Privacy Policy
Updated: 2024-11-01
Effective Date: 2024-11-01
You are welcome to use the "CarCar" software and related services!
Shenzhen Blue Whale Unlimited Network Technology Co., Ltd. (hereinafter referred to as "we", "us" or "the Company") is well aware of the importance of personal information to you, and will collect, use and protect your personal information in accordance with the requirements of laws and regulations. Through this Privacy Policy, we want to provide you with a clear introduction to how we process your personal information when you use our products/services, and how we provide you with access, correction, deletion and protection of that 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 will help you understand the following:
(1) We will collect and use your information in accordance with the Privacy Policy, but we will not collect personal information in a package just because you agree to this Privacy Policy.
(2) When you use or enable relevant functions or services, we will collect and use relevant information that is necessary for the realization of functions and services. Unless it is necessary information for the realization of basic business functions or as required by laws and regulations, you can refuse to provide other functions or services without affecting it. We will explain what information is required in each of our privacy policies.
(3) If you are not logged in to your account, we will use the identifier information corresponding to the device to ensure the basic functions. If you are logged in to your account, we will push information based on your account information.
(4) Geolocation, camera, photo album (storage), and phone permissions will not be turned on by default, and will only be used to achieve specific functions or services with your express authorization, and you can also withdraw 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 about how to apply for permissions and how to use them, see Appendix: Permission List
(5) This Privacy Policy applies to your access to and use of our products and services through the Product Application, the Product Development Kit (SDK) and Application Programming Interface (API) for use by third-party websites and applications.
2.Special Tips
(1) Before using this product and/or related services, please carefully read and choose to accept or not accept this Privacy Policy, we strive to express it in easy-to-understand, concise and concise words, in which important content such as the terms and interests of your personal information have been reminded in bold or underlined, please pay special attention. By using or continuing to use our products/services, you consent to the processing of your information in accordance with this Privacy Policy.
(2) If you do not agree to this Privacy Policy, we cannot provide you with complete products and services, and you can also choose to stop using them. When you choose to continue or use it 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 accompanied by your guardian, and use our services or provide information to us with the consent of your guardian.
(4) If you have any questions about this Privacy Policy, you can contact 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 collect the information you voluntarily provide when you use the services and collect the information generated during your use of the functions or services through automated means in the following ways:
1.Basic necessary functions
(1)Register, log in
When you register and log in to the Product and/or related services, you can log in and use it with a third-party account, and you will authorize us to obtain the public information (avatar, nickname and other information authorized by you) registered on the third-party platform for binding with the product account, so that you can directly log in and use the product and related services.
(2) Certification
When you use the identity authentication function or service, you may need to provide your real identity information (real name, ID number, phone number, etc.) to complete real-name verification in accordance with relevant laws and regulations. In order to achieve the purpose of identity authentication, you agree and authorize us to provide, inquire and verify your aforesaid identity information to the relevant identity authentication authorities by ourselves or by entrusting a third party. This information is sensitive personal information, and you may refuse to provide it, but you may not be able to obtain relevant services, but it will not affect the normal use of other functions and services.
(3) Operation and safety assurance
i. We are committed to providing you with safe and reliable products and use environment, and providing high-quality and reliable services is our core goal. The information collected for the purpose of the security function is necessary information. We may use or integrate your account information, transaction information, device information, service log information, and information shared by our affiliates and partners with your authorization or in accordance with the law to comprehensively judge the transaction risks of 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. In order to ensure the safe operation of the software and services, we will collect your WLAN access point, base station, network access mode, type, status, network quality data, operation logs, and device attribute information [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]. In order to ensure the quality and efficiency of the operation, we will collect the MAC address information of the device during the background operation of the software to determine the risk of your account.
b. In order to prevent malicious programs and necessary for security operations, we may collect information about 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 use 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 are used to judge account security, conduct identity verification, and detect and prevent security incidents.
iii. Please note that device information and log information alone cannot be used to identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be regarded as personal information during the combination period, and we will anonymize and de-identify such personal information unless we have obtained your authorization or are otherwise provided by laws and regulations. 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 use the additional business functions of this product, in order to meet the purpose of providing you with the products and services, in addition to the registration information, you need to further provide us with your personal identification information, location information and other information necessary to provide you with services, and if you do not use specific products and services, you do not need to provide relevant information (which will be explained in detail below).
1. Online events
In the process of using this product and service, we may involve online activities of the product for marketing and promotion, and such functions may be adjusted due to product version upgrades or activity periods. If it is involved: When participating in online activities, you are required to provide contact information (including name, mobile phone number, contact address, ID number, email address, etc., subject to the rules of the event).
2. Customer Service
a. When you contact our customer service or use other user response functions (such as making service inquiries, personal information protection complaints or suggestions, and other customer complaints and needs), we may need you to provide necessary personal information (name, user ID, mobile phone number, email address, audio recording, pictures, videos) to match and verify your user identity in order to protect the security of your account and system.
b. We may also save your contact information (other contact information you use when contacting us or you voluntarily provide to us, such as telephone number, email), your correspondence/call records and content (personal sensitive information) with us, and other necessary information related to your needs, so as to contact you or help you solve problems, or record the handling plans and results of related problems. This information is sensitive personal information, and you may refuse to provide it, but you may not be able to obtain relevant services, but it will not affect the normal use of other functions and services.
