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.