Children's Privacy Policy

Release Date: July 11, 2025

 

We understand that you provide us with your personal information or that of the children under your guardianship based on your trust in us, believing that we will handle your or the children's personal information in a responsible manner. Therefore, we have developed the "Children's Privacy Policy" ("this Policy") to protect children's personal information. This Policy forms part of the "Privacy Policy" and, on the basis of the "Privacy Policy", provides enhanced explanations and guidance for the parts of children's personal information that require strengthened protection.

This policy will detail our policies and measures regarding the acquisition, management, and protection of users' personal information. Meanwhile, we have implemented some more specific protective measures for the personal information of children that may be collected. In case of any inconsistencies between the Children's Personal Information Protection Policy and the <Our Privacy Policy>, this policy shall prevail.

 

Special Instructions for Child Guardians:

If you are the guardian of a child user, please carefully read and choose whether to agree to this policy. We hope that you will join us in protecting children's personal information, educating and guiding children to enhance their awareness and ability to protect personal information, and instructing, reminding, and requiring them not to provide any personal information to any online product or service provider without your consent.

 

Special Instructions for Children:

If you are a juvenile under 14 years of age, you need to carefully read this policy with your guardian and use our products or services after obtaining your guardian's consent.

 

This Policy contains the terms regarding our collection, use, sharing, storage, and protection of children's personal information. We recommend that guardians (hereinafter referred to as "you") read this Policy in its entirety and, when necessary, make choices that you consider appropriate and capable of protecting the rights of the children under your guardianship in accordance with the guidance of this Policy. To ensure that you fully understand the content of this Policy, we have used bold, bold and italic formatting to draw your attention to the provisions in this Policy that have or may have a significant impact on the rights and interests of the children under your guardianship.

 

  1.                 We collect and use children's information
  1. Register

You understand and agree that if the child under your guardianship wishes to use our APP, they need to register an account to become our child user.  During registration, you or the child under your guardianship need to provide us with a third-party account or mobile phone number , and we will verify the validity of the third-party account or mobile phone number by sending a SMS verification code or other means. When a child registers our account through the relevant account of a third-party platform that cooperates with us, we will share the relevant information of your child under that third-party account from the third-party platform, including the account name and account nickname (but not including real-name authentication information, etc.). For the personal information of children collected by the third-party platform, the Privacy Policy or relevant policies of the third-party platform shall apply.

  1.                 Real-name Authentication

To meet the requirements of relevant laws, regulations, policies, and relevant competent authorities, children may be required to undergo real-name authentication after registration to continue using our products and services.  We will collect children's ID card information and name during real-name authentication, which is sensitive information. Refusing to provide such real-name identity information will result in children being unable to log in or use our services.

  1.                 Guardian Information

When we identify a user as a child under 14 years old based on the above information you provided, we will collect your contact information, including mobile phone number and email address. If necessary, we will use this information to contact you and verify your guardianship relationship with the child you are caring for.  In certain products or services involving transactions, we may require the collection and binding of your bank card-related information so that you can be informed and manage the transaction behavior of child users.

We may collect information on users' commonly used devices, including hardware model, operating system type, and device identifier, to provide services for children.  Please understand that you can choose whether to fill in or provide us with specific information. However, if you do not fill in or provide certain specific information, it may cause our products or services to malfunction, or fail to achieve the intended service effects, and you and the children under your guardianship may not be able to use our products, services, or related specific business functions properly.

We strictly abide by the provisions of laws and regulations and the agreements with users, and use the collected information about you and the children under your guardianship to verify the identities of children and guardians and provide specific functions of necessary products or services. If we need to use your or the children's personal information under your guardianship beyond the above uses, we will inform you again and obtain your consent.

  1.                 Transaction information.

We will collect your order and transaction information to determine the transaction status and provide relevant information support in dispute resolution.

  1.                 When you initiate a complaint, appeal, or consultation with us,  for the security of your account and system, we may need you to provide account information first and match it with your previous personal information to verify your user identity. Meanwhile, to facilitate contact with you or help you resolve issues,  we may also need you to provide personal information such as your name, mobile phone number, and other contact details.  Additionally,  we will also collect communication information between you and us (including in the form of text, pictures, audio & video, and call records).  We collect this information to investigate facts and help you resolve issues. If you refuse to provide the above information, we may not be able to provide you with timely feedback on the results of your complaint, appeal, or consultation.
  1.                 Album function. When you use the image upload function, we will collect the information of the above image content that you actively provide. Meanwhile, with your consent, we will also access your phone's album permission to facilitate your image upload.By uploading an image, you are deemed to have authorized us to access, obtain, collect, and use your personal information; however, unless you have deleted your personal information in accordance with the law, your cancellation will not affect our processing and storage of your personal information based on your previous authorization.
  1.                 Geographical location. When you enable the location function of your device and post a dynamic,based on the location function provided by geographical location,we may collect information about your geographical location, including obtaining the time zone location,the purpose of which is to push relevant content to you at appropriate times based on the time zone you belong to. You can stop our collection of your geographical location information at any time by turning off the location function. If you refuse to provide this information, it will only prevent you from using this function, but will not affect your normal use of other functions of the product and/or service. You can enable/cancel this permission at any time through the relevant function settings of your device.
  1.                 Situations where children's personal information is shared, transferred, or disclosed
  1. Share

▪                 We value the protection of children's personal information. We strictly limit the circumstances of sharing, transferring, and disclosing children's personal information in accordance with laws and regulations.  Under normal circumstances, we will not share children's personal information with any company, organization, or individual,  except in the following situations:

  1.                   Prior explicit authorization or consent has been obtained from you;
  1.                   Sharing your personal information as required by applicable laws and regulations, legal procedures, government mandates, or judicial rulings;
  1.                   Within the scope required or permitted by law, it is necessary to provide your personal information to third parties in order to protect our interests, property, or safety, as well as those of our users or the general public, from harm.

