (13+)

Pingle is open to users 13 years of age or older, consistent with Apple App Store, Google Play, COPPA (United States) and GDPR (European Union) standards for general social platforms. The App enforces the following age controls:

• A self-declared age gate during registration: users must confirm they are at least 13 years old.
• Server-side rejection of any sign-up where the declared date of birth indicates the user is under 13.
• Account suspension if Pentagame becomes aware that an account is operated by a user under 13.
• Mature features (such as direct messaging, location sharing, profile photo upload) are subject to additional moderation when used by accounts declared to be under 18, and parents/guardians may contact us to request account closure for any user under 18.
• Mandatory age >= 13 enforcement is also stated in our Terms of Use.

3. In-App Reporting Mechanism

Every Pingle user has access to a built-in reporting tool that allows them to flag accounts, profile photos, memories (in-app moments), chat messages and check-ins for review:

1. Open the profile or content you wish to report inside the Pingle app.
2. Tap the "⋮" (more) menu, then select Report.
3. Choose Child safety / underage user or Sexual content involving minors as the category.
4. Optionally provide additional context and submit.

Reports flagged as child-safety related are prioritised and reviewed by Pentagame's trust & safety team typically within 24 hours. While a report is being reviewed, the reported account is temporarily restricted from contacting other users.

4. Content Moderation & Detection

Pentagame applies the following safeguards across the Pingle platform to detect and prevent CSAE:

• Image hashing & scanning: All user-uploaded profile pictures and memory photos are scanned against known CSAM hash databases prior to publication.
• Proactive moderation: A combination of automated tooling and human reviewers screens public content and reported items.
• Keyword filters: Chat, bio and venue memories are filtered for known CSAE solicitation patterns.
• Account integrity: Devices, IP addresses and signing identifiers associated with banned CSAE accounts are blocked from re-registration.
• Cooperation with law enforcement: Pentagame complies with lawful requests for information and preserves relevant data in accordance with Turkish Law no. 5651, the EU Digital Services Act and applicable international frameworks.

5. How to Report CSAE Outside the App

If you are unable to use the in-app reporting flow, or wish to escalate, please contact our dedicated Child Safety point of contact below. We respond to all child-safety reports as a top priority.

Child Safety point of contact at Pentagame Bilişim Limited Şirketi:

• E-mail: [email protected] (subject line: "Pingle Child Safety Report")
• Phone: +90 850 259 11 66 (business hours, Türkiye)
• Postal address: Pentagame Bilişim Limited Şirketi, Merkez Mah. 52140 Sk. Çevik Vitacourt B Blok No: 14B / 1, 33240 Mezitli / Mersin, Türkiye

You can also report CSAM directly to the U.S. National Center for Missing & Exploited Children at report.cybertip.org, or to local law enforcement in your country.

6. Compliance with Laws and Regulations

Pingle complies with all applicable child-safety laws and regulations, including but not limited to:

• Türkiye Law no. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications.
• Türkiye Law no. 5237 (Turkish Penal Code) Articles 103 and 226 regarding the sexual abuse and exploitation of children.
• U.S. 18 U.S.C. §§ 2251–2258A (mandatory NCMEC reporting where Pingle becomes aware of apparent CSAM).
• EU Regulation 2022/2065 (Digital Services Act), Article 14 child-safety obligations.
• Google Play Developer Program Policies — Child Safety Standards.
• Apple App Store Review Guidelines — Section 1.2 User-Generated Content.

7. Staff Training

Pentagame Bilişim's moderation team receives mandatory training on CSAE recognition, secure handling of sensitive evidence, victim-centred response, and lawful reporting procedures. Training is refreshed at least annually.

8. Standards Maintenance and Updates

These Child Safety Standards are reviewed at least annually and updated to reflect changes in applicable law, platform policies and operational practice. The latest version is always available at:

https://www.pentagame.com.tr/child-safety.html (English)
https://www.pentagame.com.tr/cocuk-guvenligi.html (Türkçe)

9. Contact & Verification

For any inquiries, including verification of these Standards by Google Play, Apple, regulators or researchers, please contact:

Pentagame Bilişim Limited Şirketi
Tax ID (VKN): 7280811380 · MERSIS: 0728081138000001 · Trade Registry: 63497 (Mersin)
Merkez Mah. 52140 Sk. Çevik Vitacourt B Blok No: 14B / 1, 33240 Mezitli / Mersin, Türkiye
E-mail: [email protected] · Phone: +90 850 259 11 66
Türkçe sayfa: Türkçe versiyonu