Last updated on: January 31, 2022
Guangdong HeyTap Technology Co., Ltd. ("we", "us", or "our", registered at Room 202, No. 112 ShaXing Road, Wusha, Chang'an, Dongguan, Guangdong, China) always attaches great importance to its obligation to protect children and strives to create a healthy online environment for children. This HeyTap Privacy Notice for Children (this "Privacy Notice") aims to explain to guardians ("you") and their children (minors under the age of 14) how we collect, use, disclose, protect, store, and transfer the personal information of children.
- Guardians shall carefully read this Privacy Notice together with their child and determine whether to accept it. We hope that you can work with us to jointly protect the child's personal information, teach and guide them to raise their awareness of personal information protection, and instruct, remind, and require them not to submit any personal information to any network product or service provider without your consent.
- Children under the age of 14 shall carefully read this Privacy Notice in the company of their guardian. They can use our products or services or provide information to us only after obtaining the consent of their guardian.
This Privacy Notice applies to the products or services that we or our affiliates provide to children within the People's Republic of China and those that can identify users as children. In general, we identify users as children based on the HeyTap child accounts they use or based on the age, date of birth, or real-name authentication information that they provide on our product or service pages. Please understand that matters not covered in this Privacy Notice shall be subject to the general HeyTap Privacy Notice or the product- or service-specific Privacy Notice. Should any inconsistency occur between this Privacy Notice and the general HeyTap Privacy Notice or any product- or service-specific Privacy Notice, this Privacy Notice shall prevail.
Where we cannot identify users or determine whether the personal information that we collect and process relates to a child, we will process the personal information in accordance with the general HeyTap Privacy Notice or the product- or service-specific Privacy Notice.
Agreeing to this Privacy Notice only means that you have understood the features that our products or services provide and the personal information of your child ("the child") necessary for running the features. It does not mean that you have agreed to us collecting other additional personal information of the child. If we need to collect additional personal information, we will do so only with your authorization that we separately obtain during the child's use of the features.
Please determine whether to allow the child to use our products or services after carefully reading and fully understanding the general HeyTap Privacy Notice, the product- or service-specific Privacy Notice, and this Privacy Notice. By allowing the child to use our products or services, you acknowledge that you are aware that we will collect, use, disclose, protect, store, and transfer the child's personal information in accordance with the general HeyTap Privacy Notice, the product- or service-specific Privacy Notice, and this Privacy Notice.
1. How We Collect and Use Children's Personal Information
We collect personal information about the child in three primary ways: (1) directly from you or the child; (2) automatically from your or the child's use of our products or services; and/or (3) from third parties. The information we collect depends on the products that the child uses, the environment in which the child interacts with us, and the choices the child makes, including the child's privacy settings and the products and features the child uses.
Below are examples of situations in which we may collect and use the child's personal information:
(1) Sign-up for a child account. When you create a child account for the child, we need to collect the child's personal information that you enter, such as the date of birth, phone number, display name, and password. After you create a child account for the child, we will link the child account with your account, and the child can sign in to this child account to use the products or services that we or our affiliates provide.
(2) Parental verification for sensitive behavior. After the child signs in to a product or service that we or our affiliates provide with the child account, we will need to verify your identity when the child attempts to perform certain sensitive behavior. To this end, we may collect your administrator password and information about the child account.
(3) Use of the products or services provided by us or our affiliates with the child account. The child may sign in to the child account to use the products or services that we or our affiliates provide, including Theme Store, Lock Screen Magazine, App Market, Game Center, Quick Games, Browser, and HeyTap Cloud. When providing age-appropriate products or services to the child, we will collect necessary personal information of the child. For details, please refer to their respective Privacy Notice.
(4) If we need to process the child's personal information beyond the scope or purposes stated in the general HeyTap Privacy Notice, the product- or service-specific Privacy Notice, or this Privacy Notice, we will inform you again and obtain your prior consent.
2. How We Share, Transfer and/or Publicly Disclose Children's Personal Information
We strictly restrict the sharing, transfer, and disclosure of children's personal information in compliance with laws and regulations. We share the child's personal information only in the following situations:
(1) Sharing with the child's guardians: We share some of the child's personal information with their guardian so that the guardian can access and manage such personal information.
(2) Sharing with our affiliates: When using the products or services that we or our affiliates provide, the child may be rewarded with certain assets by us or our affiliates and some of the assets will be synchronized with the child account. To assist the child in obtaining the assets, we may share the child's personal information with our affiliates. We will only share the necessary personal information of the child. If we or our affiliates intend to change the purpose for which the child's personal information is used and processed, we will obtain your authorization or consent again.
(3) Sharing with our authorized partners: To fulfill the purposes stated in the general HeyTap Privacy Notice, product- or service-specific Privacy Notices, and/or this Privacy Notice, we may share your child's personal information with our authorized partners, or entrust them with processing such information. We will sign a strict confidentiality agreement or personal information processing agreement with such authorized partners to clarify our responsibilities and those of such partners, the matters that the partners deal with, the period and nature of our collaboration with them, and the purpose for which they process the personal information.
(4) When we are in the process of a merger, acquisition, or bankruptcy liquidation, and if such process requires the transfer of the child's personal information, we will require the new company or organization that holds the child's personal information to continue to be bound by this Privacy Notice; otherwise, we will require this company or organization to obtain your authorization or consent again. If it does not require the transfer of the child's personal information, we will adequately inform you and delete or anonymize all of the child's personal information under our control.