3. Session and Available Data
"Session and Available Data" is information you provide to us about your use of the Application and Services, including, but not limited to, data related to your connection to the Application and Services resulting from your use of the Application and Services. Session and available data includes information related to connection requests, server communications, and data sharing, including network testing, quality of service, date, time, and location. We can also centralize sessions and available data. Please note that Session and Available Data does not include any personal information or content that you may send or share through your use of the App (such as photos, contacts, schedules, etc.) or the Services.
4. Device permission call
a. In order to ensure the normal realization of relevant business functions, we need to call the corresponding necessary permissions according to the specific usage scenarios, and ask you in a pop-up window before calling (see Appendix: Permission List for details).
b. If you need to turn off some of the above specific access rights functions (such as your location information), most mobile devices will support your request, please refer to or contact the service provider or manufacturer of your mobile device for specific methods. Please note that if you turn on any of these permissions, you authorize us to collect and use relevant information to provide you with corresponding services, and once you close any of these permissions, it means that you have cancelled your authorization, and we will no longer continue to collect and use relevant information based on the corresponding permissions, nor will we be able to provide you with the services corresponding to the permissions. However, your decision to turn off the permission will not affect the collection and use of information previously based on your authorization.
5. Advertising push function
a. Based on the information collected, we may work with third-party service providers to integrate third-party services (such as advertising, links or other forms of promotional content) into our products and/or services. We will not share your personal information (such as mobile phone number, nickname, profile picture, friend list) that you provide to us or that we collect from us 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. Third-party service providers may collect personal information necessary to provide services to you in accordance with their own privacy policies. We will use 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, but we cannot guarantee that they will take appropriate measures as requested by us.
b. If you use a mobile phone of Xiaomi, Meizu, Huawei and other brands, this product may directly or through a third party to access the Push SDK of the above-mentioned mobile phone manufacturer, and it is necessary to collect the unique identification information of the mobile phone (such as IMEI), and may collect parameters such as your mobile phone model, system type, system version, and device screen size to realize the push of product and activity information, please refer to the privacy policy or relevant statement of the SDK operator for details.
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 understand that with the development of our business, there may be adjustments and changes to the functions and services provided by this product. In principle, when a new function or service is related to the function or service we currently provide, the personal information collected and used will be directly or reasonably related to the original purpose of processing. In scenarios that are not directly or reasonably related to the original purpose of processing, we will notify you again when we collect and use your personal information and obtain your consent.
3. Information from Third Parties
1. You can also use a third-party account (such as WeChat) to log in to our platform. In this case, you can choose to authorize us to read the public information (username, nickname, profile picture) that you have registered, published and recorded on the third-party platform under the premise of complying with relevant laws and regulations. We may still ask you to provide additional personal information that we request but the third party cannot provide. The purpose of obtaining the above information from third parties is to remember your login identity as our user, so that we can provide you with better products and services. You can choose the scope of personal information that you authorize us to obtain when you log in to our platform with a third-party account. However, please note that if you discontinue certain permissions, you may not be able to enjoy the best service experience, and some services may not work properly. Please read the user agreement or privacy policy of the third-party partner service carefully.
2. Your information is included in the information shared by other users.
4. Sensitive Information
Before providing us with any personal information that is sensitive information, please carefully consider that such provision is appropriate and agree that your personal sensitive information may be processed for the purposes and in the manner described in this Policy. The definition of sensitive information is provided in Appendix: Explanation of Terms.
We will collect and use your sensitive information with your consent to achieve functions related to our business, and allow you to make choices not to agree to the collection and use of these sensitive information, but refusing to use this information will affect your use of relevant functions
5. Exceptions to Obtaining Authorization and Consent
Please understand that in the following circumstances, in accordance with laws and regulations and relevant national standards, we do not need to obtain your authorization and consent to collect and use your personal information:
1. Fulfillment of obligations under laws and regulations;
2. Directly related to national security or national defense security;
3. Directly related to public safety, public health, or major public interests;
4. Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
5. Where it is for the purpose of protecting the life, property, or other major lawful rights and interests of the Personal Data Subject or other individuals, but it is difficult to obtain the consent of the individual;
6. The personal information collected is disclosed to the public by yourself;
7. Your personal information collected from legally and publicly disclosed information, such as lawful news reports, government information disclosure, and other channels;
8. Necessary for the conclusion or performance of a contract at your request;
9. Necessary to maintain the safe and stable operation of software and related services, such as discovering and disposing of faults in software and related services;
10. Where it is necessary for legitimate news reporting;
When it is necessary for academic research institutions to carry out statistical or academic research based on the public interest, and the results of academic research or descriptions are provided externally, 11. The personal information contained in the results is de-identified;
12. Other circumstances provided for by laws and regulations.
In particular, you are reminded that if the information cannot be used alone or in combination with other information to identify you, it is not your personal information in the legal sense; When your information can be used to identify you as an individual 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, such as cookies and device identifiers, are commonly used on the Internet. When you use the Product and/or related services, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device to collect and identify information when you access and use the Product. We promise not to use cookies for any purpose other than those described in this Privacy Policy. We use cookies and similar technologies primarily to enable the following functions or services:
(1) Ensure the safe and efficient operation of products and services
We may set authenticated and secure cookies or anonymous identifiers that allow us to confirm whether you are logging in to the Services securely or if you have experienced theft, fraud, or other illegal activity. These technologies will also help us improve service efficiency, login and response times.