▪                 Within the scope permitted by laws and regulations,in order to provide you with more comprehensive and high-quality products and services, we will integrate with our partners' SDKs. With your affirmative consent to the Privacy Policy, we may share certain personal information of children with our partners. We will only share your personal information for legitimate, proper, necessary, specific, and explicit purposes, and only share the personal information necessary for providing services. Meanwhile, we will sign strict confidentiality agreements with our partners, requiring them to handle children's personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

  1. Transfer

We will not transfer children's personal information to any company, organization, or individual without obtaining your affirmative consent. In the event of a merger, acquisition, or bankruptcy liquidation, personal information transfer may occur. In such cases, we will require the new company or organization that holds children's personal information to continue to be bound by this Privacy Policy. If any changes occur to the collection and processing methods of personal information as stipulated in this Privacy Policy, the company or organization will seek your authorization and consent again.

  1.                 Public disclosure

Except for the necessary disclosure required for desensitized display of user nicknames when announcing the list of winners, we will not publicly disclose children's personal information. If there are reasonable grounds for public disclosure, we will inform you of the purpose and type of the information to be publicly disclosed before the disclosure (if it involves your personal sensitive information, we will also inform you of the content of the sensitive information involved), and will publicly disclose it only after obtaining your authorized consent, except as otherwise provided by laws and regulations or otherwise agreed in this Policy.

Please be informed that, in accordance with laws, regulations, or requirements of relevant government departments, sharing, transferring, or publicly disclosing your personal information does not require prior authorization or consent from you under the following circumstances:

•                     directly related to national security or national defense security;

•                     directly related to public safety, public health, or major public interests;

•                     directly related to criminal investigation, prosecution, trial, and execution of judgment; or required by laws and regulations, administrative agencies, or authorized agencies such as public security, procuratorial, and judicial organs;

•                     When it is necessary to protect your or other individuals' major legitimate rights and interests such as life and property, but it is difficult to obtain your consent;

•                     The information is publicly disclosed by you or collected from legally public channels (such as legal coverage, government information disclosure, etc.).

•                     Necessary for the conclusion and performance of relevant agreements or other written documents signed with you;

•                     Other circumstances stipulated by laws, regulations, etc.

  1.             How to store your child's personal information
  1. Information Storage

We will adopt technical measures such as encryption to store children's personal information to ensure information security. We will not store children's personal information for longer than the period necessary to achieve the purposes for which it was collected and used. In principle, we will not transfer your child's personal information outside of China,and we will only store your child's personal information collected and generated during operations within China within China. We will only retain your child's personal information for the shortest necessary period, except where required by national laws, regulations, etc., or to fulfill our compliance obligations. When our products or services cease operations or the storage period of your and your child's personal information expires, we will notify you and your child in the form of push notifications, announcements, etc., and delete or anonymize your and your child's personal information within a reasonable period. Please refer to the "Information Security" section of our <Privacy Policy> for detailed information on how we store children's personal information.

  1.             Information Protection

We have adopted various measures, including internal management systems and technical safeguards, to protect children's personal information. We have implemented a data classification and grading system based on the sensitivity and type of data, and have imposed multi-faceted access restrictions, such as user access rights, usage scenario access rights, usage authorization rights, and graded approval mechanisms, based on the classification and grading results. Please refer to the "Information Security" section of the <Privacy Policy> for detailed information on how we store and protect personal information.

  1.             Manage children's personal information
  1. During the period when child users use our products or services, to enable you and children to more conveniently access, correct, and delete relevant personal information,  we have provided you with corresponding operation settings. You can change or delete your child's personal information by controlling your child's account,  to protect your child's information security, physical and mental health. Please understand that modifying or deleting some information requires us to verify with you. During the verification process, we may need you to provide personal information such as your child's account number, date of birth, and contact information, so that we can continue to respond to your requests after completing identity verification and issue verification.
  1. If we collect, store, use, transfer, or disclose the personal information of children in violation of laws, administrative regulations, the agreements between the parties, or beyond the scope of purpose or necessary period, you may request us to delete the personal information of the children under your guardianship. If you or the children under your guardianship terminate using our services by canceling your account or other means, you may request us to delete the personal information of the children under your guardianship.
  1.             Application of this Policy
  1. This Policy only applies to our products or services targeting children under 14 years of age. For users whose age cannot be identified or who do not proactively provide us with age information, only the <Our Privacy Policy> applies.
  1. Please understand that where this Policy does not provide for a matter, the <Our Privacy Policy> shall apply by reference. In the case of applying this Policy, if there are inconsistencies between the provisions of this Policy and those of the <Our Privacy Policy>, this Policy shall prevail.