Safety and Conduct Policy

# Safety & Conduct Policy

**Effective Date/Last Modified: December 31, 2025\.**

## Applicability

This Policy applies to all users of the VLT Gymnastics Platform (“VLT”), including:

– Athletes (NCAA, club, elite, and professional)
– Coaches (NCAA, club, and private)
– Parents and Guardians
– Fans and general users
– VLT staff, contractors, and representatives

## 1\. Introduction: Trust is Our Foundation

In the post-Nassar gymnastics community, **safety is not a compliance checkbox, it is the foundation of trust** that makes everything else possible. VLT was built with safety as a core design principle, not an afterthought.

VLT operates on a **”Verified-Only” model** to ensure that every interaction on our platform is accountable, transparent, and traceable. We have zero tolerance for predatory behavior, harassment, or misconduct of any kind.

While VLT is a technology platform and not a National Governing Body (NGB), we align our community standards with:

– **U.S. Center for SafeSport** policies and best practices
– **COPPA** (Children’s Online Privacy Protection Act) requirements
– **NCAA** recruiting and conduct regulations
– **USA Gymnastics** member conduct expectations

### Plain Language Summary

**For Athletes & Families:** You will never interact with an anonymous user on VLT. Every coach and fan is identity-verified. If anyone makes you uncomfortable, report them immediately; we take every report seriously and respond with urgency.

**For Coaches:** VLT gives you powerful tools to connect with athletes ethically. Misuse of these tools, or any attempt to circumvent our safety systems, results in immediate, permanent removal from the platform and potential reporting to your institution and law enforcement.

## 2\. SafeSport Alignment

VLT adopts the definitions of misconduct established by the **U.S. Center for SafeSport**. Violations of SafeSport standards on the VLT platform are grounds for immediate permanent ban and, where applicable, referral to law enforcement and National Governing Bodies.

### 2.1 SafeSport Prohibited Conduct Categories

VLT prohibits all forms of misconduct defined by SafeSport, including:

### 2.2 Mandatory Reporting

VLT is committed to mandatory reporting of suspected abuse:

– **Child Sexual Abuse Material (CSAM):** Any detection is automatically reported to the National Center for Missing & Exploited Children (NCMEC) via CyberTipline
– **Suspected Child Abuse:** Reported to appropriate child protective services and law enforcement
– **Imminent Harm:** Credible threats of physical violence or self-harm are referred to local law enforcement immediately
– **SafeSport Violations:** Serious violations are reported to U.S. Center for SafeSport and relevant NGBs

## 3\. Prohibited Conduct on VLT Platform

The following conduct is strictly prohibited on all VLT platforms and services:

### 3.1 Sexual Misconduct & Grooming

– Any sexualized comments, imagery, or solicitation
– **Grooming behaviors:** A pattern of behavior \- excessive attention, gift-giving, secrecy, boundary testing \- intended to lower inhibitions
– **Private communication violations:** Attempting to move conversations off-platform (requesting personal phone numbers, Snapchat, private email, etc.)
– Sharing or requesting intimate images
– Sexual jokes or innuendo directed at minors

### 3.2 Harassment & Bullying

– Repeated unwanted contact after being asked to stop
– Intimidation, threats, or hostile behavior
– **Body shaming:** Any commentary regarding an athlete’s weight, body shape, eating habits, or physical appearance
– Mocking, ridiculing, or publicly humiliating others
– Coordinated harassment campaigns

### 3.3 Hate Speech & Discrimination

– Discrimination based on race, ethnicity, national origin, religion, gender, gender identity, sexual orientation, disability, or any protected characteristic
– Slurs, derogatory language, or symbols of hate
– Promoting or glorifying violence against any group

### 3.4 Privacy Violations

– **Doxxing:** Sharing private information (home address, phone number, school schedule, etc.) without consent
– Sharing private messages or communications without consent
– Unauthorized photography or recording
– Misuse of data obtained through the platform

### 3.5 Fraud & Impersonation

– Creating fake accounts or impersonating others
– Misrepresenting credentials, affiliations, or identity
– Using bots or automated systems to access the platform
– Providing false information during verification

### 3.6 Platform Misuse

– Attempting to circumvent safety features or verification requirements
– Spam, scams, or commercial solicitation
– Encouraging others to violate this Policy
– Interfering with platform operations or security

### 3.7 NCAA & Recruiting Violations (Coaches)

– Contacting athletes during NCAA “dead periods” or “quiet periods” in violation of rules
– Inducements or improper benefits
– Tampering with athletes committed to other programs
– Misrepresenting program information to recruits

## 4\. Minor Athlete Protections

VLT enforces strict technical and policy safeguards to protect athletes under 18\. We implement a **”Digital Two-Deep” philosophy**, mirroring the SafeSport principle that two adults should be present with minors at all times in our platform architecture.

### 4.1 Athletes Under 13 (COPPA Compliance)

In compliance with the Children’s Online Privacy Protection Act (COPPA):

### 4.2 Athletes Ages 13-17

### 4.3 The “Digital Open Door” Policy

**For Parents:** You have full visibility into your child’s VLT account. You can see every message they receive and send. If anyone attempts to circumvent this system; asking your child to communicate off-platform, requesting personal contact information, or suggesting secrecy-report them immediately.

**For Coaches:** All communications with minor athletes are transparent to parents by design. This protects both athletes AND coaches from false accusations. Conduct yourself as if parents are reading every message, because they are.

## 5\. Verification System

VLT is a **Verified-Only platform**. We do not permit anonymous accounts because anonymity enables abuse. Every user must verify their identity before participating.