(2) To help you get an easier access experience
Using this type of technology can help you avoid having to repeat the steps and processes of filling out your personal information and entering your searches.
3. How We Share, Transfer, and Publicly Disclose Personal Information
1.Sharing
(1) The principle of sharing
a. Principle of authorization and consent: The sharing of your personal information with our affiliates and third parties is subject to your authorization and consent, unless the shared personal information is de-identified information, and the sharing third party cannot re-identify the natural person subject of such information. If the purpose of the related party or third party to use the information exceeds the scope of the original authorization and consent, they need to obtain your consent again.
b. The principle of legality, legitimacy and minimum necessity: The data shared with related parties and third parties must have a legitimate and legitimate purpose, and the shared data must be necessary to achieve the purpose.
c. Principle of security prudence: We will carefully assess 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 to obtain information to protect data security.
(2) We are obligated to keep your information confidential and will not sell or sell 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, litigation and dispute resolution, or the requirements of 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.
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: In order to facilitate us to provide you with products or services based on the platform account and 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, and if 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 provide you with better and high-quality products and services, we may entrust authorized partners or use 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, legitimate, necessary, specific and explicit purposes stated in this Privacy Policy, and our partners will only have access to the information necessary for them to perform their duties, and shall not use this information for any other purpose.
(3) At present, our authorization information includes the following:
i. Shared information to enable a feature or service
a. When you use the functions provided by our affiliates and third parties in our products or services, or when software service providers, smart device providers, and system service providers jointly provide services to you with us, we will share the information necessary for the realization of business with these affiliates and third parties for the realization of the required service capabilities of the products.
b. Geolocation services: When you use geolocation-related services, we will share the device location information with the location service provider through SDK or related technologies so that we can reflect the location results to you, including: IP information, GPS information, WLAN access point and base station sensor information. GPS information is sensitive personal information, and refusal to provide it will only affect the function of the geolocation service, but will not affect the normal use of other functions.
c. In order to adapt the message push function with the terminal model you use, we may share the model, version and related device information with the terminal device manufacturer (Meizu, Huawei, OPPO, VIVO, Xiaomi, Samsung, etc.) through SDK and other technologies, please refer to the privacy policy or relevant statement of the SDK operator for details.
ii. Enabling the sharing of information related to advertising
We may work with third-party advertising partners to serve you ads. 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 may uniquely identify your device. The collection and processing of information by the aforementioned partners shall comply with their own privacy policies and shall not apply to this Policy. To protect your legitimate rights and interests, if you find that there is a risk, it is recommended that you immediately terminate the relevant operation and contact us in time.
a. Advertising push: We may share information with partners who entrust us to carry out promotion and advertising, and we will not share information (name, ID number) used to identify you personally, but will only provide these partners with indirect portrait tags that cannot identify you personally and de-identified or anonymized information, so as to help them improve 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, which 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 attach great importance to the security of accounts and services, and in order to protect the security of your and other users' accounts and property, and to protect the legitimate and 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: In order to analyze the use of our services and improve the user experience, we will share statistical data on product usage (crashes, flashbacks) with affiliates or third parties, which 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. Include:
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 IN ORDER TO FUNCTION THE ABOVE FUNCTIONS PROPERLY;
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, in order 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 in order 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, and 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 unless we have your explicit consent.
(2) With the continuous development of our business, we may carry out mergers, acquisitions, and asset transfers, and your personal information may be transferred as a result. In the event of the aforesaid changes, we will require the successor to protect your personal information in accordance with laws and regulations and security standards not lower than those set forth in this Privacy Policy, otherwise we will require the successor to obtain your authorization and consent again.
3. Disclosure
(1) We will not publicly disclose your information unless we comply with national laws and regulations or obtain your consent. When we publicly disclose your personal information, we will adopt security protection measures that comply with industry standards.
(2) When announcing penalties for illegal accounts and fraudulent acts, we will disclose the information of the relevant accounts.
(3) For public welfare projects such as "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. When the incident is over, we will delete the disclosed personal information in a timely manner.
4. Personal letters that are exempt from obtaining consent to share, transfer, or publicly disclose in accordance with law
Please understand that in the following circumstances, in accordance with laws, regulations and national standards, we do not need to obtain your authorization and consent to share, transfer and publicly disclose your personal information:
(1) Related to national security and national defense security;
(2) Where it is related to public safety, public health, or major public interests;
(3) Where it is related to criminal investigation, prosecution, trial, or enforcement of judgments;
(4) For the purpose of protecting the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the consent of the individual;
(5) Other circumstances to safeguard the public interest, such as your credit evaluation information needs to be disclosed/shared;
(6) Personal information that you disclose to the public;
(7) Personal information is collected from legally and publicly disclosed information, such as lawful news reports, government information disclosure, and other channels. However, unless you expressly refuse or the processing of the information infringes on your major interests.
In accordance with 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 process such data without further notice to you and with your consent.