3. How We Protect Children's Personal Information
To secure children's personal information, we have a designated person in charge of children's personal information protection. We take all reasonable and actionable measures to protect children's personal information, including:
(1) Children's privacy protection by design, such as:
- Providing content or services suitable for children;
- Turning off personalized recommendations;
- Limiting ad tracking and stopping the push of profile-based personalized ads and marketing messages; and
- Providing necessary prompts before the child publishes content.
In addition to the above measures, the products or services may use other varying measures. Before the child uses the products or services, please carefully read and fully understand the relevant terms and privacy policies.
(2) Necessary technical protection measures, for example:
- We protect children's personal information as sensitive personal information.
- We use mainstream security means such as SSL to encrypt many of our services. We regularly review our practices regarding information collection, storage, and processing (including physical security measures) to protect our systems from unauthorized access or alteration.
- We strictly control access to children's personal information and only grant access permissions to our employees and those of an authorized service provider who need to access children's personal information in order to help us process such information. These employees are subject to strict contractual confidentiality obligations.
- We carefully select business partners and service providers and include our requirements for protecting children's personal information in our business contracts, audits, and/or assessments. We do not allow the re-delegation of a third party to process children's personal information.
- We conduct security and privacy protection training, tests, and publicity activities to raise our employees' awareness of the importance of protecting children's personal information.
- We use international and industry-recognized standards to protect personal information and actively acquire security and privacy protection certifications.
4. Children and Their Guardians' Rights to Their Personal Information
We respect personal data subjects' rights to their personal data. The following describes the rights to the child's personal information that both you and the child have under the law and how we will protect these rights. If our products or services provide no means to exercise your rights to the child's personal information or if you and the child have any problem in exercising your rights, please feel free to contact us as set forth under "7. Contact Us".
Please note that after reaching the age of 14, the child will have the right to manage their own account. If the child chooses to manage their account by themselves, you will no longer be able to access or control their account. We will notify you and the child when the child has the right to manage their own account.
(1) Right to be informed and decide
Before the child uses any of our products or services, we inform you and the child of how we process children's personal information through the general HeyTap Privacy Notice, the product- or service-specific Privacy Notice, and this Privacy Notice as well as, where required by law, through a pop-up window, an announcement, or SMS or email. We are committed to staying transparent about how we use children's personal information. Before the child uses any of our products or services, please carefully read the relevant terms and privacy policies and decide whether to allow the child to use the product or service.
(2) Right to view and copy personal information
Both you and the child have the right to view and copy the child's personal information, including but not limited to viewing the display name, profile picture, date of birth, and other personal information of the child account on the relevant product or service page.
(3) Right to rectify and complete personal information
If you and the child find that any of the child's personal information that we hold is inaccurate or incomplete, both you and the child have the right to request us to correct or complete it. For example, you may go to the child account management page to correct or complete the account information, such as the display name and date of birth. Please note that to prevent the provision of inappropriate content from our products or services caused by the child's modification of certain account information, we only allow you to modify certain child account information (such as the date of birth) or allow the child to do so only with your consent.
(4) Right to delete personal information
If you and the child discover that we have processed the child's personal information in violation of laws, administrative rules, or the agreements between you and us, you or the child has the right to request the deletion of the child's personal information that we collected, used, and/or processed.
(5) Right to withdraw consent
You can change the scope of the child's personal information you authorize us to collect or withdraw your authorization by deleting information, turning off app permissions, or changing relevant product or feature settings. You may also delete the child account to withdraw your consent to our further collection of the child's personal information in connection with the products or services accessed or used with the child account. However, the withdrawal of your consent shall not affect the lawfulness of data processing based on consent before its withdrawal.
(6) Right to complain
We will respond to the questions, concerns, or recommendations raised by you or the child within the time limit specified by law. If you are not satisfied with our reply, particularly if our processing of the child's personal information damages the legitimate rights and interests of the child, you can also file a complaint or report it to regulatory authorities such as the Cyberspace Administration of China, a relevant public security organ, and the State Administration for Market Regulation, or file a lawsuit with the court with jurisdiction.
5. Third-Party Service Providers and Their Services
Our websites, products, apps, and services may contain links to third-party websites, products, or services (collectively, "Third-Party Services"). Please note that this Privacy Notice does not apply to data collection by any Third-Party Services. Such Third-Party Services should ask for your consent before processing the personal information of your child. You are encouraged to ask your child to communicate with you before submitting any of their personal information to a third party concerned.
6. How Children's Personal Information Is Transferred Globally
The child's personal information that is collected or generated during our operations in the People's Republic of China will be stored on our server deployed in the People's Republic of China. If certain products or services require the cross-border transfer of the child's personal information, we will provide such information to the recipients outside the People's Republic of China in compliance with laws and regulations. In addition, we will inform you of the names and contact information of the recipients as well as the purpose for which the personal information is transferred, the information processing methods, the type of personal information to be transferred, and the methods and procedures for you to exercise your rights to such personal information, and we will separately ask for your prior consent.
7. Contact Us
We have a dedicated department for personal information protection and a designated person in charge of children's personal information protection. You may go to our Data Subject Rights Platform to contact that person. After verifying your identity, we will respond to your or your child's question, concern, or recommendation within the time limit specified by law.