Children's Privacy Protection Policy
Effective date: November 1st, 2024
Guangdong Qunyu Interactive Technology Co., Ltd. (hereinafter referred to as "Qunyu" or "we") attaches great importance to the personal information and privacy security of children (referring to minors under the age of 14, the same below). The 《Children's Privacy Protection Policy》 (hereinafter referred to as "this policy") and the 《Privacy Policy》 aim to explain to you the corresponding processing rules and other related matters when we collect and use children's personal information.This policy is a special rule formulated based on the 《Privacy Policy》 and only applies to products or services that we can identify as children; In case of any conflict between this policy and the 《Privacy Policy》, this policy shall prevail; For matters not covered in this policy, the 《Privacy Policy》 shall prevail.Unless otherwise agreed, the terms and abbreviations used in this policy have the same meaning as those in the 《User Agreement》and 《Privacy Policy》.
Parents or other guardians of children (hereinafter referred to as "guardians") are requested to carefully read and thoroughly understand this policy before using this product and service. They must confirm that they fully understand and agree to all terms before starting to use or allowing their children to use this product and service. Specifically, please focus on reading the important terms that are closely related to your and the children under your guardianship, which we have highlighted in bold.
Special instructions for child guardians:
If you are the guardian of a minor under the age of 14, please carefully read and choose whether to agree to this policy. By clicking to agree to this policy online or by other means, you agree to our collection, use, storage, sharing, transfer, and disclosure (collectively referred to as "processing") of your guardian's personal information in accordance with this policy. If you do not agree with this policy, it may result in the malfunction of this product and service or the inability to achieve the intended service effect. You should request your guardian to immediately stop accessing or using this product and service. If your ward uses or continues to use this product and service, or submits their personal information, it means that you agree to our processing of your ward's personal information in accordance with this policy (including updated versions).
In addition to this policy, we may also inform you of specific personal information collection purposes, scope, and usage through instant messaging methods such as pop ups, page prompts, etc. These instant messaging contents constitute a part of this policy and have the same legal effect as this policy.
Special instructions for children:
Any child participating in online activities should obtain the consent of their guardian in advance. If you are a child, please notify your guardian to read this policy together and seek their consent and guidance before using this product service or submitting personal information. If you use or continue to use this product and service, or submit personal information, it means that you have obtained permission from your guardian, and both you and your guardian agree that we will process your personal information in accordance with this policy.
After reading this policy, if you have any questions about this policy or matters related to this policy, you can contact us through the feedback channels listed in the "7. How to Contact Us" section of this policy and we will provide answers as soon as possible.
This policy will help you understand the following:
a、How do we collect and use children's personal information
b、How do we delegate the processing, sharing, transfer, or disclosure of children's personal information
c、How do we protect children's personal information
d、How do we store children's personal information
e、How to exercise children's personal information related rights
f、Revision of this policy
g、How to Contact Us
a、How do we collect and use children's personal information
1. We will strictly abide by laws and regulations, follow the principles of legitimacy and necessity, informed consent, clear purpose, security protection, and lawful use, and collect and use children's personal information. After obtaining the consent of the guardian, we will collect personal information of children based on their specific use of products and services for the following purposes:
（1） Identify child users and obtain guardian consent:According to laws, regulations, and industry management requirements, we may require users to provide information on whether they are over 14 years old in order to identify child users and obtain consent from guardians for our processing of children's personal information.
（2） Collecting personal information of children during the use of this product and service:In the process of children using this product and service, we will collect and use other children's personal information. Please refer to the "II. How We Collect and Use Your Personal Information" section of the 《Privacy Policy》 for details.
（3） If we collect or use other personal information of guardians or children beyond the aforementioned scope, we will inform and obtain the consent of the guardians again.
2. Children's personal information belongs to sensitive personal information. Guardians and children are advised to be cautious and pay attention to sensitive personal information of children. If the product or service involves uploading avatars and other functions, we strongly recommend that you guide children not to upload real personal portrait photos and other information while using our product or service.
3. The guardian agrees that we will handle sensitive personal information related to children in accordance with this policy.
b、 How do we delegate the processing, sharing, transfer, or disclosure of children's personal information
1. We only entrust the processing, sharing, transfer, or disclosure of children's personal information in compliance with legal and regulatory requirements.
2. This product service may provide children with access to or link to skills, products, or services provided by third parties (including products and services or other forms of services). Third party skills, products, and services are operated by relevant third parties. Children using third-party skills, products, and services (including any information provided by children to such third parties) are subject to the third party's own terms of service and information protection statement (not this policy), and guardians and children need to carefully read their terms. This policy only applies to the personal information we collect and does not apply to any third-party services or information usage rules provided by third parties. If guardians and children discover risks in these skills, products, and services, it is recommended to terminate the relevant operations to protect the legitimate rights and interests of children and contact us promptly.
