Privacy Policy
Updated: 2024-12-02
Effective Date: 2024-12-02
You are cordially invited to utilize the "<crazy fair>" software and its associated services!
Shenzhen Blue Whale Unlimited Network Technology Co., Ltd. (hereinafter referred to as "we", "us", or "the Company") fully comprehends the significance of personal information to you. We will collect, utilize, and safeguard your personal information in strict accordance with the stipulations of relevant laws and regulations. Through this Privacy Policy, we aim to offer you a lucid explanation regarding how we handle your personal information when you make use of our products or services, as well as how we afford you the means to access, correct, delete, and protect such information.
Directory
Introduction
1.How We Collect and Use Personal Information
2.How We Use Cookies and Other Similar Technologies
3.How We Share, Transfer, and Publicly Disclose Personal Information
4.How We Store and Protect Your Personal Information
5.How Do You Manage Your Personal Information?
6.Minors Clause
7.Access, Revision, and Notification of Privacy Policy
8.Dispute Resolution
9.Contact Us
Appendix: Explanation of Terms
Attachment: A List of Permissions
Attachment: Third-party SDK Directory
Attachment: Children's Data Protection Statement
Introduction
1.This Privacy Policy is designed to assist you in understanding the following aspects:
(1) We will collect and utilize your information in line with the stipulations of this Privacy Policy. However, we will not engage in the indiscriminate collection of personal information just because you have agreed to this Privacy Policy.
(2) When you utilize or enable relevant functions or services, we will collect and make use of the relevant information that is essential for the realization of those functions and services. Unless it is necessary information for the accomplishment of basic business functions or as mandated by laws and regulations, you have the option to refuse to provide it without it affecting other functions or services. We will clarify in each of our privacy policies which information is required.
(3) In the event that you are not logged into your account, we will utilize the identifier information corresponding to the device to ensure the basic functions. If you are logged into your account, we will push information based on your account information.
(4) By default, geolocation, camera, photo album (storage), and phone permissions will not be enabled. These permissions will only be utilized to achieve specific functions or services with your explicit authorization, and you also have the option to revoke your authorization. In particular, even if we have obtained these sensitive permissions with your authorization, we will not collect your information when the relevant functions or services are not needed. For details regarding how to apply for permissions and how to use them, please refer to the Appendix: Permission List.
(5) This Privacy Policy is applicable to your access to and utilization of our products and services through the Product Application, the Product Development Kit (SDK), and the Application Programming Interface (API) for use by third-party websites and applications.
2.Special Tips
(1) Prior to using this product and/or related services, please carefully read and then decide whether to accept or reject this Privacy Policy. We have endeavored to express it in an easy-to-understand, concise, and to-the-point manner. Important content such as the terms and your personal information rights and interests have been highlighted in bold or underlined for your special attention. By using or continuing to use our products/services, you are giving your consent to the processing of your information in accordance with this Privacy Policy.
(2) If you do not agree to this Privacy Policy, we will be unable to provide you with comprehensive products and services, and you can choose to cease using them. When you opt to continue or use them again, it will be deemed that you accept and acknowledge that we will process your relevant information in accordance with this Policy based on the necessity of providing products and services.
(3) If you are under the age of 18, please carefully read and fully understand this Privacy Policy in the company of your guardian, and use our services or provide information to us with the consent of your guardian.
(4) If you have any questions regarding this Privacy Policy, you can get in touch with us through the methods provided in the "Contact Us" section of this Privacy Policy.
(5) Please note that this Policy does not apply to other third-party products/services ("other third parties", including your trading counterparty, any third-party websites and third-party service providers, etc.) that you access through our products/services.
1.How We Collect and Use Personal Information
We will gather the information that you willingly provide when using our services and also collect the information generated during your utilization of the functions or services through automated means, specifically in the following manners:
1.Basic Necessary Functions
(1) Register, Log In
When you register and log in to the Product and/or related services, you have the option to log in and use it with a third-party account. In doing so, you will authorize us to obtain the public information (such as avatar, nickname, and other details that you have authorized) registered on the third-party platform for the purpose of binding it with the product account. This enables you to directly log in and use the product and related services.
(2) Certification
When you make use of the identity authentication function or service, you might be required to provide your real identity information (including real name, ID number, phone number, etc.) in order to complete the real-name verification as per the relevant laws and regulations. To achieve the goal of identity authentication, you agree and authorize us to either provide, inquire about, or verify your aforementioned identity information to the relevant identity authentication authorities on our own or by entrusting a third party. Please note that this information is sensitive personal information, and while you may choose to refuse to provide it, doing so may result in your inability to obtain the relevant services. However, it will not impact the normal use of other functions and services.
(3) Operation and Safety Assurance
i. We are dedicated to offering you a safe and reliable product along with a secure usage environment. Providing high-quality and dependable services is our central objective. The information collected for the purpose of the security function is of essential importance. We may utilize or integrate your account information, transaction information, device information, service log information, and the information shared by our affiliates and partners with your authorization or in accordance with the law. This is done to comprehensively assess the transaction risks associated with your account, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures.
ii. Device Information and Log Information
a. To ensure the safe operation of the software and services, we will collect various details regarding your device and its usage. This includes your WLAN access point, base station, network access mode, type, status, network quality data, operation logs, and device attribute information such as [SDK version, device manufacturer, device model, device language, device name, application list information, hardware serial number, operating system and application version and type, language setting, resolution, IP address, GPS location, system platform, system version, application package name and version, and application before and after time, Unique Device Identifier, iOS Advertising Identifier (IDFA), Network Card (MAC) Address, International Mobile Equipment Identity (IMEI), Anonymous Device Identifier (OAID), International Mobile Subscriber Identity (IMSI) Base Station Information, Sensor Information, Bluetooth Information, WIFI Scan Results (WIFI List), WIFI Status Information, CPU Information, Memory Information, Battery Usage]. For the sake of ensuring the quality and efficiency of the operation, we will also collect the MAC address information of the device during the background operation of the software to evaluate the risk associated with your account.
b. To prevent malicious programs and for the necessity of security operations, we may collect information about the installed applications or running processes, the overall operation, usage, and frequency of applications, application crashes, overall installation usage, performance data, and application sources.
c. We may utilize your account information and device information [including device model, operating system and version, client version, device resolution, package name, device settings, process and software list, andriod_id/Android device unique identifier, bssid/WIFI MAC physical address, IMSI/International Mobile User Identity code, IMEI/International Mobile Equipment Identity number, iccid/mobile phone SIM card number, IDFA, OPENUDID, GUID, OAID, device MAC address, service log information, and information that our affiliates and partners may share with your authorization or in accordance with the law] to assess account security, conduct identity verification, and detect and prevent security incidents.
iii. It should be noted that device information and log information, when considered on their own, are not sufficient to identify a specific natural person. However, if we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, then during the period of combination, such non-personal information will be regarded as personal information. Unless we have obtained your authorization or are otherwise directed by laws and regulations, we will anonymize and de-identify such personal information. During the period of combination, this information will be treated and protected as your personal information in accordance with this policy.
