Safeguarding.

TRANXFER.MARKET

1. Our Commitment

tranxfer.market is committed to safeguarding and promoting the welfare of every child and young person who uses, or is represented on, our platform. Because our service helps scouts, agents, and coaches discover football players, we have a responsibility to make sure every interaction on the platform is safe, appropriate, and in the best interests of the child.

If a child is in immediate danger, call 999 now. Do not wait to contact us.

2. Scope

• Everyone under the age of 18 registered on the platform. UK law treats everyone under 18 as a child.
• Every adult who interacts with those children through the platform, in any capacity.
• Every activity on or arising from the platform, including profiles, messages, and any in-person meetings or trials arranged as a result of contact made on the platform.
• Everyone who works for or on behalf of TRANXFER MARKET LTD.

3. Guiding Principles

• The welfare of the child is the overriding priority in every decision we make.
• Every child has an equal right to protection, regardless of age, ability, gender, racial background, religious belief, sexual orientation, or identity.
• Every concern and allegation of abuse, exploitation, or inappropriate conduct is taken seriously and acted on promptly.
• We work in partnership with parents, guardians, and statutory agencies.
• We respect confidentiality, but a child’s safety always comes first.

4. Designated Safeguarding Lead

Our Designated Safeguarding Lead is responsible for this policy, for assessing and responding to every safeguarding concern, and for keeping secure records. You can contact them at hello@tranxfer.market.

5. Age-Based Protections

Controls are applied automatically based on the date of birth given at registration. In summary:

• A child under 13 can only have a profile created and held by their parent or guardian, and has no login of their own.
• A young person aged 13 to 17 who signs up themselves stays hidden from other users until a parent or guardian has linked to their account and passed our identity check.
• A scout, agent, or coach cannot message a player under 18 without the approval of the player’s parent or guardian. Their first message is held as a contact request and hidden from the player until the parent or guardian decides.
• Players under 16 cannot send messages. Players aged 16 and 17 can reply only if their parent or guardian switches this on. A linked parent or guardian can see every conversation.
• Scouts, agents, and coaches cannot message or track a player under 18 who lives outside the United Kingdom.

These controls are enforced by our systems, not only in the app. Full details are in Section 5 of our Privacy Policy.

6. Scouts, Agents and Coaches

6.1 Verification

• Every scout, agent, and coach must pass an identity check, matching their face to a government-issued photo ID, before they can view full player profiles or send contact requests.
• Agents must provide their FA registration number when they register.
• Scouts, agents, and coaches can add details of an enhanced DBS check. Whether a professional has provided DBS details is shown on their profile and in contact requests, so parents and guardians can take it into account before approving contact.
• We review the FA registration and DBS details provided, and may restrict or remove any account where details cannot be confirmed.

6.2 Code of Conduct

• Contact with any player under 18 must go through the parent or guardian’s approval on the platform.
• Do not ask any player for personal information outside the platform’s purpose, such as their home address, school, or personal social media.
• Do not try to move contact with a player under 18 off the platform without their parent or guardian’s involvement.
• Private, unsupervised meetings with any player under 18 are not allowed.
• Keep every communication professional and respectful, with no discriminatory, intimidating, or inappropriate language.
• Report any safeguarding concern to us immediately.

7. Parents and Guardians

• Provide accurate information about your child and your relationship to them. We may ask for evidence of the relationship.
• Review contact requests carefully, including the professional’s profile and DBS status, before approving.
• Keep an eye on your child’s account and conversations, and report any concern promptly.
• Accompany your child to any in-person meeting, trial, or session arranged through the platform.

8. Players

• Do not share your phone number, address, school, or other contact details on your profile or in messages.
• Tell your parent or guardian, and us, about any message that makes you feel uncomfortable, pressured, or unsafe.
• Do not try to get around the controls your parent or guardian has set.

9. Photos, Videos and Profile Content

Photos, videos, and profile text appear on the platform as soon as they are added. To keep children safe:

• Avoid content that shows a school uniform or name, a home, or anything else that identifies where a child can be found.
• Only add content showing other people, especially other children, where you have their permission or their parent or guardian’s.
• Parents and guardians can hide or delete content on their child’s profile at any time.
• We remove content that breaches this policy or our Terms, and may suspend the account responsible.

10. Recognising a Concern

Examples of concerns you should report include:

• Inappropriate, sexual, or exploitative messages sent to a player.
• Attempts to arrange private or unsupervised contact with a child.
• Requests for personal information beyond what the platform needs.
• Bullying, harassment, or discriminatory behaviour.
• Signs of coercion, manipulation, or grooming.
• Inappropriate content on a profile or in the video feed.
• Anything suggesting a child’s physical or emotional welfare may be at risk.

11. How to Report a Concern

Email our Designated Safeguarding Lead at hello@tranxfer.market. Please include the names of the accounts involved, what happened and when, and screenshots if you have them. We acknowledge every report within 24 hours.

If a child is in immediate danger, call 999. You can also report concerns about online sexual abuse or grooming directly to CEOP at ceop.police.uk.

12. How We Respond

• The Designated Safeguarding Lead assesses the nature and seriousness of the concern.
• Accounts involved may be restricted or suspended while we investigate.
• Where there is a risk of criminal conduct or immediate harm, we refer the matter to the police and/or local authority children’s services without delay.
• We tell the child’s parent or guardian, unless doing so would increase the risk to the child.
• We keep a secure written record of the concern, our investigation, and the outcome.

13. In-Person Meetings and Trials

Any meeting, trial, or training session with a player under 18 that is arranged through the platform must take place in a supervised, public, or club setting. A parent or guardian should be told in advance and should attend wherever possible.

14. Information Sharing

We share information with the police, local authority children’s services, the NSPCC, football governing bodies, or other statutory bodies where necessary to protect a child. Any sharing is proportionate, necessary, and in line with data protection law, and the safety of the child always comes before confidentiality. See our Privacy Policy for more on how we handle personal data.

15. Our Team

Anyone who works for us, or on our behalf, with access to user data or responsibility for responding to concerns has an enhanced DBS check and safeguarding training before they start, refreshed at least once a year.

16. Review

We review this policy at least once a year, and sooner after any safeguarding incident, a change in the law or guidance, or a significant change to the platform.

17. Useful Contacts

• Emergency: 999. Police non-emergency: 101.
• NSPCC Helpline: 0808 800 5000 or help@nspcc.org.uk
• Childline (for children and young people): 0800 1111
• CEOP (online sexual abuse and grooming): ceop.police.uk