4. How we store and protect your personal information
1. Storage of Personal Information
(1) Storage period: We will only retain your personal information for the shortest period necessary for the purpose of providing this product and service, and after the necessary period, we will delete or anonymize your personal information, unless otherwise provided by laws and regulations.
(2) Storage area: In accordance with the provisions of laws and regulations, we will store your personal information collected and generated in the course of domestic operations within the territory of the People's Republic of China. At present, we do not transfer the above information overseas, and if we do transfer overseas, we will comply with relevant national regulations or obtain your consent.
2. Measures for the protection of personal information
(1) We attach great importance to the security of your personal information and will strive to take reasonable security measures (including technical and administrative aspects) to protect your personal information and prevent the personal information you provide from being accessed, publicly disclosed, used, modified, damaged, lost or leaked in an improper or unauthorized manner.
(2) We will use encryption technology, anonymization and related reasonable and feasible means no less than those of industry peers to protect your personal information, and use security protection mechanisms to prevent your personal information from being maliciously attacked.
(3) We will establish a special security department, security management system, and data security process to ensure the security of your personal information. We have strict data use and access policies in place to ensure that only authorized personnel have access to your personal information, and conduct security audits of data and technology in a timely manner.
(4) Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that due to technical limitations and various malicious means that may exist, it is impossible to ensure 100% security of information in the Internet industry, even if we do our best to strengthen security measures, and we will 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 have problems due to factors beyond our control. Therefore, we strongly recommend that you take active 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 immediately activate the emergency plan in the event of a user information security incident, and strive to prevent the impact and consequences of these security incidents from expanding. In the event of a user information security incident (leakage or loss), we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions you can independently prevent and reduce risks, and the remedial measures for you. We will promptly inform you of the relevant circumstances of the incident in the form of push notifications, emails, letters, text messages and related forms, and if it is difficult to inform you one by one, 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 leave this product and/or related services and browse or use other websites, services and content resources, we will not have the ability and 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 above-mentioned software or websites based on links or guides of this product.
5. How you manage your personal information
1. Accessing and Correcting Your Personal Information
Except as required by laws and regulations, you have the right to access and correct your personal information at any time. Please feel free to contact us if you need to access or correct other personal information generated during your use of our products and/or services. We will respond to your request in the manner and within the time frame set out in this Privacy Policy.
2. Change the scope of your authorization and consent or withdraw your authorization
(1) You can change the scope of your authorization for us to continue to collect personal information or withdraw your authorization by deleting information, turning off device functions, making privacy settings on our website or software, etc. You can also withdraw all authorization for us to continue to collect your personal information by canceling your account.
(2) How to change or revoke permission settings, you can turn off the permission function in the operating system of the device itself. You understand that after you do the above, we will not be able to continue to provide you with the services corresponding to the withdrawal of consent or authorization, but it will not affect the processing of personal information that has been carried out based on your authorization.
(3) You understand that each business function requires some basic personal information to be completed, and after you withdraw your consent or authorization, we will not be able to continue to provide you with the services corresponding to the withdrawal of consent or authorization, nor will we process your corresponding personal information. Your decision to withdraw your consent or authorization will not affect the processing of personal information previously carried out based on your authorization.
3. Cancel your account
You can apply for account cancellation directly in our products. You can access Settings - Cancel through the mobile app to complete the account cancellation; After you cancel your account, we will stop providing you with products and/or services, and according to your request, we will delete or anonymize your personal information, unless otherwise provided by laws and regulations.
4. Notify you of the cessation of operations
If we cease to operate, we will stop collecting your personal information in a timely manner, notify you of the cessation of operation in the form of a one-by-one delivery or announcement, and delete or anonymize your personal information in our possession.
5. Respond to your requests
If you are unable to access, correct or delete your personal information through the above methods, or you need to access, correct or delete other personal information generated by your use of our products and/or services, or if you believe that we have violated any laws and regulations or agreed with you regarding the collection or use of personal information, you can contact us through the contact information in this Privacy Policy. For security purposes, we may require you to provide a written request, or to provide proof of your identity, and we will respond to your request within 15 business days of receiving your feedback and verifying your identity. In principle, we do not charge a fee for your reasonable request, but we will charge a certain cost fee for repeated requests that exceed a reasonable limit. We may reject requests that are unreasonably repetitive, require excessive technical means (e.g., need to develop new systems or fundamentally change current practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).
6. Minors Clause
1. Guardian consent
(1) If you are a minor under the age of 18, you should read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before using this product and/or related services.
(2) We protect the personal information of minors in accordance with the provisions of relevant national laws and regulations, and will only collect, use, store, share, transfer or disclose the personal information of minors as permitted by law, with the explicit consent of parents or other guardians, or as necessary for the protection of minors; If we become aware that we have collected personal information from minors without prior verifiable parental consent, we will try to delete the relevant information as soon as possible.
(3) If you are the guardian of a minor, if you have any questions about the personal information of the minor under your guardianship, please contact us through the contact information published in this Privacy Policy.
2. Special protection for children
(1) We will further take the following measures to protect the personal information of children under the age of 14 that may be involved: For the personal information collected from children, in addition to complying with the provisions of this Privacy Policy on users' personal information, we will also adhere to the principles of legitimate necessity, informed consent, clear purpose, security and lawful use, and strictly follow 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. After expiration, we will delete or anonymize children's personal information. For more information on the special protection of children, please refer to the Appendix: Children's Data Protection Statement.