2.Additional Business Functions
When you utilize the additional business functions of this product, with the aim of fulfilling the objective of providing you with the products and services, apart from the registration information, you are required to further supply us with your personal identification information, location information, and other details that are essential for rendering the services to you. It should be noted that if you do not engage with specific products and services, there is no need for you to provide the relevant information (the details will be elaborated below).
1.Online Events
During the process of using this product and service, we may conduct online activities related to the product for marketing and promotional purposes. Such functions may be subject to adjustments due to product version upgrades or the specific periods of the activities. In the event of participation in online activities, you are obliged to provide contact information (including your name, mobile phone number, contact address, ID number, email address, etc., depending on the rules of the specific event).
2.Customer Service
a. When you get in touch with our customer service or make use of other user response functions (such as making service inquiries, lodging personal information protection complaints or suggestions, and other customer complaints and needs), we may require you to provide necessary personal information (name, user ID, mobile phone number, email address, audio recordings, pictures, videos) in order to match and verify your user identity, thereby safeguarding the security of your account and the system.
b. We may also retain your contact information (any other contact information you utilize when contacting us or that you willingly provide to us, such as your telephone number, email), your correspondence/call records and their contents (which are personal sensitive information), along with other necessary information related to your needs. This is done so that we can contact you, assist you in resolving problems, or record the handling plans and results of related issues. It should be noted that this information is sensitive personal information, and while you may choose to refuse to provide it, doing so may result in your inability to obtain the relevant services. However, it will not impact the normal use of other functions and services.
3.Session and Available Data
"Session and Available Data" refers to the information that you provide to us regarding your utilization of the Application and Services. This encompasses, but is not limited to, data associated with your connection to the Application and Services that arises from your use of them. Session and available data includes details related to connection requests, server communications, and data sharing, such as network testing, quality of service, date, time, and location. Additionally, we are capable of centralizing sessions and available data. It should be noted that Session and Available Data does not comprise any personal information or content that you might send or share through your use of the App (for example, photos, contacts, schedules, etc.) or the Services.
4.Device Permission Call
a. To ensure the normal execution of relevant business functions, we need to invoke the corresponding necessary permissions based on the specific usage scenarios. Before doing so, we will prompt you in a pop-up window (for detailed information, please refer to Appendix: Permission List).
b. If you wish to disable some of the aforementioned specific access rights functions (such as your location information), most mobile devices will support your request. For the specific methods, please refer to or get in touch with the service provider or manufacturer of your mobile device. Please note that if you enable any of these permissions, you are authorizing us to collect and use relevant information to provide you with the corresponding services. Once you disable any of these permissions, it implies that you have revoked your authorization. Consequently, we will no longer continue to collect and use relevant information based on the corresponding permissions, nor will we be able to offer you the services associated with those permissions. However, your decision to turn off the permission will not impact the collection and use of information that was previously collected based on your authorization.
5.Advertising Push Function
a. Based on the information we have collected, we may collaborate with third-party service providers to incorporate third-party services (such as advertising, links, or other forms of promotional content) into our products and/or services. We will not share any of your personal information (such as mobile phone number, nickname, profile picture, friend list) that you provide to us or that we collect from you with third-party service providers. Nor will we collect your personal information on behalf of third-party service providers. Third-party service providers that access through our products and/or services may have their own privacy policies, which are not subject to this Privacy Policy. These third-party service providers may collect the personal information necessary to provide services to you in accordance with their own privacy policies. We will make commercially reasonable efforts to require third-party service providers to comply with relevant laws and regulations when processing your personal information and to require them to take relevant confidentiality and security measures. However, we cannot guarantee that they will take the appropriate measures as we have requested.
b. If you are using a mobile phone of brands like Xiaomi, Meizu, Huawei, etc., this product may directly or through a third party access the Push SDK of the aforementioned mobile phone manufacturer. It is necessary to collect the unique identification information of the mobile phone (such as IMEI) and may also collect parameters such as your mobile phone model, system type, system version, and device screen size to achieve the push of product and activity information. For detailed information, please refer to the privacy policy or relevant statement of the SDK operator.
c. We may collect information about the device's gravity sensor to adapt to and display new forms of programmatic advertising (such as new forms of advertising designed according to the tilt angle and shaking amplitude of the terminal device).
6.Change of Purpose of Collection and Use of Personal Information
Please be aware that as our business evolves, there may be modifications and alterations to the functions and services offered by this product. Generally speaking, when a new function or service is connected to the functions or services that we are currently providing, the personal information that is collected and utilized will be directly or reasonably associated with the original purpose of processing. However, in situations where the new purpose of collection and use is not directly or reasonably related to the original purpose of processing, we will once again notify you when we collect and use your personal information and seek your consent.
3.Information from Third Parties
1.You have the option to use a third-party account (such as WeChat) to log in to our platform. Under such circumstances, provided that it complies with relevant laws and regulations, you can decide to authorize us to access the public information (including username, nickname, profile picture) that you have registered, published, and recorded on the third-party platform. We might still require you to supply additional personal information that we need but which the third party is unable to provide. The reason for obtaining the above information from third parties is to keep track of your login identity as our user, enabling us to offer you better products and services. When you log in to our platform using a third-party account, you can select the range of personal information that you authorize us to obtain. However, it should be noted that if you revoke certain permissions, you may not be able to enjoy the optimal service experience, and some services might not function as expected. Please carefully read the user agreement or privacy policy of the third-party partner service.
2.Your information may be included in the information shared by other users.
4.Sensitive Information
Before furnishing us with any personal information that qualifies as sensitive information, please give careful thought to whether such provision is fitting and concur that your personal sensitive information may be processed for the purposes and in the manner delineated in this Policy. The definition of sensitive information can be found in Appendix: Explanation of Terms.
We will gather and utilize your sensitive information with your consent in order to fulfill functions associated with our business operations. You do, however, have the option to decline the collection and use of such sensitive information. Nevertheless, refusing to allow the use of this information will have an impact on your utilization of the relevant functions.
5.Exceptions to Obtaining Authorization and Consent
Please be aware that under the following circumstances, in accordance with laws and regulations as well as relevant national standards, we are not required to obtain your authorization and consent for the collection and use of your personal information:
1.When fulfilling obligations mandated by laws and regulations.
2.When it is directly related to national security or national defense security.
3.When it is directly related to public safety, public health, or major public interests.
4.When it is directly related to criminal investigation, prosecution, trial, and the enforcement of judgments.
5.When it is for the purpose of safeguarding the life, property, or other significant lawful rights and interests of the Personal Data Subject or other individuals, yet it is difficult to obtain the consent of the individual.
6.When the personal information collected has been made public by you yourself.
7.When your personal information is collected from legally and publicly disclosed sources, such as through lawful news reports, government information disclosure, and other channels.
8.When it is necessary for the conclusion or performance of a contract at your request.
9.When it is necessary to maintain the safe and stable operation of software and related services, for example, when it comes to detecting and handling faults in software and related services.
10.When it is necessary for legitimate news reporting.
11.When academic research institutions need to conduct statistical or academic research based on the public interest, and when the results of the academic research or descriptions are provided externally, provided that the personal information contained in the results has been de-identified.
12.In other circumstances as stipulated by laws and regulations.
