Last updated: January 29, 2023
Effective date: February 28, 2023
Shenzhen Heiman Technology Co., Ltd. and its affiliates (collectively referred to as "we" or "Heiman") are committed to protecting the personal privacy of children (i.e., minors under the age of fourteen) who use our products and services. This "Children's Privacy Protection Statement" (including subsequent updated versions, hereinafter referred to as "this Statement") and the "Heiman Privacy Policy" are intended to explain to parents and other guardians (hereinafter referred to as "guardians" or "you") how we collect and use children's personal information related to our products and services, the rules for our processing of this personal information, and the ways in which guardians can access, correct, delete, and protect this information.
We will protect children's personal information and privacy security in accordance with this Statement. We also ask for your help in protecting your child's personal information and privacy security by requiring them to read and accept this Statement together under your supervision, and to use our products and services with your consent and guidance. Please note that your choice to agree to this Statement, or your child's commencement or continued use of our products or services, or submission of their personal information, indicates your consent to our collection, use, storage, sharing, transfer, and disclosure of your child's personal information in accordance with this Statement.
We recommend that any child should obtain the prior consent of a guardian before using our products or services. If you are a child, you need to carefully read this Statement with your guardian and, after obtaining your guardian's consent, use our products, services, or provide us with information.
We hereby remind you to carefully read and fully understand this Statement and the "Heiman Privacy Policy" (especially the terms marked in bold) before choosing whether to agree to all the terms and whether to allow the child under your guardianship to use our products or services. If you do not agree with the relevant terms of the "Heiman Privacy Policy" and/or the content of this Statement, or if you do not agree to provide the necessary information for specific functions or scenarios of some of our products and services, please understand that you and the child under your guardianship may not be able to use our products, services, or related specific functions or scenarios normally. In terms of children's privacy protection, if there is any inconsistency between this Statement and the "Heiman Privacy Policy", this Statement shall prevail. For matters not mentioned in this Statement, the "Heiman Privacy Policy" shall apply.
This Statement applies to products or services that require users to enter their date of birth, age, or other information that can identify the user's age, or to specific devices, functions, and scenarios designed and developed for children that are intelligently controlled through our software (including mobile applications, mini-programs, etc.). The products and services we provide may include products or services provided by third parties, and you may also log in and use third-party products and services through our software or products (such as Heiman); this third party may collect, use, or process children's relevant information. We recommend that you ask your child to seek your consent before authorizing a third party to collect and process any of their personal information.
If you have any questions about the content of the terms during the process of reading this Statement, or if you have any requests regarding personal information rights during the process of you and the child under your guardianship using our products and services, please contact us through the dedicated channels we have opened for you. For details, please refer to the "Contact Us" section of this Statement. We will process and respond to your questions or requests as soon as possible after receiving your message.
We will strictly collect and use children's personal information in accordance with the obligations and responsibilities for the protection of children's personal information stipulated by laws and regulations, as well as the agreements in relevant privacy policies and this Statement, after obtaining the consent of the guardian, and according to the specific needs of the relevant products and services.
In the process of providing you and the child under your guardianship with certain products or services specifically for children, for the purpose of providing these products and services, we may require users to fill in their personal date of birth to identify whether the user is a child under the age of 14, and in accordance with the provisions of laws and regulations, allow the child to continue to use the relevant products or services only after obtaining the guardian's consent.
When you and the child under your guardianship use specific devices intelligently controlled by our software, we may collect and use necessary children's personal information in certain functions or scenarios, including age/month-age information, exercise information, and geographic location information. The specific types and scope of information involved will be determined by the functions of the product used and the intelligent scenarios.
During the process of children using the products or services, we may collect other relevant information. For details, please refer to the "What Personal Information We Collect" section of the "Heiman Privacy Policy" to learn more about the other children's personal information we collect.
If we need to collect your or the child under your guardianship's personal information beyond the above scope, we will inform you again and obtain your consent.