(2) If we find that we have collected the personal information of minors without the prior consent of a verifiable parent or legal guardian, we will try to delete the relevant data as soon as possible.
3. Anti-addiction
(1) We attach great importance to the protection of minors' personal information, and continue to explore updated ways to protect minors' personal information.
(2) We will actively protect the legitimate rights and interests of minors through the activation of 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 a minor, and then decide whether to include the account in the anti-addiction system. In addition, 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 try to contact their guardians for reminders, confirmation, and handling after suspected minors make purchases, so as to help minors surf 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.
7. Access, Revision, and Notification of Privacy Policy
1. Access to Privacy Policy
(1) You can view the full content of this Privacy Policy when you visit the App welcome page for the first time, and you can also view the full content of this Privacy Policy in Settings - Privacy Policy.
(2) Please understand that the products and/or related services described in this Privacy Policy may vary depending on the mobile phone model, system version, software application version, mobile client and other factors you are using. The final products and services are subject to the products and/or related services you use.
2. Revision and Notification of Privacy Policy
(1) In order to provide you with better services, this product and/or related services will be updated and changed from time to time, and we will revise this Privacy Policy from time to time, which will form part of this Privacy Policy and have the same effect as this Privacy Policy.
(2) After this Privacy Policy is updated, we will issue an updated version of this product and remind you of the updated content in an appropriate way before the updated terms take effect, so that you can keep abreast of the latest version of this Privacy Policy. By continuing to use our services, you agree to accept and be bound by the revised Policy.
8. Dispute Resolution
1. The establishment, effectiveness, performance, interpretation and dispute resolution of this Agreement shall be governed by the laws of mainland China.
2. If any dispute or controversy arises between you and us due to the policy of this Agreement, it shall first be settled through friendly negotiation; If the negotiation fails, you agree to submit the dispute or controversy to the people's court where the company is located for jurisdiction.
9. Contact us
1. Contact feedback: If you have complaints, suggestions or questions about personal information protection, you can send them to 1974029957@qq.com, and we will reply to your complaints and reports within 15 working days after verifying and verifying your user identity.
2. This product is operated and serviced by Shenzhen Blue Whale Unlimited Network Technology Co., Ltd. and its affiliates.
This Privacy Policy was updated and published on 2024-04-22 and will take effect at the same time.
Appendix: Explanation of terms
Unless otherwise agreed, the terms used in this Privacy Policy generally have only the following definitions:
1. Personal information (from GB/T 35273-2020 "Information Security Technology, Personal Information Security Specification") recorded electronically or by other means, which can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. The personal information that may be involved in this Privacy Policy includes the basic information of a natural person (including name, address, telephone number, and e-mail address), personal identification information (including ID number), network identification information (including system account number, IP address, email address, and passwords, passwords, and password protection answers related to the foregoing), personal property information (including bank account numbers, passwords, transaction and consumption records, virtual currency, virtual transactions, redemption codes and other virtual property information), address book information, and Personal Internet access records (including website browsing records, software usage records), device information (including 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), Personal location information (including approximate geographic location, precise location information, longitude, latitude). The specific types of personal information we actually collect are subject to the descriptions above.
2. Personal sensitive information (from GB/T 35273-2020 "Information Security Technology Personal Information Security Specification"): Once leaked, illegally provided or abused, personal information that may endanger personal and property safety, and can easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment. Sensitive personal information that may be involved in this Privacy Policy includes your personal property information, personal identification information (including ID number), network identification information, address book information, precise location information, and contact address. The specific types of sensitive personal information we actually collect are subject to the following descriptions. The specific types of sensitive personal information we actually collect are subject to the descriptions above.
3. Device: means a device that can be used to access our products and/or services, such as a desktop computer, laptop, tablet or smartphone.
4. SSL: SSL (Secure Socket Layer), also known as Secure Socket Layer, is a security protocol implemented on the transmission communication protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which use public and symmetric key technologies to keep information private.
5. Cookies: Cookies are small files containing strings of characters that are sent to or stored on your computer, mobile device or other device (usually encrypted) when you log in to and use a website or other web content.
6. De-identification/anonymization: refers to the process of technical processing of personal information so that the personal information subject cannot be identified without the help of additional information, and the processed information cannot be restored.
7. Server Logs: Normally, our servers automatically record web page requests that you make when you visit the website. These "server logs" typically include 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 refer to companies and institutions that control, are controlled by, or are under common control with us now and in the future. Control refers to the ability to directly or indirectly influence the management/operation of the controlled object through ownership, voting shares, contracts, actual operational associations or other legally recognized means.
Attachment: A list of permissions
【Permission Description】
1. In order to ensure the realization of the functions and the safe and stable operation of the product, we may apply for or use the relevant permissions of the operating system;
2. In order to protect your right to know, we display the relevant operating system permissions that the product may apply for and use through the following list, and you can manage the relevant permissions according to your actual needs;
3. According to the upgrade of the product, the type and purpose of the application and use of the right may change, and we will adjust the list according to these changes in time to ensure that you are informed of the application and use of the right in time;
4. Please be aware that we may also use third-party SDKs for the functional and security needs of our business and products, and these third parties may also apply for or use relevant operating system permissions.