It should be particularly noted that if the information cannot be used alone or in combination with other information to identify you, it does not qualify as your personal information in the legal sense. However, when your information can be used to identify you as an individual either alone or in combination with other information, or when we combine data that cannot be linked to any specific personal information with other personal information, such information will be treated and protected as your personal information in accordance with this Privacy Policy during the combined use.
2.How We Use Cookies and Similar Technologies
Similar technologies like cookies and device identifiers are widely utilized on the Internet. When you use the Product and/or related services, we may employ relevant technologies to dispatch one or more cookies or anonymous identifiers to your device for the purpose of gathering and identifying information during your access and use of the Product. We guarantee that cookies will not be used for any purposes other than those outlined in this Privacy Policy. We mainly utilize cookies and similar technologies to facilitate the following functions or services:
(1) Ensure the Safe and Efficient Operation of Products and Services
We might set up authenticated and secure cookies or anonymous identifiers that enable us to verify whether you are logging in to the Services securely or if you have encountered issues such as theft, fraud, or other illegal activities. These technologies will also assist us in enhancing service efficiency, reducing login and response times.
(2) To Help You Have an Easier Access Experience
The application of this kind of technology can assist you in avoiding the need to repeat the steps and procedures of filling out your personal information and inputting your searches.
3.How We Share, Transfer, and Publicly Disclose Personal Information
1.Sharing
(1) The Principles of Sharing
a. Principle of Authorization and Consent: The sharing of your personal information with our affiliates and third parties is conditional upon your authorization and consent. Unless the shared personal information is de-identified information where the sharing third party is unable to re-identify the natural person subject of such information. If the purpose of the related party or third party in using the information exceeds the scope of the original authorization and consent, they will need to obtain your consent again.
b. Principle of Legality, Legitimacy and Minimum Necessity: The data shared with related parties and third parties must serve a legitimate and legal purpose, and the shared data must be necessary to achieve that purpose.
c. Principle of Security Prudence: We will meticulously evaluate the purpose of data use and sharing by related parties and third parties, conduct a comprehensive assessment of the security guarantee capabilities of these partners, and require them to comply with the cooperation legal agreement. We will strictly monitor the security of the software tool development kit (SDK) and application programming interface (API) of the partner through which information is obtained to safeguard data security.
(2) We are Duty-bound to Keep Your Information Confidential and Will Not Sell or Trade Any of Your Information, Except in the Following Circumstances:
a. Sharing under Statutory Circumstances: We may share your personal information externally in accordance with the provisions of laws and regulations, for litigation and dispute resolution, or as required by administrative and judicial authorities in accordance with the law.
b. Sharing with Explicit Consent: With your explicit consent, we will share your personal information with other parties. Also, to the extent required or permitted by law, it is necessary to provide your personal information to third parties in order to protect the interests, property or safety of us, our users or the public.
c. Sharing with Affiliates: To enable us to provide you with products or services based on the platform account and to identify whether the account is abnormal, your personal information may be shared with our affiliates and/or their designated service providers. We will only share necessary personal information and be bound by the purposes stated in this Privacy Policy. In the event that we share your sensitive personal information or our affiliates change the purpose of use and processing of personal information, we will seek your authorization and consent again.
d. Sharing with Authorized Partners: To offer you better and high-quality products and services, we may entrust authorized partners or utilize third-party SDK-related technologies to provide you with services or perform functions on our behalf. We will only share your information for the legitimate, legal, necessary, specific and explicit purposes stated in this Privacy Policy. Our partners will only have access to the information necessary for them to perform their duties, and they shall not use this information for any other purpose.
(3) Currently, our authorization information encompasses the following:
i. Shared Information to Enable a Feature or Service
a. When you utilize the functions provided by our affiliates and third parties within our products or services, or when software service providers, smart device providers, and system service providers collaborate with us to offer services to you jointly, we will share the information necessary for realizing the business with these affiliates and third parties to actualize the required service capabilities of the products.
b. Geolocation Services: When you make use of geolocation-related services, we will share the device location information with the location service provider through SDK or related technologies so that we can present the location results to you. This includes: IP information, GPS information, WLAN access point and base station sensor information. Note that GPS information is sensitive personal information, and declining to provide it will only impact the functionality of the geolocation service, without affecting the normal use of other functions.
c. To adapt the message push function to the terminal model you are using, we may share the model, version, and related device information with the terminal device manufacturer (such as Meizu, Huawei, OPPO, VIVO, Xiaomi, Samsung, etc.) through SDK and other technologies. For more details, please refer to the privacy policy or relevant statement of the SDK operator.
ii. Enabling the Sharing of Information Related to Advertising
We may collaborate with third-party advertising partners to serve you advertisements. Our partners include, but are not limited to, Tencent, etc. Our partners may collect hardware and software information, such as IP address, device ID and type, advertising ID, device language, operating system, time zone, location information, and identifiers associated with cookies or other technologies that can uniquely identify your device. The collection and processing of information by these partners will comply with their own privacy policies and will not be subject to this Policy. To safeguard your legitimate rights and interests, if you discover that there is a risk, it is recommended that you immediately halt the relevant operation and contact us promptly.
a. Advertising Push: We may share information with partners who entrust us to conduct promotion and advertising. We will not share information (such as name, ID number) used to identify you personally, but will only supply these partners with indirect portrait tags that cannot identify you personally, along with de-identified or anonymized information, to assist them in enhancing the effective reach rate of advertisements without identifying you personally.
b. Advertising Statistics: We may share analytics and de-identified statistical information with service providers, vendors, and other partners of our business that are difficult to associate with your identity information. This will help us analyze and measure the effectiveness of advertising and related services.
iii. Realize the Sharing of Information for Security and Analysis Statistics
a. Ensuring the Security of Use: We place great emphasis on the security of accounts and services. To protect the security of your and other users' accounts and property, and to safeguard the legitimate rights and interests of you and us from illegal infringement, we and our affiliates or service providers may share necessary device information, account and log information.
b. Analyze Product Usage: To analyze the use of our services and improve the user experience, we will share statistical data on product usage (such as crashes, flashbacks) with affiliates or third parties. These data are difficult to combine with other information to identify your personal identity.
iv. Third-Party Services
We may link to social media or other services (including websites or other forms of service) provided by third parties. This includes:
a. You can use the "Share" button to share certain content with a third-party service, or you can use a third-party service to log in to your account. These functions may collect information about you (including your log information) and may install cookies on your computer to ensure the proper functioning of the above functions.
b. We provide you with links through advertisements or other means of our Services that enable you to link to third parties' services or websites.
c. Other situations of accessing third-party services. For example, to achieve the purposes stated in this Policy, we may access third-party SDK services and share some of your personal information collected by us in accordance with this Policy with such third parties to provide better customer service and user experience (see Appendix: Directory of Third-Party SDKs Accessed for details).
These third-party social media or other services are operated by the relevant third parties. Your use of such third parties' social media services or other services, including any information you provide to such third parties, is subject to the third party's own terms of service and information protection statement, not this Policy. You need to read their terms carefully. This Policy applies only to the personal information we collect, and does not apply to any services provided by third parties or the rules governing the use of information by third parties. If you find that these third-party social media or other services are at risk, we recommend that you terminate the relevant operations to protect your legitimate rights and interests.
