Children's Privacy Protection Statement
Update Date: January 14, 2022
Zemismart Technology Limited (hereinafter referred to as "we" or "Zemismart Technology") is committed to protecting the personal privacy of children (i.e., minors under the age of fourteen) who use our products and services. This "Children's Privacy Protection Statement" is intended to explain to parents and other guardians (hereinafter referred to as "guardians" or "you") how we collect and use children's personal information related to our products and services, the rules for processing such information, and the ways in which guardians can access, correct, delete, and protect this information.
Special Note for Guardians:
We will protect the personal information and privacy of children according to this statement, and we also ask for your help in protecting your child's personal information and privacy. Please ensure that they read and accept this statement under your supervision and use our products and services with your consent and guidance. Please note that by agreeing to this statement, or by your child starting or continuing to use our products or services, or submitting their personal information, you are indicating your consent for us to collect, use, store, share, transfer, and disclose your child's personal information as per this statement.
Special Note for Children:
We recommend that any child use our products or services only after obtaining consent from a guardian. If you are a child, you need to carefully read this statement with your guardian and use our products, services, or provide information to us after obtaining their consent.
We hereby remind you to read and fully understand this statement and the "Privacy Policy" (especially the terms highlighted in bold) before deciding whether to agree to all the terms and whether to allow the children under your guardianship to use our products or services. If you disagree with the relevant terms of the "Privacy Policy" and/or this statement, or if you do not agree to provide certain necessary information when using specific functions or scenarios of some of our products or services, please understand that you and the children under your guardianship may not be able to use our products, services, or related specific functions or scenarios normally. In terms of children's privacy protection, this statement shall prevail if there is any inconsistency with the "Privacy Policy". If this statement does not cover certain matters, the "Privacy Policy" shall apply.
This statement applies to products or services that require users to input birthday, age, or other information that can identify the user's age, or to specific devices and their functions and scenarios designed and developed for children through our software (including mobile applications, mini-programs, etc.). The products and services we provide may include products or services provided by third parties, and you may also log in and use third-party products or services through our software or products (such as ZEMISMART). The third party may collect, use, or process the child's relevant information. We recommend that you allow children to seek your consent before authorizing any third party to collect and process their personal information.
If you have any questions about the terms in this statement, or if you have any requests related to personal information rights when using our products or services, please contact us through the dedicated channels we have opened for you, as detailed in the "Contact Us" section of this statement. We will process and respond to your inquiries or requests as soon as possible after receiving your message.
What Information We Collect
We will strictly follow the obligations and responsibilities for the protection of children's personal information as stipulated by laws and regulations, as well as the relevant privacy policies and this statement. With the consent of the guardian, we will collect and use children's personal information based on the specific needs of related products and services.
In the process of providing certain products or services specifically aimed at children, in order to provide these products or services, we may require users to fill in personal birthday information to identify whether the user is a child under the age of 14, and only allow the child to continue using the relevant products or services after obtaining the guardian's consent in accordance with the provisions of laws and regulations.
When you and the children under your guardianship use specific devices controlled by our software, we may collect and use necessary children's personal information in certain functions or scenarios, including age/age information, motion information, and geographical location information, etc. The specific types and scope of information involved will be determined based on the functions of the product and the intelligent scenarios used.
During the use of products or services by children, we may collect other relevant information. For a detailed understanding of other children's personal information we collect, please refer to the "What Personal Information We Collect" section of our "Privacy Policy".
If we need to collect personal information from you or the children under your guardianship beyond the scope mentioned above, we will inform you again and obtain your consent.
Please understand that you can choose whether to fill in or provide specific information, but if you do not fill in or provide certain specific information, it may lead to our products or services being unable to function normally, or not achieving the service effects we intend, and you and the children under your guardianship may not be able to use our products, services, or related specific business functions normally.
How We Use This Information
We strictly comply with the provisions of laws and regulations and the agreements with users, and use the information collected from you and the children under your guardianship for the following purposes:
- a) To provide necessary products or services, and specific functions of the products or services;
- b) For the purpose of optimizing products or services, safety assurance, and service surveys.
If we need to use the personal information of you or the children under your guardianship beyond the purposes mentioned above, we will inform you again and obtain your consent.
Sharing, Transferring, and Disclosing Children's Personal Information
We follow the provisions of laws and regulations and strictly limit the circumstances in which we share, transfer, or disclose children's personal information. Under normal circumstances, we do not share children's personal information with third parties. We only share children's personal information with third parties with the prior consent of the guardian.
- a) Sharing with Guardians
We will share some children's personal information (such as the child's username, account, password, and the transaction content of the child in some of our products and services, etc.) with the guardian, who can access and manage the relevant personal information.
- b) Sharing with Third Parties
Only 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., such as communication service providers who send emails or push notifications on our behalf, map service providers who provide location services for us) (they may not be located in your jurisdiction) according to our instructions, privacy policy, and related confidentiality and security policies to process the information for us.
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 actions, sign a trust agreement, and require the entrusted party's processing actions not to exceed our authorized scope. The main purposes for which we entrust third parties to process children's personal information are:
- To provide our services to children;
- To achieve the purposes described in the "How We Use This Information" section;
- To fulfill our obligations and exercise our rights as stated in our "Privacy Policy" and this statement;
- To understand, maintain, and improve our services.
If we share your and the child's information with the above third parties, we will conduct a security assessment and use encryption, anonymization, de-identification processing, and other means to ensure the security of your and the child's information.
As our business continues to develop, when a merger, acquisition, asset transfer, or other transactions occur that lead to the sharing of your and the child's personal information with a third party, we will inform you through push notifications, announcements, and other forms, and continue to protect or require the new manager to continue protecting your and the child's personal information according to the standards that are not lower than those required by this statement.
We may use the collected children's information for big data analysis after anonymization treatment, such as forming a service usage report for you.
- c) Other Disclosure Circumstances
Under normal circumstances, we prohibit the disclosure of children's personal information externally, but we may disclose children's personal information for the following purposes:
- To comply with applicable laws, legal procedures, or requests from public authorities and government bodies;
- To fulfill our terms of use and other agreements, policies, or standards, including investigating any potential misuse;
- To protect the rights, privacy, safety, or property of us and/or other users, including you, and to seek available detection, prevention, remedial measures, or to limit the damages we may need to provide or resolve security, fraud, or technical issues.
Storing Children's Personal Information
We will take technical measures such as encryption to store children's personal information and ensure its security. We will not store children's personal information for longer than necessary to achieve the purpose for which it was collected and used. For more details on how we store and protect children's personal information, please refer to the "Where and How Long We Store Information" and "Information Security" sections of our "Privacy Policy".
If our products or services cease operation, or if the storage period for you and the children's personal information expires according to the requirements of this statement or the "Privacy Policy", we will notify you and the children through push notifications, announcements, emails, and other forms, and delete or anonymize your and the children's personal
