Children's
Personal Information Protection Policy
Release date of this edition: 2/4/2022
Effective date: 2/4/2022
Xi’an OusiQi
software co.,Ltd
(hereinafter referred to as "the Company" or "We/Us") is
well aware of the importance of protecting children's personal information
security. On the basis of “The Personal
Privacy Protection Policy”, we hope that we can clarify the corresponding
information processing rules that we adopt and other related matters when we
collect and use children's personal information through “The Children's Personal Information Protection Policy”
(hereinafter referred to as "this Policy"). As the guardian of a
child user (hereinafter referred to as "you" or
"guardian"), please carefully read and understand this Policy before
you or the child in your custody use our Phone System and services, and then
start using or allow the child in your custody to use our Phone System and
services after you confirm your full understanding of and consent to all the
terms and conditions. We will take corresponding measures to protect the
personal information of child in your custody according to this Policy.
Special instructions of guardian:
In order to protect the legitimate rights and
interests of the child in your custody, please carefully read and choose
whether to agree to this Policy. Please confirm that you are the legal guardian
of child user, otherwise you have no right to agree to this Policy. We hope
that you will work with us to protect the personal information of child user,
educate and guide child user to enhance his/her awareness and ability of
personal information protection, ensure that the child in your custody will use
our Phone System and services and submit his/her personal information to us
with your consent and guidance, and direct, remind and ask him/her not to
provide any personal information to any network Phone System and service
provider without your consent. If you don't agree to the content of this
Policy, please ask your child to stop using our Phone System and services
immediately.
Special instructions for children:
This Policy specifically refers to minors
under the age of fourteen. If you are a child user, please ensure that you read
this Policy in the company of your guardian. The guardian should guide the
child user to use our Phone System and services upon full understanding of and
consent to all the contents of this Policy.
This Policy will help you understand the
following contents:
I.
How do we
collect and use the personal information of children users
II.
How do we store
the personal information of children users
III.
How do we share,
transfer and publicly disclose the personal information of children users
IV. How do we protect the personal information of children users
V.
How to manage
the personal information of children users
VI. Scope of application of privacy policy
VII. Change and revision of privacy policy
VIII. How to contact us
I.
How
do we collect and use children's personal information
(1) We will strictly fulfill our obligations and
responsibilities to protect children's personal information according to laws
and regulations, follow the principles of just
necessity, informed consent, clear purpose, security and legal utilization, and
collect the personal information of children users after we obtain the consent
of guardians in view of their choice of Phone System or services. If you
actively report or provide the personal information of the child in your
custody when using our Phone System and services, it means that you have permitted
us to collect and use your child's personal information according to this
Policy. In addition, you don't have to provide us with the personal information
of child user. But in some cases, if you choose not to provide it, we will not
be able to actively identify child user and provide him/her with corresponding
services, nor can we respond or solve the problems encountered by child user.
(2) When you or the child in your custody uses
our Phone System and services, we will collect and use the personal information
of you or the child in your custody. Please refer to the Chapter "How do
we collect and use your personal information" of the Personal Privacy
Protection Policy for details about the specific content, purpose, processing
mode and consequences if you refuse to provide the corresponding information.
In addition, we or a
third party may automatically collect personal information about you or the
child in your custody through SDK and other similar technologies. For details,
please refer to the chapter on third-party SDK in the Personal Privacy
Protection Policy.
Please note that in
most cases, we can't identify and judge whether the collected and processed
personal information is the personal information of child based on the
information other than the personal identity information of children that you
provide. We will collect and process the personal information of users
according to the Personal Privacy Policy.
(3) Exception of authorization and consent
According to laws and
regulations, the authorization and consent of the child’s guardian is not
required for collecting the information of child user under the following
circumstances:
1. It is related to our performance of
obligations stipulated by laws and regulations;
2. It is related to national security, national
defense security, public safety, public health and major public interests;
3.
It is related to criminal investigation,
prosecution, trial and judgment enforcement;
4.
It is difficult to obtain the consent of
the guardian or the child himself/herself for the sake of safeguarding the
child's life, property and other major legitimate rights and interests;
5.
The information we collect is disclosed
to the public by the child or his/her guardian;
6.
The personal information is collected
from legally disclosed information, such as legal news reports, government
information disclosure and other channels;
7.
It is necessary to sign and perform
relevant agreements or other written documents with you or the child in your
custody;
8.
It is necessary for us to maintain the
safe and stable operation of our Phone System and services, for example we
detect and remove the faults of our Phone System and services;
9.
When it is necessary for academic
research institutions to make statistics or academic research based on public
interests and disclose the results of academic research or description, the
personal information contained in the results is de-identified;
10.