2.Assignment
(1) We will not transfer your personal information to any other third party without obtaining your explicit consent.
(2) As our business continues to develop, we may engage in mergers, acquisitions, and asset transfers. In such cases, your personal information might be transferred as a result. In the event of these changes, we will require the successor to safeguard your personal information in accordance with laws and regulations and security standards that are no lower than those stipulated in this Privacy Policy. Otherwise, we will demand that the successor obtain your authorization and consent once again.
3.Disclosure
(1) We will not publicly disclose your information unless we are in compliance with national laws and regulations or have obtained your consent. When we publicly disclose your personal information, we will implement security protection measures that meet industry standards.
(2) When announcing penalties for illegal accounts and fraudulent activities, we will disclose the information of the relevant accounts.
(3) For public welfare projects like "tracing people" and "chasing fugitives", we will publicly disclose information related to the incident in accordance with the provisions of laws and regulations and with express authorization. Once the incident is over, we will promptly delete the disclosed personal information.
4.Circumstances Where Personal Information Can Be Shared, Transferred, or Publicly Disclosed Without Obtaining Consent in Accordance with the Law
Please be aware that under the following circumstances, in accordance with laws, regulations, and national standards, we are not required to obtain your authorization and consent to share, transfer, and publicly disclose your personal information:
(1) When it is related to national security and national defense security.
(2) When it is related to public safety, public health, or major public interests.
(3) When it is related to criminal investigation, prosecution, trial, or enforcement of judgments.
(4) When it is for the purpose of protecting the life, property, and other significant legitimate rights and interests of you or other individuals, but it is difficult to obtain the consent of the individual.
(5) In other circumstances to safeguard the public interest, for example, when your credit evaluation information needs to be disclosed or shared.
(6) When you disclose your personal information to the public.
(7) When personal information is collected from legally and publicly disclosed information, such as through lawful news reports, government information disclosure, and other channels. However, this is subject to the condition that unless you expressly refuse or the processing of the information infringes on your major interests.
According to the law, if we share, transfer, or publicly disclose de-identified personal information and ensure that the data recipient cannot recover and re-identify the personal information subject, we will handle such data without further notifying you or obtaining your consent.
4.How We Store and Protect Your Personal Information
1.Storage of Personal Information
(1) Storage Period: We will retain your personal information for only the shortest duration required to fulfill the purpose of providing this product and service. Once the necessary period elapses, we will either delete or anonymize your personal information, unless otherwise stipulated by laws and regulations.
(2) Storage Area: In line with the provisions of laws and regulations, we will store the personal information that we collect and generate during our domestic operations within the territory of the People's Republic of China. Currently, we do not transfer the aforementioned information overseas. However, if we do transfer it overseas in the future, we will comply with relevant national regulations or obtain your consent.
2.Measures for the Protection of Personal Information
(1) We place great emphasis on the security of your personal information and will make every effort to adopt reasonable security measures (covering both technical and administrative aspects) to safeguard your personal information and prevent it from being accessed, publicly disclosed, used, modified, damaged, lost, or leaked in an improper or unauthorized manner.
(2) We will utilize encryption technology, anonymization, and other reasonable and feasible means that are on a par with or better than those of our industry counterparts to protect your personal information and employ security protection mechanisms to fend off malicious attacks on your personal information.
(3) We will set up a specialized security department, a security management system, and a data security process to guarantee the security of your personal information. We have strict data use and access policies in place to ensure that only authorized personnel can access your personal information and will conduct timely security audits of data and technology.
(4) Despite having implemented the above reasonable and effective measures and having complied with the standards mandated by relevant laws and regulations, please understand that due to technical limitations and the existence of various malicious means, it is impossible to ensure 100% information security in the Internet industry. Even if we do our utmost to 强化 security measures, we will still try our best to ensure the security of the personal information you provide to us. You acknowledge and understand that the systems and communication networks you use to access our services may encounter problems that are beyond our control. Therefore, we highly recommend that you take proactive measures to protect the security of your personal information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account password and related personal information to others.
(5) We will formulate an emergency response plan and promptly activate the emergency plan in the event of a user information security incident, striving to prevent the impact and consequences of such security incidents from expanding. In the event of a user information security incident (such as leakage or loss), we will, in accordance with the requirements of laws and regulations, promptly notify you of the basic situation and possible impact of the security incident, the measures we have taken or will take to handle it, the suggestions you can independently implement to prevent and reduce risks, and the remedial measures available to you. We will promptly convey the relevant circumstances of the incident to you through push notifications, emails, letters, text messages, and other related means. If it is difficult to notify you individually, we will make an announcement in a reasonable and effective manner. At the same time, we will also report the handling of user information security incidents in accordance with the requirements of relevant regulatory authorities.
(6) Special Reminder: Once you exit this product and/or related services and start browsing or using other websites, services, and content resources, we will not possess the ability or have a direct obligation to protect any personal information you submit on software or websites other than this product and/or related services, regardless of whether you log in, browse, or use the aforementioned software or websites via links or guides from this product.
5.How You Manage Your Personal Information
1.Accessing and Correcting Your Personal Information
Except when mandated by laws and regulations, you are entitled to access and correct your personal information whenever you wish. Should you need to access or correct any other personal information that has been generated during your use of our products and/or services, please do not hesitate to get in touch with us. We will respond to your request in the manner and within the time limit specified in this Privacy Policy.
2.Change the Scope of Your Authorization and Consent or Withdraw Your Authorization
(1) You have the option to modify the extent of your authorization for us to keep collecting personal information or to revoke your authorization. This can be achieved by means such as deleting information, disabling device functions, or making privacy settings on our website or software. Additionally, you can withdraw all authorizations for us to continue gathering your personal information by canceling your account.
(2) Regarding how to adjust or revoke permission settings, you can turn off the permission function within the operating system of the device itself. It should be noted that once you take the above actions, we will be unable to continue providing you with the services associated with the withdrawal of consent or authorization. However, this will not impact the processing of personal information that has already been conducted based on your prior authorization.
(3) You are aware that each business function typically requires certain basic personal information to be fulfilled. After you withdraw your consent or authorization, we will not be able to carry on providing you with the services corresponding to the withdrawal of consent or authorization, nor will we handle your relevant personal information. Nevertheless, your decision to withdraw your consent or authorization will not affect the processing of personal information that was previously carried out based on your authorization.
3.Cancel Your Account
You can directly apply for account cancellation within our products. You can access the "Settings - Cancel" option through the mobile app to finalize the account cancellation process. Once you cancel your account, we will cease providing you with products and/or services. In accordance with your request, we will either delete or anonymize your personal information, unless otherwise stipulated by laws and regulations.
4.Notify You of the Cessation of Operations
In the event that we discontinue our operations, we will promptly halt the collection of your personal information. We will notify you of the cessation of operations either on an individual basis or through a public announcement. Additionally, we will delete or anonymize the personal information that is in our possession.