3. Regarding the specific situation of entrusting us to process, share, transfer, or disclose children's personal information, as well as the types of third-party services that we access or link to, please refer to the "Section 4: How We Entrust Processing, Sharing, Transfer, and Publicly Disclose Your Personal Information" of the 《Privacy Policy》. In addition, we will take the following measures to protect the security of children's personal information during the sharing, transfer, and public disclosure process, including but not limited to:
（1） We will only share children's personal information for legal, legitimate, necessary, specific, and clear purposes. We will conduct security assessments and sign strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to handle information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures;
（2） If we entrust a third party to process children's personal information, we will require them to take protective measures for children's personal information and strictly comply with relevant laws, regulations, and regulatory requirements. We will require third parties who receive children's personal information to comply with strict confidentiality obligations and take effective confidentiality measures, prohibit them from using these children's personal information for purposes not authorized by the child and their guardian, and require the entrusted company to fulfill the following obligations in accordance with the law:
1）Process children's personal information in accordance with laws, administrative regulations, and our requirements;
2）Assist us in responding to applications from child guardians;
3）Take measures to ensure information security and provide timely feedback to us in the event of a child's personal information leakage security incident;
4）Timely delete children's personal information when the entrusted relationship is terminated;
5）No delegation is allowed;
6）Other obligations to protect children's personal information that should be fulfilled according to law.
4. According to legal provisions, entrusting the processing, sharing, transfer, or disclosure of anonymized personal information of children, and ensuring that the recipient of the child's personal information cannot recover and re identify the information subject, does not constitute entrusting the processing, sharing, transfer, or disclosure of child's personal information. The storage and processing of such information will not require separate notification to the guardian and the consent of the guardian.
c、 How do we protect children's personal information
We attach great importance to the protection of children's personal information and have taken reasonable security measures such as encrypted storage to protect children's personal information. We adhere to the principle of minimum authorization and only allow employees and third parties who need to know this information to access children's personal information. We have established strict access control and monitoring mechanisms to record and control the handling of children's personal information, in order to avoid illegal duplication and downloading of children's personal information. For specific information on how we protect children's personal information, please refer to the "V. How We Protect Your Personal Information" section of the 《Privacy Policy》.
d、How do we store children's personal information
The personal information we collect and generate within the territory of the People's Republic of China is stored within the territory of the People's Republic of China. Generally speaking, we only store children's personal information for the time necessary to achieve the processing purposes described in this policy, unless otherwise provided by applicable laws, regulations, or national normative documents. For specific information on how we store children's personal information, please refer to the "VI. How We Store Your Personal Information" section of the 《Privacy Policy》.
e、How to exercise children's personal information related rights
If you or your guardian have any questions about the use of our children's personal information for any reason, and wish to access, correct, supplement or delete children's personal information, or need to change the scope of your authorization for us to collect children's personal information, or revoke your authorization, you can manage your child's personal information by accessing, correcting or deleting information, canceling your account, disabling device functions, etc. Regarding how you exercise other rights related to children's personal information and the specific ways to exercise them, please refer to the "7. How do you realize the right to manage your personal information" section of the 《Privacy Policy》. If you have any questions or need assistance, you can contact us through the feedback channels listed in the "7. How to Contact Us" section of this policy.
f、Revision of this policy
In order to provide better services, we may modify the terms of this policy in a timely manner based on updates to our products and services, as well as relevant legal and regulatory requirements. Such modifications constitute a part of this policy. If such modifications result in a substantial reduction or significant change in the rights of guardians and children under this policy, we will notify them through product and service announcements, push notifications, pop-up prompts, or other means before this policy takes effect. If guardians do not agree with such modifications, they may choose and should immediately require children to stop using this product and service. If the child continues to use this product and service, it shall be deemed that the guardian has fully read, understood, and accepted the modifications we have made to the relevant terms of this policy.
The significant changes referred to in this policy include but are not limited to:
1. Our service model has undergone significant changes. Such as the purpose of processing personal information, the type of personal information processed, and the way in which personal information is used;
2. We have undergone significant changes in ownership structure, organizational structure, and other aspects. Changes in ownership caused by business adjustments, bankruptcy mergers and acquisitions, etc;
3. The main objects of personal information sharing, transfer or public disclosure have changed;
4. There has been a significant change in your right to participate in personal information processing and the way you exercise it;
5. When the responsible department, contact information, and complaint channels for handling personal information security change;
6. When the personal information security impact assessment report indicates the presence of high risks.
g、How to Contact Us
If guardians and children have any questions, opinions or suggestions regarding this policy and the protection of children's personal information, please feel free to contact us through the following methods:
TEL：0754-88098777
Please understand that in order to ensure safety, we may need the guardian to provide relevant materials to prove their guardian identity before responding to the questions raised by the guardian. We will review the issues as soon as possible and provide feedback within 15 working days after verifying your user identity or within the time limit specified by laws and regulations. If you are not satisfied with our response, especially if you believe that our handling of children's personal information has harmed your legitimate rights and interests, you can also seek a solution through the following external channels: file a lawsuit with the Shantou People's Court in Guangdong Province.