5. In the process of using the product, you may use H5 pages or mini-programs developed by third parties, and these plug-ins or mini-programs developed by third parties may also apply for or use relevant operating system permissions as necessary for business functions.
【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: Third-party SDK directory
In order to ensure the realization of the relevant functions of the application and the safe and stable operation of the application, we may access the software development kit (SDK) provided by a third party to implement the relevant functions. We list the relevant third-party SDKs in the catalog. Please note that the data processing type of third-party SDKs may change due to their version upgrades, policy adjustments, etc., please refer to the official instructions published by the third-party SDKs. The relevant third-party SDKs we have access to are:
Tencent Ads
Provider: Tencent Technology (Shenzhen) Co., Ltd
Purpose of use: Provide the pull and display functions of ads, anti-cheat and reduce the data diagnosis function of App crash
Personal information involved: device information (device manufacturer, device model, operating system version, screen resolution, screen orientation, screen DPI, IP address, accelerometer, magnetic field sensor), identifier (IMEI/MEID, DeviceID, Android_ID), application information (process name, running status, suspicious behavior of the host application), running process, usage data (product interaction data, advertising data such as impressions, clicks, conversion advertising data), Diagnostic data such as crash data, performance data
Link to Privacy Policy: https://e.qq.com/dev/help_detail.html?cid=2005&pid=5983
Today's headline advertising service
Provider: Beijing Mega Engine Network Technology Co., Ltd
Purpose of use: The ads function properly and load display ads accurately
Personal information involved: device information (basic information such as device brand, model, software system version, resolution, network signal strength, IP address, device language, sensor information), device identifier (such as IMEI, OAID, IMSI, ICCID, GAID (GMS service only), MEID, device serial number, build_serial etc., specific fields vary depending on software and hardware versions), application information (developer application name, application package name, version number, Application backend status), running processes, advertising information, location information
Link to Privacy Policy: https://partner.oceanengine.com/privacy
Wechat
Provider: Tencent Technology (Shenzhen) Co., Ltd
Purpose of use: Provide functions such as sharing to WeChat sharing, collection, WeChat login, etc
Personal information: device information (including device identifiers, device platforms, device manufacturers, and device brands), application list information, network information, location information, and storage space information
Link to Privacy Policy: https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8
Provider: Huawei Technologies Co., Ltd
Purpose: Programmatic advertising, ad measurement attribution and anti-cheating
Personal information: device information (advertising identifier (OAID), device identifier (IMEI, Android ID), device brand, model, sensor information, basic system information (operating system information)), network information, location information (approximate location information (WLAN information, Bluetooth information)), application information (application basic information, application installation list, running process), application usage information (advertising interaction behavior (advertising interaction records, such as exposure, clicks, Conversions, etc.), contextual information (contextual real-time information (page topic, article or video title, article or image link, etc.), (optional) latitude and longitude information)
Link to Privacy Policy: https://developer.huawei.com/consumer/cn/hms
Baidu Ads
Provider: Baidu, Inc
Purpose of use: Advertising function
Personal information involved: device information: device brand, model, software system version, resolution, network signal strength, sensor information, total disk space, total system memory space, mobile phone restart information, mobile phone system update time and other basic information, OAID, AndroidID (collected only on Andriod), running process, application information: application package name, application background and backend status, device information: IMEI, IMSI, MEID (collected on Andriod only); IDFA (iOS only), location information
Link to Privacy Policy: https://union.baidu.com/bqt/#/legal/policies
Kuaishou advertising
Provider: Beijing Kuaishou Technology Co., Ltd
Purpose of use: Advertising delivery, optimization of advertising effect, application of anti-cheating
Personal information involved: device information, device identification (IMEI, MEID, OAID, AndroidId, IMSI, ICCID), location information (IP address, MAC address, GPS location information, base station information, WIFI information), application information (application installation list), running processes, sensor information, SIM card activation information
Link to Privacy Policy: https://u.kuaishou.com/home/help/detail/1337/1425
Pangolin advertising SDK
Provider: Beijing Mega Engine Network Technology Co., Ltd
Purpose: To provide users with ad display, ad attribution, anti-cheat services, optimize the advertising scene and advertising element rendering, and identify the list of installed applications to optimize the advertising effect
Personal information involved: device information (basic information such as device brand, model, software system version, resolution, network signal strength, IP address, device language, sensor information), device identifier (such as IMEI, OAID, IMSI, ICCID, GAID (GMS service only), MEID, device serial number, build_serial etc., specific fields vary depending on software and hardware versions), application information (developer application name, application package name, version number, App backend status), advertising information, location information
Link to Privacy Policy: https://ad.oceanengine.com/union/media/privacy
cocos2dx
Purpose of use: to assist in development
Personal information involved: device access permissions, location permissions, network permissions, external storage access rights, and obtain device brand, model, WIFI status, and network connection information after the user's consent
Alibaba Cloud SDK
Provider: Alibaba Group Holding Limited
Purpose: To monitor app crashes, ANRs, and other issues
Personal information involved: device information, log information
Link to Privacy Policy: https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202107091605_49213.html?spm=a1zaa.8161610.0.0.58374144iNf5pq
Datatalk SDK
Provider: Beijing Volcano Engine Technology Co., Ltd
Purpose of use: Digital Talk SDK
Personal information involved: device information, network information, wifi information. The SDK will involve the relevant capabilities of iFLYTEK AI Marketing Cloud, and after your consent, it will obtain the storage device permission, location permission, current application information, and recording permission required for voice interaction advertising.