5.Respond to Your Requests
If you are unable to access, correct, or delete your personal information using the aforementioned methods, or if you need to access, correct, or delete other personal information that has been generated as a result of your use of our products and/or services, or if you believe that we have violated any laws and regulations or the agreements we have with you regarding the collection or use of personal information, you can get in touch with us using the contact information provided in this Privacy Policy. For security reasons, we may ask you to submit a written request or to provide proof of your identity. We will respond to your request within 15 business days of receiving your feedback and verifying your identity. In principle, we do not levy a fee for your reasonable requests. However, we will impose a certain cost fee for requests that are unreasonably repetitive, require excessive technical means (such as the need to develop new systems or make fundamental changes to current practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup tapes).
6.Minors Clause
1.Guardian Consent
(1) If you are a minor who is under 18 years old, you are required to read and consent to this Privacy Policy under the supervision and guidance of your parents or other guardians prior to using this product and/or related services.
(2) We safeguard the personal information of minors in accordance with the stipulations of relevant national laws and regulations. We will only collect, utilize, store, share, transfer, or disclose the personal information of minors when it is permitted by law, with the explicit consent of parents or other guardians, or when it is necessary for the protection of minors. In the event that we discover that we have collected personal information from minors without obtaining prior verifiable parental consent, we will make an effort to delete the relevant information as quickly as possible.
(3) If you are the guardian of a minor and have any inquiries regarding the personal information of the minor under your guardianship, please get in touch with us through the contact information publicized in this Privacy Policy.
2.Special Protection for Children
(1) We will take the following additional measures to safeguard the personal information of children under the age of 14 that might be involved. Regarding the personal information collected from children, aside from conforming to the stipulations in this Privacy Policy regarding users' personal information, we will also adhere to the principles of legitimate necessity, informed consent, clear purpose, security, and lawful use. We will strictly abide by the requirements of laws and regulations such as the Provisions on the Protection of Children's Personal Information on the Internet and will not exceed the period necessary to achieve the purpose of collection and use. Once that period expires, we will delete or anonymize the children's personal information. For more details on the special protection of children, please refer to the Appendix: Children's Data Protection Statement.
(2) If we discover that we have collected the personal information of minors without obtaining the prior consent of a verifiable parent or legal guardian, we will attempt to delete the relevant data as quickly as possible.
3.Anti-Addiction
(1) We place great emphasis on protecting the personal information of minors and are continuously exploring updated methods to safeguard it.
(2) We will actively protect the legitimate rights and interests of minors by activating the anti-addiction system in accordance with the requirements of the national anti-addiction policy. We will verify the real-name identity and other information to determine whether the real-name information of the relevant account is that of a minor and then decide whether to include the account in the anti-addiction system. Additionally, we will collect information such as your login time and game time, guide minors to play reasonably by automatically intervening and limiting minors' game time at the system level, enabling the forced offline function, etc., and attempt to contact their guardians for reminders, confirmation, and handling after suspected minors make purchases, so as to help minors use the Internet in a healthy manner.
(3) If you are the legal guardian of a minor, please pay attention to whether the minor under your guardianship uses our services or provides his/her personal information after obtaining your authorization and consent. If you have any questions about the personal information of the minor under your guardianship, please contact us through the contact information in this Agreement.
(4) Special Note: The anti-addiction system is only applicable when this product is recognized as a game product and connected to the anti-addiction system.
1.
7.Access, Revision, and Notification of Privacy Policy
1.Access to Privacy Policy
(1) You can view the complete content of this Privacy Policy when you visit the App welcome page for the first time. Additionally, you can also access the full text of this Privacy Policy within the Settings - Privacy Policy option.
(2) Please be aware that the products and/or related services referred to in this Privacy Policy may differ based on factors such as the mobile phone model, system version, software application version, and mobile client that you are using. The actual products and services you end up using will determine the applicable scope.
2.Revision and Notification of Privacy Policy
(1) To offer you improved services, this product and/or related services will undergo occasional updates and modifications. Correspondingly, we will also revise this Privacy Policy from time to time. The revised versions will become an integral part of this Privacy Policy and carry the same legal effect as the original.
(2) Once this Privacy Policy has been updated, we will release an updated version of the product and will notify you of the updated content in an appropriate manner before the updated terms come into effect. This enables you to stay informed about the latest version of this Privacy Policy. By continuing to use our services, you are agreeing to accept and be bound by the revised Policy.
8. Dispute Resolution Mechanisms
(1) Regarding this Agreement, all aspects including its establishment, the determination of its effectiveness, the process of performance, the proper interpretation, as well as the resolution of any disputes that may arise, shall be subject to the laws of mainland China. This means that in any situation where legal matters related to this Agreement are in question, the legal framework and regulations of mainland China will serve as the guiding principles for making judgments and decisions.
(2) In the event that any dispute or controversy emerges between you, as the user, and us, the service provider, specifically due to the policies outlined in this Agreement, the initial approach to resolving such issues will be through friendly negotiation. We firmly believe that open and amicable communication can often lead to satisfactory solutions. During this negotiation process, both parties are expected to express their concerns and viewpoints clearly and work towards finding a common ground.
However, if despite our best efforts, the negotiation does not result in a resolution, then you hereby agree to submit the dispute or controversy to the jurisdiction of the people's court located in the area where our company is situated. This ensures that there is a clear and established legal pathway for resolving any lingering issues that cannot be settled through negotiation.
9. Contact Information and Product Operation Details
(1) Contact Feedback Channel: Should you have any complaints, suggestions, or questions pertaining to the protection of your personal information, we have established a dedicated contact point for you. You can send your concerns to the email address: [email protected]. Once we receive your message, our team will take steps to verify your user identity. After successful verification, we are committed to providing you with a reply to your complaints and reports within 15 working days. This timeframe is set to ensure that you receive timely feedback on the matters you have raised, allowing for efficient communication and resolution of any potential issues.
(2) Product Operation and Service Providers: It's important for you to know that this product is under the operation and service management of Shenzhen Blue Whale Unlimited Network Technology Co., Ltd. and its affiliated entities. These organizations work together to ensure the smooth running of the product, delivering the services you expect and safeguarding your rights and interests as a user.
This Privacy Policy was last updated and made public on April 22nd, 2024, and it came into effect immediately upon publication. This means that from that date onwards, all the provisions and regulations stated within this policy are applicable to your use of our product and services.
Appendix: Explanation of Terms
Unless otherwise stipulated in a separate agreement, the terms employed within this Privacy Policy generally hold the following specific definitions:
1.Personal Information (as defined in GB/T 35273-2020 "Information Security Technology, Personal Information Security Specification"): This pertains to information that is either recorded electronically or by other means and has the capacity to identify a particular natural person or mirror the activities of a specific natural person, either on its own or when combined with other pieces of information.