Please understand that you can choose whether to fill in or provide us with specific information, but if you do not fill in or provide certain specific information, it may cause our products or services to fail to operate normally, or fail to achieve the service effect we intend to achieve, and you and the child under your guardianship may not be able to use our products, services, or related specific business functions normally.
We strictly abide by the provisions of laws and regulations and the agreement with users, and use the information collected from you and the child under your guardianship for the following purposes:
If we need to use your or the child under your guardianship's personal information for purposes other than those described above, we will inform you again and obtain your consent.
We comply with the provisions of laws and regulations and strictly restrict the sharing, transfer, and disclosure of children's personal information. In general, we will not share children's personal information with third parties. We may only share children's personal information with third parties with the prior consent of the guardian.
We will share some of the child's personal information (such as the child's username, account, password, and the content of transactions made by the child user in some of our products and services) with the guardian, who can access and manage the relevant personal information.
For external processing purposes only, we may share children's personal information with third-party partners (third-party service providers, contractors, agents, application developers, etc., for example, communication service providers who send emails or push notifications on our behalf, map service providers who provide us with location services) (they may not be located in your jurisdiction), so that they can 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 security assessment of the entrusted party and the entrusted behavior, sign an entrustment agreement, and require that the processing behavior of the entrusted party does not exceed our authorized scope. We entrust third parties to process children's personal information mainly for the following purposes:
If we share your and your child's information with the above-mentioned third parties, we will conduct a security assessment and use encryption, anonymization, de-identification, and other means to protect the security of your and your child's information.
As our business continues to develop, when transactions such as mergers, acquisitions, and asset transfers lead to the sharing of your and your child's personal information with third parties, we will inform you of the relevant situation through push notifications, announcements, etc., and continue to protect or require the new manager to continue to protect your and your child's personal information in accordance with laws and regulations and standards no less than those required by this Statement.
We may use the collected children's information for big data analysis after anonymization, such as forming a usage report for your service.
In general, we prohibit the external disclosure of children's personal information, but we may disclose children's personal information for the following purposes:
We will take 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 is necessary to achieve the purpose for which it was collected and used. Please refer to the "Location and Duration of Information Storage" and "Information Security" sections of the Heiman Privacy Policy for details on how we store and protect children's personal information.
If our products or services cease to operate, or if the storage period for your and your child's personal information expires as required by this Statement or the Heiman Privacy Policy, we will notify you and your child by means such as push notifications, announcements, or emails, and delete or anonymize your and your child's personal information within a reasonable period.
During the period when child users use our products or services, in order for you and your child to access, correct, and delete relevant personal information more conveniently, we have provided corresponding operation settings in the product design. You can also provide feedback and consult relevant information through the contact methods we provide. We will contact you in a timely manner after verifying your feedback. Please understand that during the verification process, we may need you to provide the child's account, date of birth, contact information, and other personal information in order to respond to your needs after completing identity verification and problem verification.
You and the child under your guardianship can view the personal information provided or generated by the child user when using our products or services, including but not limited to username, nickname, gender (if any), and actively published content.
When you and the child under your guardianship find that there are errors in the children's personal information we have collected, used, and processed, you can correct the information by clicking "Me" - "Personal Information" - "Nickname"/"Time Zone", or you can contact us for correction. We will take timely measures to correct it after completing identity verification and problem verification.
You and the child under your guardianship can request us to delete the children's personal information we have collected, used, and processed in the following situations. We will take timely measures to delete it after completing identity verification and problem verification.
For your request, we will first conduct identity verification and verification, and take relevant deletion measures in a timely manner after the verification is completed. However, please note that if you and the supervised child request us to delete specific children's personal information, it may result in the child user being unable to continue to use our products and services or certain specific business functions of the products and services. If you find that your child's personal information has been collected without your prior consent, please contact us in a timely manner, and we will try to delete the relevant information as soon as possible.
If you have any questions about our practices or this Statement, please contact us through the following methods:
Company Name: Shenzhen Heiman Technology Co., Ltd.
Registered Address: Room 101, Building 4, Dafu Industrial Zone, Kukeng Community, Guanlan Street, Longhua District, Shenzhen
Contact: heimanapp1@heiman.com