Link to Privacy Policy: https://datarangers.com.cn/help/doc?lid=1584&did=10959
Snebula Ads SDK
Purpose of use: The APP integrates the Snebula advertising SDK for normal and accurate loading of display ads and ad tracking services.
Personal information involved: type of data collected: device identification information, network information; Obtain your device information with your consent.
Digital Alliance
Provider: Beijing Digital Alliance Network Technology Co., Ltd
Purpose of use: to detect device fraud and cheating, and to identify the authenticity of the feedback device.
Personal information involved: device manufacturer, device model, device system version, application version, sensor, gyroscope, software list, device network status information, and other equipment physical environment information
Link to Privacy Policy: https://www.shuzilm.cn/privacy.html
sigmob
Provider: Beijing Chuangzhi Convergence Technology Co., Ltd
Purpose of use: Ad delivery, advertiser attribution, anti-cheating
Personal information involved: device information: device brand, model, operating system version, OAID, resolution and other basic device information, application information: application name, application package name, application version number, etc., running processes, others: carrier information, time zone.
Link to Privacy Policy: https://www.sigmob.com/policy.html
Attachment: Children's Data Protection Statement
Attachment: Children's Data Protection Statement
We are committed to protecting the personal information of children who use our products or services. The Children's Information Protection Statement (hereinafter referred to as "this Statement") and the Privacy Policy are intended to explain to guardians (hereinafter referred to as "you") and children how we collect, use, store and process children's personal information, and the ways we provide you and your children to access, correct, delete and protect this information. Unless otherwise agreed, the terms and abbreviations used in this Statement have the same meanings as those in the User Agreement and Privacy Policy.
Special Instructions
1. Special instructions for children's guardians:
If you are the guardian of a child user, please read carefully and choose whether to agree to this statement. We hope that you will work with us to protect children's personal information, educate and guide children to enhance their awareness and ability to protect personal information, and guide, remind and require them not to provide any personal information to any network product and service providers without your consent.
2. Special instructions for children:
(1) If you are a minor under the age of 14, you need to read this statement carefully with your guardian and use our products and services or provide us with information after obtaining the consent of your guardian.
(2) Please choose whether to agree to the relevant privacy policy and whether to agree to your and the children under your guardianship to use our products or services after carefully reading and fully understanding the Privacy Policy and this statement. If you do not agree with the relevant privacy policy and the content of this statement, or do not agree to the necessary information to provide services, it may cause our products or services to fail to operate normally, or fail to achieve the service effect we intended, and you and the children under your guardianship may not be able to use our products, services or related specific business functions normally.
By clicking "Agree", you agree to our collection, use and processing of your and your children's information in accordance with the Privacy Policy and this Statement.
(3) Please understand that this statement only applies to our products or services that are specially designed for children under the age of 14, products or services with functional sections specifically for children under the age of 14, or products or services that require the user to enter the date of birth, age information and other products or services that can identify the user's age. For products or services that cannot or actively identify the age of users, the Privacy Policy applies. 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 QQ, WeChat, Weibo. Please note that such third parties may collect, use or process information about children, and such third parties need to obtain your consent separately. We recommend that you ask your child for your consent before authorizing the third party to collect and process any of their personal information.
(4) We remind you that the important terms in this statement that are (may) closely related to the rights and interests of you and the children under your guardianship are (maybe) closely related to you, and we have used bold fonts to remind you in special respect, please pay attention to them.
(5) If you have any questions or requests for rights related to personal information during the process of reading this statement, we have provided you with contact information, and we will answer you as soon as possible.
1. What Information We Collect
1. We strictly abide by the provisions of laws and regulations and the agreement with users, and collect the following personal information of you and the children under your guardianship according to the specific situation of the user's choice of products or services.
2. For our products and services specifically for children under the age of 14 or some functional sections of products and services, or products or services that require users to input date of birth, age information and other products or services that can identify the age of users, such as registering or using such products or services, we will require users to fill in personal birthday information to identify whether the user is a child under the age of 14, and in accordance with the provisions of laws and regulations, children will be allowed to continue to use relevant products or services only after obtaining the consent of their guardians.
3. When we identify a user as a child under the age of 14 based on the above information provided by the user, we will collect your contact information, including mobile phone number and email address, and use this information to contact you to verify the guardianship relationship between you and the child under your guardianship. Depending on the specific plan of the product or service to verify the guardianship relationship and obtain your consent, we may also associate your account with the child's account in order to protect the personal information rights and interests of 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 understand and manage the transaction behavior of child users. If the product or service involves the upload of avatar and other functions, we strongly recommend that you instruct your children not to upload real personal portrait photos and other information during the use of our products or services.
4. In the process of children's use of products or services, we will collect relevant information, please refer to the Privacy Policy for details of other children's personal information we collect.
If we need to collect personal information about you or children under your guardianship beyond the scope of collection above, we will inform you again and obtain your consent.