The personal information that might be encompassed within this Privacy Policy comprises several categories. Firstly, the basic information of a natural person, which includes details such as name, address, telephone number, and e-mail address. Secondly, personal identification information, with the ID number being a prime example. Thirdly, network identification information, which encompasses elements like system account number, IP address, email address, as well as passwords and the corresponding password protection answers related to the aforementioned items. Fourthly, personal property information, such as bank account numbers, passwords associated with them, transaction and consumption records, virtual currency, details regarding virtual transactions, redemption codes, and other forms of virtual property information. Fifthly, address book information is also considered part of personal information. Sixthly, personal Internet access records, which consist of website browsing records and software usage records. Finally, device information is included, covering aspects like hardware serial number, hardware model, device MAC address, operating system type, software list, unique device identifier, MAC address, andriod_id/Android device unique identification, bssid/WIFI MAC physical address, IMSI/International Mobile User Identification Number, IMEI/International Mobile Equipment Identity Number, iccid/mobile SIM card number, along with personal location information that includes approximate geographic location, precise location information, longitude, and latitude. The specific types of personal information that we actually collect will be in line with the descriptions provided above.
2.Personal Sensitive Information (as per GB/T 35273-2020 "Information Security Technology Personal Information Security Specification"): This refers to personal information that, if leaked, illegally provided, or misused, has the potential to endanger personal and property safety and can readily result in harm to personal reputation, physical and mental health, or lead to discriminatory treatment.
The sensitive personal information that could be involved in this Privacy Policy includes your personal property information, personal identification information (with the ID number being a key element), network identification information, address book information, precise location information, and contact address. The specific types of sensitive personal information that we actually collect will be subject to the descriptions detailed above.
3.Device: This term designates a device that can be utilized to access our products and/or services. Examples of such devices include a desktop computer, laptop, tablet, or smartphone.
4.SSL (Secure Socket Layer), also known as Secure Socket Layer: It is a security protocol that is implemented on the transmission communication protocol (TCP/IP). SSL is capable of supporting various types of networks and offers three fundamental security services. All of these services make use of public and symmetric key technologies to maintain the privacy of information.
5.Cookies: These are small files that contain strings of characters. When you log in to and use a website or other web content, these cookies are either sent to or stored on your computer, mobile device, or other device (usually in an encrypted manner).
6.De-identification/Anonymization: This denotes the process of subjecting personal information to technical processing in such a way that the subject of the personal information cannot be identified without the aid of additional information, and the processed information cannot be restored to its original identifiable state.
7.Server Logs: Under normal circumstances, our servers automatically record the web page requests that you make when you visit the website. These "server logs" typically contain details such as your web request, Internet Protocol address, browser type, browser language, the date and time of the request, and one or more cookies that uniquely identify your browser.
8.Affiliates: This term refers to companies and institutions that either control, are controlled by, or are under common control with us, both in the present and in the future. The concept of control here implies the ability to directly or indirectly influence the management/operation of the controlled object through means such as ownership, voting shares, contracts, actual operational associations, or other legally recognized means.
Attachment: A List of Permissions
【Permission Description】
1.To guarantee the proper functioning and the safe, stable operation of our product, we might request or utilize the relevant permissions provided by the operating system. This is essential as it enables us to deliver all the intended features and maintain a seamless user experience without any disruptions or security risks.
2.With the aim of safeguarding your right to be informed, we present the relevant operating system permissions that our product may seek and utilize through the following list. You have the freedom to manage these permissions in accordance with your actual requirements. This allows you to have more control over what access the product has to your device's resources and functions, ensuring your privacy and device security are maintained according to your preferences.
3.As the product undergoes upgrades, the types and purposes associated with the application and use of these permissions are likely to change. We will promptly adjust this list in line with such alterations to ensure that you are promptly notified about any new or modified permissions being requested or used. This way, you can stay updated on how the product interacts with your device's operating system and make informed decisions regarding permission management.
4.It should be noted that for the functional and security necessities of our business and products, we may also incorporate third-party Software Development Kits (SDKs). These third parties, in turn, may also request or utilize relevant operating system permissions. When using third-party SDKs, we take measures to ensure that the permissions they request are legitimate and in line with our overall privacy and security policies, but it's important for you to be aware that these additional permissions may be involved.
5.During the process of using our product, you may come across H5 pages or mini-programs developed by third parties. These plug-ins or mini-programs, due to the requirements of their business functions, may also need to request or utilize relevant operating system permissions. Similar to the use of third-party SDKs, we strive to manage and monitor these external elements to ensure that the permissions they request do not pose any unnecessary risks to your device or privacy, but again, it's crucial for you to be aware of such potential permission requests from these third-party components.
【List of Permissions】
android.permission.READ_EXTERNAL_STORAGE
Permission function description: Provides the function of reading data in the storage space of the phone
Usage Scenario and Purpose: Allow the App to read the stored pictures, files, and other content
android.permission.ACCESS_NETWORK_STATE
Permission Function Description: Allows the application to view the network status
Usage Scenario and Purpose: View the current network status
android.permission.WRITE_EXTERNAL_STORAGE
Permission Function Description: Provides the function of writing to external storage
Usage Scenario and Purpose: Allows the App to write/download/save/modify/delete pictures, files and other information
android.permission.READ_PHONE_STATE
Permission function description: Provide information such as reading mobile phone device identification, please rest assured that this permission cannot listen to or obtain any of your call content and information
Usage Scenario and Purpose: Read the device identification code, identify the mobile device ID, and use it for advertising display, data analysis, and product safety and other main functions.