It is necessary for legal news
reporting;
11. Other circumstances stipulated by laws and
regulations.
II.
How
do we store the personal information of children users
The personal information of children users that is
collected and generated within the People's Republic of China will be stored in
the People's Republic of China. And we will strictly conform to the laws and
regulations of the state, and store the sensitive personal information safely
according to the relevant encryption approach.
We only store your
personal information during the period required for the purpose of this Policy
and within the time limit required by laws and regulations.
Please be aware that the personal information protection
measures we adopt for children users are only applicable to our Phone System.
Once children users view other resources through third-party software or browsers,
we are not able and obligated to protect any personal information submitted by
children users through websites or software beyond our Phone System.
If we terminate the service or operation, we will stop
collecting children's personal information in time, notify their guardians in
advance according to laws and regulations, and delete or anonymize the
children's personal information after the service or operation is terminated,
unless otherwise required by laws, regulations or regulatory authorities.
III.
How
do we share, transfer and publicly disclose the personal information of
children users
(1) Sharing
We will not share
with third parties the personal information of children users. Only with the
prior consent of the guardian can we share the personal information of the
child user with a third party, and require the receiver to store and use the
personal information of the child user as required by the laws and regulations
of the state. For details, please refer to "How do we share, transfer and
publicly disclose your personal information" in the Personal Privacy
Protection Policy, except for the following circumstances:
1.
We will not share the personal
information of child user with other parties without explicit consent of child
user and his/her guardian;
2.
We may share the personal information of
child user according to laws and regulations, as required for litigation
dispute resolution, or required by administrative and judicial authorities
according to law;
3.
To the extent permitted by laws and
regulations, it is necessary to share the personal information of child user in
order to protect us, our affiliates or partners, you and the child in your
custody or other users or safeguard the public interest, property or safety
from any harm;
4. When our affiliates provide you or the child
in your custody or us with services, we may share with our affiliates the
personal information of you or the child in your custody. However, we only
share necessary personal information, and our affiliates are bound by this Privacy
Policy. If any of our affiliates wants to change the purpose of personal
information processing, it will request for the consent of you and the child in
your custody again.
5.
Unless explicitly authorized and agreed
by you and the child in your custody, we will not share the personal
information of you and the child in your custody with third-party advertisers,
application developers, open platforms or other partners. We may provide these
partners with summarized information, anonymized information or other
information that will not disclose your personal identify. For example, we may
tell application developers how many users have installed their developed
applications;
6.
For the purpose stated in this Privacy
Policy only, we may share personal information with our vendors, service
providers, consultants or agents to provide better customer service and user
experience. These vendors, service providers, consultants and agents may
provide us with technical infrastructure services, analyze the usage of our
services, weigh up the effectiveness of advertisements and services, provide
customer service and payment services, conduct academic research and
investigation, or provide legal, financial and technical advisory services;
7.
For the companies, organizations and
individuals with whom we share personal information, we will enter into rigid
data protection agreements with them, requiring them to treat personal
information in accordance with our instructions, this Privacy Policy and any
other relevant confidentiality and security measures;
8.
The guardian should know and understand
that children may deliver texts, photos and other information to specific or
unspecified persons by sending messages, etc when
they use our Phone System and services. Such messages may contain personal
information of children users. We suggest that guardians should guide their
children users to pay attention to the Notes when they use our Phone System or
services, including but not limited to not uploading personal information such
as real personal portrait photos. If the personal information of children users
is known to anyone else because they actively post and share their personal
information, we will not bear any legal responsibility for that.. Meanwhile, we also suggest that you carefully provide
children's personal information when using our Phone System or services.
(2) Transfer
We will not transfer
the personal information of children users to any other company, organization
or individual, except for the following circumstances:
If the personal
information is required to be transferred for related transactions, we will
request new companies, organizations and individuals in possession of personal
information about you and the child in your custody to continue to be bound by
this Policy, otherwise we will ask the companies, organizations and individuals
to request for your authorization again.
As defined by
transfer of personal information only with explicit consent of you and the
child in your custody, we will not transfer the personal information of child
user we have obtained to any other party without the explicit consent of the
guardian and the child user.
(3) Disclosure
We will only publicly
disclose the personal information of children users under the following
circumstances:
1.
We have obtained the explicit consent of
you and the child in your custody.
2.
We may publicly disclose personal
information as required by laws, legal proceedings, lawsuits or government
authorities.
3.
Other circumstances stipulated by laws
and regulations.
IV.
How
do we protect the personal information of children users
We will take all
reasonable measures to protect the personal information of children that we
obtain in accordance with laws and regulations, and designate staff in charge
of data security to protect the personal information of children users.