5. 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 some specific information, it may cause our products or services to fail to operate normally, or fail to achieve the service effect we intended, and you and the children under your guardianship may not be able to use our products, services or related specific business functions normally.
2. How we use this information
1. We strictly abide by the provisions of laws and regulations and the agreement with users, and use the information collected from you and the children under your guardianship for the following purposes:
(1) Verify the identity of the child and guardian
(2) To provide necessary products or services, and specific functions of products or services
(3) For product or service optimization, safety assurance, and service investigation purposes
2. If we need to use your personal information or the children under your guardianship beyond the above purposes, we will inform you again and obtain your consent.
III. Circumstances of sharing, transferring, or disclosing children's personal information
In accordance with the provisions of laws and regulations, we strictly restrict the sharing, transfer, and disclosure of children's personal information. In general, we do 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.
(1) Sharing
1. We will share some of the child's personal information (such as the child's user name, account number, password, and the child's transaction content in some of our products and services) with the guardian, and the guardian can access and manage the relevant personal information.
2. For the purpose of external processing, we may share children's personal information with third-party partners (third-party service providers, contractors, agents, application developers, etc., e.g., 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) and let them process the above information for us in accordance with our instructions, privacy policy and relevant confidentiality and security policies.
3. 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 the entrusted party to process the personal information of children not beyond the scope of our authorization, and we entrust the third party to process children's personal information mainly for the following purposes:
(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 in the Privacy Policy and this Statement;
(4) To understand, maintain, and improve our services.
If we share your and children's information with the above-mentioned third parties, we will conduct a security assessment and use encryption, anonymization, de-identification and other means to ensure the security of your and children's information.
(2) Assignment
1. With the continuous development of our business, when a merger, acquisition, asset transfer or other transaction results in the sharing of your and children's personal information with a third party, we will inform you of the relevant circumstances through push notifications, announcements, etc., and continue to protect or require a new manager to continue to protect your and children's personal information in accordance with laws and regulations and standards not lower than those required by this statement.
2. We may anonymize the collected children's information and use it for big data analysis, such as forming heat maps and insight reports that do not contain any personal information.
3. We may disclose and share with our partners the information that does not contain identifying content after statistical processing, for the purpose of understanding how users use our services or for the public to understand the overall usage trend of our services.
(3) Disclosure
In general, we prohibit the disclosure of children's personal information to the outside world, but we may disclose children's personal information for the following purposes:
(1) Comply with applicable laws and regulations;
(2) comply with the provisions of court judgments, rulings or other legal procedures;
(3) Comply with the requirements of relevant government agencies or other legally authorized organizations;
(4) We have reason to believe that we need to comply with laws and regulations;
(5) Reasonable and necessary purposes for 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, us or our affiliates, other users or employees.
4. Storage of children's personal information
1. 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 purposes for which it was collected and used. Please review our Privacy Policy to learn more about how we store and protect children's personal information.
2. When our products or services cease operation or the storage period of your and children's personal information expires, we will delete or anonymize your and children's personal information within a reasonable period of time.
5. Management of children's personal information
During the use of this product or service by child users, in order to make it more convenient for you and children to access, correct and delete relevant personal information, we have provided you with corresponding operation settings in the product design, and you can also provide feedback and consultation on relevant information through the contact information provided by us. 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 personal information such as the child's account number, date of birth, and contact information, so that we can continue to respond to your needs after completing the identity verification and question verification.
1. Access to children's personal information
You and the children under your guardianship can view the personal information provided or generated by child users in the use of our products or services, including but not limited to usernames, passwords, avatars, nicknames, etc.
2. Correction of children's personal information
When you and the child under your guardianship find that there is an error in the personal information we collect, use and process about the child, you can contact us to correct it. We will take timely steps to correct the issue after we have completed the identity verification and verification process.
3. Delete children's personal information
You and the children under your guardianship may request us to delete the children's personal information collected, used and processed under the following circumstances. Once we have completed the identity verification and verification of the issue, we will take timely steps to remove it.
(1) If we collect, store, use, transfer, or disclose children's personal information in violation of the provisions of laws, administrative regulations, or the agreement between the two parties;
(2) If we collect, store, use, transfer, or disclose children's personal information beyond the scope of the purpose or the necessary period;
(3) you withdraw your consent;
(4) You or the child under your guardianship terminates the use of the products or services through cancellation or other means.
However, please note that if you and the child under your guardianship request us to delete the personal information of a specific child, the child user may not be able to continue to use our products and services or some specific business functions in the products and services.
If you become aware that your child's personal information has been collected without your prior consent, please contact us and we will try 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, he or she has the right to manage his or her own account. If a child user chooses to manage their own product account, you will no longer be able to access or control their account. When the child under guardianship has the right to manage the account of this product by himself, we will notify you and the child under guardianship.
6. Application of this Statement
1. This statement only applies to our products or services that are specifically for children under the age of 14, products or services with functional sections specifically for children under the age of 14, or products or services that require the user to enter date of birth, age information and other products or services that can identify the user's age. Please understand that if there is anything not specified in this statement, the Privacy Policy shall apply by reference.
2. In the case of the application of this statement, if there is any inconsistency between this statement and the provisions of the Privacy Policy, this statement shall prevail.