android.permission.ACCESS_COARSE_LOCATION
Permission function description: Obtain the user's rough latitude and longitude information through WiFi or mobile base station
Usage Scenarios and Purposes: Use the coarse location source of the mobile network database, which is commonly used in advertising scenarios to obtain advertising configuration information according to the location strategy
android.permission.ACCESS_FINE_LOCATION
Permission function description: Receive the positioning information of the satellite through the GPS chip
Usage Scenarios and Purposes: In advertising SDKs such as ByteDance and Tencent, the advertising efficiency is optimized by obtaining location information according to the configuration strategy
android.permission.ACCESS_WIFI_STATE
Permission Description: Obtain the status of the current Wi-Fi access and the information of the Wi-Fi hotspot
Usage Scenario and Purpose: When the network is connected, the app checks the wifi connection status
android.permission.BLUETOOTH
Permission function description: Allows the program to connect to paired Bluetooth devices
Usage Scenario and Purpose: Connect and pair Bluetooth devices
android.permission.CALL_PHONE
Permission Function Description: Allows the program to enter a phone number from a non-system dialer
Usage Scenario and Purpose: The application dials from a non-system dialer
android.permission.CAMERA
Permission function description: Allow access to the camera to take pictures
Usage Scenario and Purpose: Shoot with a camera
android.permission.CHANGE_NETWORK_STATE
Permission Feature Description: Allows the application to change the network connection status
Usage Scenario and Purpose: The application switches the network state to ensure the normal operation of the product
android.permission.CHANGE_WIFI_STATE
Permission Description: Change the WiFi status
Usage Scenario and Purpose: Change the WiFi status
android.permission.DISABLE_KEYGUARD
Permission Function Description: Allow the program to disable the keypad lock
Usage Scenario and Purpose: Disable the keypad lock
android.permission.GET_TASKS
Permission Description: Allows the program to get the current or recently running app
Use Scenario and Purpose: The application is used when the context is collected at the time of a crash
android.permission.INTERNET
Permission function description: Access the network connection
Usage Scenarios and Purposes: Access network connections for app and server network communication
android.permission.MODIFY_AUDIO_SETTINGS
Permission Function Description: Modify the sound setting information
Usage Scenario and Purpose: Modify the sound setting information
android.permission.RECORD_AUDIO
Permission function description: Record sound through the microphone of your phone or headphones
Usage Scenario and Purpose: The app records sound through the microphone of your phone or headphones
android.permission.REORDER_TASKS
Permission Function Description: Reorder tasks running on the Z-axis of the system
Use Scenario and Purpose: The application reorders the tasks in the running system
android.permission.SYSTEM_ALERT_WINDOW
Permission Function Description: The system window is displayed
Usage Scenario and Purpose: Display the system window
android.permission.VIBRATE
Permission Feature Description: Allows the app to control the vibrator
Usage Scenario and Purpose: Used to prompt the user when the application receives a notification
android.permission.WAKE_LOCK
Permission Feature Description: Allows to prevent application processes from sleeping or screen dimming
Usage Scenario and Purpose: The app stays running after the phone screen is turned off
android.permission.WRITE_SETTINGS
Permission Description: Allows you to read and write system settings
Usage Scenario and Purpose: The application reads and writes system settings
android.permission.REQUEST_INSTALL_PACKAGES
Permission Feature Description: Allow apps to install apps from unknown sources
Usage Scenario and Purpose: The application installs applications from unknown sources
android.permission.QUERY_ALL_PACKAGES
Permission Feature Description: Allows the app to get other apps that are installed on the current device
Usage Scenario and Purpose: Get other apps installed on the current device
android.permission.FLAG_GRANT_READ_URI_PERMISSION
Permission Function Description: Application inter-process communication
Usage Scenario and Purpose: Used for inter-process communication of applications
com.asus.msa.SupplementaryDID.ACCESS
Permission Feature Description: Allows applications to obtain anonymous device identifiers through the Mobile Security Alliance
Use Scenario and Purpose: Obtain anonymous device identifiers through the Mobile Security Alliance
freemme.permission.msa
Permission Feature Description: Allows applications to obtain anonymous device identifiers through the Mobile Security Alliance
Use Scenario and Purpose: Obtain anonymous device identifiers through the Mobile Security Alliance
android.permission.READ_PRIVILEGED_PHONE_STATE
Permission function description: Allow the application to adapt to a higher version (Android Q and above) in order to obtain the device identifier
Usage Scenario and Purpose: The application obtains the device identifier
Attachment: Children's Data Protection Statement
We are wholeheartedly dedicated to safeguarding the personal information of children who utilize our products or services. The Children's Information Protection Statement (hereinafter referred to as "this Statement") along with the Privacy Policy are formulated to elucidate to guardians (hereinafter referred to as "you") and children how we gather, utilize, store, and handle children's personal information, as well as the means by which we afford you and your children the opportunity to access, correct, delete, and protect this information. Unless otherwise stipulated, the terms and abbreviations employed in this Statement carry the same connotations as those in the User Agreement and Privacy Policy.
Special Instructions
1.Special Instructions for Children's Guardians:
Should you be the guardian of a child user, please peruse this statement carefully and then decide whether to consent to it. We anticipate that you will collaborate with us to protect children's personal information, educate and guide children to heighten their awareness and capabilities regarding personal information protection, and direct, remind, and require them not to furnish any personal information to any network product and service providers without your explicit consent.
2.Special Instructions for Children:
(1) If you are a minor under the age of 14, it is necessary for you to read this statement attentively in the company of your guardian and only use our products and services or provide us with information upon obtaining the consent of your guardian.
(2) Please carefully consider and fully understand the Privacy Policy and this statement before choosing whether to consent to the relevant privacy policy and whether to permit you and the children under your guardianship to use our products or services. If you do not concur with the relevant privacy policy and the contents of this statement, or if you do not agree to supply the requisite information for service provision, it might result in our products or services failing to operate normally, or being unable to achieve the intended service outcomes, and you and the children under your guardianship may be unable to utilize our products, services, or related specific business functions in the normal manner.
By clicking "Agree", you are signifying your agreement to our collection, use, and processing of your and your children's information in accordance with the Privacy Policy and this Statement.
(3) Please be aware that this statement is only applicable to our products or services that are specifically crafted for children under the age of 14, products or services with functional sections explicitly designed for children under the age of 14, or products or services that mandate the user to input their date of birth, age information, and other such products or services that can identify the user's age. For products or services that are incapable of or do not actively identify the age of users, the Privacy Policy shall apply. The products and services we offer may encompass those provided by third parties, and you may also log in and utilize third-party products and services via QQ, WeChat, Weibo. Please note that such third parties may collect, use, or process information regarding children, and these third parties are required to obtain your separate consent. We suggest that you seek your child's consent before authorizing the third party to collect and process any of their personal information.
(4) We would like to remind you that the crucial terms in this statement that are (potentially) closely associated with the rights and interests of you and the children under your guardianship are (possibly) of great significance to you, and we have utilized bold fonts to draw your special attention to them. Please take note of these.
(5) If you have any queries or requests pertaining to rights related to personal information during the process of reading this statement, we have furnished you with contact information, and we will respond to you as promptly as possible.
1.What Information We Collect
We are committed to strict compliance with the provisions of relevant laws and regulations as well as the agreements we have with users. Based on the specific circumstances of users' choices regarding our products or services, we collect the following personal information of you and the children under your guardianship.
For our products and services that are specifically designed for children under the age of 14, certain functional sections within our products or services, or those products or services that require users to input their date of birth, age information, etc., which can be used to identify the age of users, such as during the registration or usage of these products or services, we will prompt users to fill in their personal birthday information. This is to determine whether the user is a child under the age of 14. In line with the stipulations of laws and regulations, only after obtaining the consent of their guardians will children be permitted to continue using the relevant products or services.
Once we identify a user as a child under the age of 14 based on the information provided by the user as mentioned above, we will collect your contact information, including your mobile phone number and email address. We will utilize this information to get in touch with you for the purpose of verifying the guardianship relationship between you and the child under your guardianship. Depending on the specific verification plan of the product or service regarding the guardianship relationship and obtaining your consent, we may also link your account with the child's account to safeguard the personal information rights and interests of both you and the child under your guardianship. In some products or services that involve transactions, we may require you to collect and bind your bank card information so that you can keep track of and manage the transaction activities of the child users. If the product or service includes functions like uploading avatars, we highly recommend that you guide your children not to upload real personal portrait photos and other similar information during their use of our products or services.
During the process of children using our products or services, we will collect relevant information. For details about other personal information of children that we collect, please refer to our Privacy Policy.
Should we need to collect personal information about you or the children under your guardianship beyond the scope of what has been mentioned above, we will notify you once again and seek your consent.
Please be aware that you have the option to decide whether to fill in or provide us with specific information. However, if you choose not to fill in or provide certain specific information, it might lead to our products or services not operating normally, or failing to achieve the intended service outcomes, and you and the children under your guardianship may not be able to use our products, services, or related specific business functions in the usual manner.