In order to prevent
the personal information of children users from being illegally accessed,
copied, modified, transmitted, lost, destroyed, processed or used accidentally
without authorization, we adopt security measures in line with industry
standards to protect the personal information provided by children users. The
personal information of children under the age of 14 is personal sensitive
information. The personal information of children under the age of 14 will be
processed according to the relevant laws and regulations on personal sensitive
information as well as national standards and requirements.
(1) We will encrypt, transmit and store
identifiable personal identity information to ensure the confidentiality of
data. For the International Mobile Equipment Identity (IMEI) of the user's
mobile phone device identifier, we will anonymize and encrypt it with MD5
algorithm on the user's device, and only collect and upload the anonymized and
encrypted identifiers.
(2) If our application adopts WebView
technology, we will check the URL of all file protocols used in WebView and restrict access to sensitive data of this
Application and SD Card data, to avoid any private files and sensitive
information of our Phone System from malicious theft without special
permission, which may give rise to the leakage of the personal information of
child user.
(3) We deploy an access control mechanism on the
server, adopt the principle of minimum sufficient authorization for staff who may have access to the personal information of children
users, and regularly check the list of visitors and access records.
(4) Our server systems that store users' personal
information are all security-hardened operating systems. We will audit and monitor
the server operation. If we find the server operating system with security
problems announced, we will upgrade the server security as soon as possible to
ensure the security of all our server systems and applications.
(5) We give regular training of laws and
regulations on personal information protection for staff members to strengthen
their awareness of protecting users' personal privacy.
(6) If our physical, technical or management
protection measures are unfortunately damaged, we will start the emergency plan
immediately to prevent the escalation of security incident, report it to the
competent government authority as required by laws and regulations, and
forthwith inform you and the child in your custody of the basic information,
potential influence, measures already taken or measures to be taken, etc. of
the security incident by reasonable and effective means such as push and
announcement.
(7) We have set up a rigid data use and access
system, and adopted reliable data access control and multi-identity authentication
technology to protect children's personal information and avoid illegal use of
children's data.
(8) For details, please refer to the Chapter
"How do we protect your personal information" in “The Personal Privacy Protection Policy” to learn more about how
and what measures we have taken to protect children's personal information.
V.
How
to manage the personal information of children users
(1) In order to enable you or the child in your
custody to access and manage the personal information of child user more conveniently
during the use of our Phone System and services, you and the child in your
custody should follow the Chapter "Your right to manage personal
information" in the Personal Privacy Protection Policy.
(2) Under the following circumstances, you or the
child in your custody can contact us through the contact information specified
in “The Personal Privacy Protection
Policy” and request to delete the corresponding children's personal
information:
1.
We collect, store, use and provide
children's personal information in violation of laws, administrative
regulations or the agreement between both parties;
2.
The children's personal information that
we collect, store, use or disclose beyond the scope of purpose or the necessary
time limit;
3.
You withdraw your consent;
4.
You or the child in your custody
terminates the use of our Phone System or services by means of cancellation,
etc.
VI.
Scope
of application of privacy policy
(1) This Policy is not applicable to the
third-party Phone System and services contained in our Phone System. When
children users use third-party Phone System or accept services provided by
third party, the personal information of children users may be obtained by
third party. Therefore, we hereby remind guardians and children users to read
the privacy protection policies of third parties.
(2) This Policy is not applicable to the
collection of data from external websites after children users click the link.
VII.
Change
and revision of privacy policy
Our privacy policy
may change. Without the explicit consent of guardians and children users, we
will not restrict children users from normally exercising their rights
specified in this Privacy Policy.
In the event of
significant change in this Privacy Policy, we will also issue significant
notice (for example, when software is revised or upgraded, we will notify in
time by pop-up window).
The significant
change referred to in this Policy include but are not limited to:
1. Our service mode is significantly changed.
For instance, the purpose of personal information processing, the type of
personal information processing, the usage of personal information, etc.
2. Our control is significantly changed. For
instance, the change of owners because of merger and acquisition;
3. The main objects of personal information
sharing, transfer or public disclosure are changed;
4. The right of children users to participate in
personal information processing and how to exercise the right is significantly
changed;
5. The responsible department, contact
information and complaint channel for personal information security are
changed;
6. The personal information security impact
assessment report indicates that there is high risk.
VIII. How
to contact us
Should guardians and
children users have any question, opinion, suggestion or complaint about our
privacy policy and how we process the personal information of children users,
please send an email to [supportab@126.com] to contact us.
Under normal
circumstances, we will respond to guardians and children users within 15
working days.
Our registered
address is: Room 713, 7th Floor, Building B,
Life One Center, No. 51 Tangyan Road, High-tech Zone,
Xi'an City, Shaanxi Province.