### 5.1 Verification Requirements by User Type

### 5.2 Coach Credential Verification

Coaches claiming NCAA, club, or elite status must:

1. Provide proof of current employment or certification (ID badge, institutional email, or official letter)
2. Pass third-party background check (SafeSport compliant)
3. Maintain active SafeSport certification (where applicable)
4. Re-verify annually

**False credentialing results in immediate permanent ban** and potential reporting to institutions and law enforcement.

### 5.3 Why No Anonymous Accounts?

– Anonymous accounts enable predatory behavior without accountability
– Verification creates a traceable chain of responsibility
– Real names and identities foster professional, respectful interactions
– This is a non-negotiable safety requirement, not a convenience feature

## 6\. Reporting Mechanisms

VLT empowers our community to maintain safety through accessible, responsive reporting tools.

### 6.1 How to Report

### 6.2 What Happens When You Report

1. **Acknowledgment:** You receive confirmation that your report was received
2. **Review:** Our Safety Team reviews the report (see response times below)
3. **Action:** Appropriate enforcement action is taken
4. **Follow-up:** You receive notification of the outcome (where appropriate)

### 6.3 Response Time Commitments

### 6.4 Reporter Protections

– **No Retaliation:** VLT prohibits retaliation against good-faith reporters
– **Confidentiality:** Reporter identity is protected to the extent possible
– **Anonymous Option:** Anonymous reporting is available for sensitive situations

## 7\. Enforcement Framework

VLT employs graduated enforcement, though severity of the violation determines the starting point. **SafeSport violations and any misconduct involving minors start at Level 3\.**

### Level 1: Warning (Minor Infractions)

**Examples:**

– Accidental spam or duplicate posts
– Minor disputes or arguments
– First-time coarse language
– Unintentional policy violations

**Action:**

– Content removal
– Formal written warning
– Education on policy violation

### Level 2: Suspension (Moderate Violations)

**Examples:**

– Repeated Level 1 violations after warning
– Verified bullying or harassment
– Inappropriate recruiting behavior
– Misrepresentation (non-fraudulent)
– NCAA recruiting rule violations

**Action:**

– 7 to 30-day account suspension
– Profile hidden during suspension
– Required acknowledgment of policy before reinstatement
– For coaches: Potential notification to institution

### Level 3: Permanent Ban (Severe Violations)

**Examples:**

– **ANY sexual misconduct** (zero tolerance)
– Grooming behavior or attempts
– Hate speech or discrimination
– Predatory behavior of any kind
– Doxxing or privacy violations causing harm
– Fraud or identity falsification
– Repeated moderate violations
– Circumventing safety features

**Action:**

– Immediate permanent ban
– IP and identity flagged to prevent new accounts
– Addition to VLT “Ineligible List”
– Referral to law enforcement (where applicable)
– Notification to institutions, NGBs, or SafeSport (where applicable)

### NCAA Reporting

Coaches found violating NCAA recruiting rules via the platform may be:

– Reported to their institution’s compliance office
– Reported to the NCAA
– Have “Verified Coach” status permanently revoked

## 8\. Appeals Process

Users may appeal enforcement decisions to ensure due process while maintaining safety.

### 8.1 How to Appeal

1. Submit appeal via the Trust & Safety Portal within **14 days** of the enforcement action
2. Include any relevant context or evidence
3. Explain why you believe the decision was incorrect

### 8.2 Appeal Review

### 8.3 Appeal Decisions

– Appeal decisions are **final**
– Users will receive written explanation of the decision
– Successful appeals result in immediate reinstatement and record correction

### 8.4 No Appeal Rights

The following have **no right to appeal** within the VLT platform:

– Users banned for CSAM or child exploitation
– Users referred to law enforcement
– Users with multiple permanent bans (ban evasion)

## 9\. Data Sharing & External Reporting

### 9.1 When VLT Shares Information

VLT may share user information with external parties when:

– **Required by law** (subpoenas, court orders, legal process)
– **Mandatory reporting** (suspected child abuse, CSAM, imminent harm)
– **SafeSport referral** (serious misconduct warranting NGB notification)
– **Institutional notification** (NCAA coaches violating rules)
– **Protecting safety** (credible threats requiring law enforcement involvement)

### 9.2 Relationship with NGBs

VLT operates independently from USA Gymnastics, NCAA, and other governing bodies. However:

– A VLT ban does not automatically constitute a ban by any NGB
– VLT reserves the right to share information with NGBs when safety is at risk
– VLT may honor bans from SafeSport or NGBs on our platform

## 10\. Policy Updates

This Policy may be updated to reflect:

– Changes in law or regulation
– Evolution of SafeSport standards
– Platform feature changes
– Community feedback and learnings

**Notification:** Users will be notified of material changes via email and in-app notification at least 30 days before changes take effect.

**Review Schedule:** This Policy is reviewed quarterly by VLT’s Trust & Safety team and annually by legal counsel.

## 11\. Contact Information

**VLT Trust & Safety Team**

– **General Safety Reports:** [](mailto:)
– **Legal Inquiries:** [legal@](mailto:)[vltgymnastics](mailto:)[.com](mailto:)
– **Anonymous Tips:** \[Link to third-party form\]
– **Emergency:** Call 911

**External Resources:**

– **U.S. Center for SafeSport:** safesport.org | 833-5US-SAFE
– **NCMEC CyberTipline:** missingkids.org/gethelpnow/cybertipline
– **National Child Abuse Hotline:** 1-800-422-4453
– **Crisis Text Line:** Text HOME to 741741

## 12\. Acknowledgment

By creating an account on VLT, all users acknowledge that they have read, understood, and agree to comply with this Safety & Conduct Policy. Violations may result in enforcement actions up to and including permanent removal from the platform and referral to law enforcement.

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