2.How We Use This Information
We are firmly committed to strictly adhering to the provisions of relevant laws and regulations as well as the agreements we have with users. The information collected from you and the children under your guardianship is utilized for the following purposes:
(1) Verifying the Identity of the Child and Guardian
We use the collected information to accurately confirm the identity of the child and the corresponding guardian, ensuring that the services and interactions are carried out in a legitimate and secure manner.
(2) Providing Necessary Products or Services, and Specific Functions of Products or Services
This information enables us to offer the appropriate products or services that meet the specific needs of children and guardians. It also allows for the seamless operation of various specific functions within our products or services, enhancing the overall user experience.
(3) For Product or Service Optimization, Safety Assurance, and Service Investigation Purposes
We analyze the collected data to continuously improve our products or services, making them more efficient, user-friendly, and secure. Additionally, it helps us conduct investigations related to the services to better understand user behavior and preferences, thereby enabling us to make more informed decisions for further enhancements.
If we need to use your personal information or that of the children under your guardianship for purposes beyond those mentioned above, we will notify you once again and obtain your consent.
III. Circumstances of Sharing, Transferring, or Disclosing Children's Personal Information
In strict accordance with the provisions of laws and regulations, we exercise stringent control over the sharing, transfer, and disclosure of children's personal information. Generally speaking, we refrain from sharing children's personal information with third parties without proper authorization. We will only share children's personal information with third parties upon obtaining the prior consent of the guardian.
(1) Sharing
We will share certain aspects of the child's personal information (such as the child's user name, account number, password, and details of the child's transactions within some of our products and services) with the guardian. This allows the guardian to access and manage the relevant personal information, thereby facilitating their oversight and control over the child's online activities.
For the purpose of external processing, we may share children's personal information with third-party partners (including third-party service providers, contractors, agents, application developers, etc., for example, communication service providers who send emails or push notifications on our behalf, and map service providers who provide us with location services) (they may not be located in your jurisdiction). These third-party partners will process the above information for us in accordance with our instructions, privacy policy, and relevant confidentiality and security policies.
If we entrust a third party to process children's personal information, we will conduct a thorough security assessment of the entrusted party and the entrusted behavior. We will also sign an entrustment agreement, stipulating that the entrusted party must process the personal information of children within the scope of our authorization. The main purposes for which we entrust the third party to process children's personal information are as follows:
(1) To provide our services to children;
(2) For the purposes described in the "How We Use this Information" section;
(3) To fulfill our obligations and exercise our rights as stated in the Privacy Policy and this Statement;
(4) To understand, maintain, and improve our services.
When sharing your and children's information with the above-mentioned third parties, we will conduct a security assessment and employ encryption, anonymization, de-identification and other means to ensure the security of your and children's information.
(2) Transfer
As our business continues to develop, in the event that a merger, acquisition, asset transfer, or other such transaction occurs which leads to the sharing of your and children's personal information with a third party, we will notify you of the relevant circumstances via push notifications, announcements, and the like. Moreover, we will continue to safeguard, or require the new management to continue to safeguard, your and children's personal information in accordance with laws and regulations and standards that are no less stringent than those stipulated in this statement.
We may anonymize the collected children's information and utilize it for big data analysis. For instance, we can create heat maps and generate insight reports that do not contain any personal details.
We may disclose and share with our partners the information that has undergone statistical processing and no longer contains identifying content. This is done with the aim of understanding how users utilize our services or to enable the public to grasp the overall usage trend of our services.
(3) Disclosure
Generally speaking, we refrain from disclosing children's personal information to the outside world. However, we may disclose children's personal information for the following reasons:
(1) To comply with applicable laws and regulations.
(2) To adhere to the provisions of court judgments, rulings, or other legal procedures.
(3) To meet the requirements of relevant government agencies or other legally authorized organizations.
(4) When we have valid reasons to believe that compliance with laws and regulations is necessary.
(5) For reasonable and necessary purposes related to the implementation of relevant service agreements or this statement, safeguarding the public interest, and protecting the personal and property safety or other legitimate rights and interests of our customers, ourselves, our affiliates, other users, or our employees.
4.Storage of Children's Personal Information
5.We will implement technical measures like encryption to store children's personal information, thereby guaranteeing its security. The storage duration of children's personal information will not exceed what is necessary for fulfilling the purposes for which it was collected and utilized. To gain a more in-depth understanding of how we store and safeguard children's personal information, please refer to our Privacy Policy.
6.In the event that our products or services cease to operate or when the storage period of your and children's personal information comes to an end, we will delete or anonymize your and children's personal information within a reasonable timeframe.
7.Management of Children's Personal Information
During the period when child users are using this product or service, with the aim of making it more convenient for you and children to access, correct, and delete relevant personal information, we have incorporated corresponding operation settings in the product design. Additionally, you can also offer feedback and seek consultation regarding relevant information through the contact information we have provided. Once we have verified your feedback, we will get in touch with you promptly. Please be aware that during the verification process, we may require you to supply personal information such as the child's account number, date of birth, and contact information. This is so that we can continue to address your requirements after successfully completing the identity verification and query verification.
1.Accessing Children's Personal Information
You, as the guardian, along with the children under your guardianship, have the ability to view the personal information that has been provided or generated by the child users during their utilization of our products or services. This encompasses, but is not limited to, details such as usernames, passwords, avatars, and nicknames.
2.Correcting Children's Personal Information
Should you or the child under your guardianship notice that there is an error in the personal information regarding the child that we have collected, used, and processed, you can get in touch with us to have it rectified. Once we have successfully completed the identity verification and the relevant verification procedures, we will promptly take the necessary steps to correct the issue.
3.Deleting Children's Personal Information
You and the children under your guardianship may request us to delete the children's personal information that we have collected, used, and processed under the following circumstances. Upon completing the identity verification and the verification of the specific situation, we will take timely action to remove the relevant data.
(1) If we have collected, stored, used, transferred, or disclosed children's personal information in contravention of the provisions of laws, administrative regulations, or the agreement between the two parties.
(2) If we have collected, stored, used, transferred, or disclosed children's personal information beyond the scope of the intended purpose or the necessary period.
(3) If you withdraw your consent.
(4) If you or the child under your guardianship terminates the use of the products or services through cancellation or other means.
However, it should be noted that if you and the child under your guardianship request the deletion of the personal information of a specific child, the child user may then be unable to continue using our products and services or certain specific business functions within them.
If you become aware that your child's personal information has been collected without your prior consent, please contact us immediately and we will endeavor to delete the relevant data as soon as possible.
4.When Can Children Manage Their Own Accounts?
When a child under guardianship reaches the age of 14, they acquire the right to manage their own account. If a child user opts to manage their own product account, you will no longer have access to or be able to control their account. When the child under guardianship attains the right to manage the account of this product independently, we will notify both you and the child under your guardianship.
5.Application of This Statement
(1)This statement is applicable only to our products or services that are specifically designed for children under the age of 14, products or services with functional sections specifically tailored for children under the age of 14, or products or services that require the user to enter their date of birth, age information, and other details that can identify the user's age. Please understand that in the event that there is anything not covered by this statement, the Privacy Policy shall be referred to for application.
(2)In the context of the application of this statement, if there is any inconsistency between this statement and the provisions of the Privacy Policy, this statement shall take precedence.