Children's Privacy Statement
Effective Date: January15, 2025
Updated: January 15,2025
Shenzhen Hengha Smart Electronics Co., Ltd. and itsaffiliates (collectively, "we", "us", "our", or"HH Smart") are committed toprotecting the privacy of children (i.e., minors under 13 years of age orsuch other age provided by applicable law in your country/region of residence)who use our products and services. This Children's Privacy Statement (includingsubsequent updates, collectively, this "Statement") and the HH SmartPrivacy Policy are intended toexplain to children's parents or other guardians ("guardians" or"you") how we collect and use children's personal information inconnection with our products and services, the rules applicableto processing such personal information, and the ways in whichguardians may access, correct, delete, and protect such personal information.
Special Instructions for aGuardian:
We protect the personal information and privacy ofchildren in accordance with this Statement. You are expected to help us protectthe personal information and privacy of children under your custody, torequire them to read and accept this Statement together with you, andto ensure that they use our products and services with your consent andguidance. Please note that if you choose to agree to this Statement, or yourchildren begin, or continue, to use our products or services, orsubmit their personal information, you acknowledge that you agree to ourcollection, use, storage, sharing, transfer, and disclosure of your children'spersonal information in accordance with this Statement.
Special Instructions forChildren:
We recommend that any child use our products orservices with the prior consent of his/her guardian. If you are a child, pleasebe sure to carefully read this Statement with your guardian, and use ourproducts or services or provide information to us with your guardian's consent.
We hereby remind you that youshall carefully read and fully understand this Statement and the HH Smart Privacy Policy(especially the terms in bold) before choosing whether to agree to the termsand whether to agree to your children's use of our products or services.If youdo not agree to any of the terms of the HH Smart Privacy Policy and/or the content of this Statement, orto provide relevant necessary information in the use of a specific feature orscenario of our products and services, please understandthat you and your childmay not be able to normally use our products or services or the specificfeature or scenario.If there is any inconsistency between this Statement and theHH SmartPrivacy Policy in terms of the protection of children'sprivacy, this Stabtement shall apply. Matters not covered herein shall besubject to the HH Smart Privacy Policy.
This Statement applies to (1) our products orservices that require a user to enter birth date, age, or any other informationthat can identify the user’s age, and (2) specific smart devices and theirfeatures and scenarios designed and developed for children that are controlledby our software (including mobile applications and applets/mini-programs). If there is no information needed fromchild, then the Statement is not applied. The products and services that weprovide may include products or services provided by third parties, and you maylog in and use such third-party products and services through our software orproducts (e.g., App). Such third parties may collect, use, orprocess information related to children.We recommend that you ask yourchildren to seek your consent before authorizing a third party to collector process any of their personal information.
If you have any questions about any term of thisStatement, or you and your children have any requests related to personalinformation during the use of our products or services, please contact usthrough the special channels available to you, which are shown in the"Contact Us" section below. We will handle and respond to yourquestions or requests as soon as possible upon receipt thereof.
I. What Information Do WeCollect?
We will, in strict accordance with the obligationsand responsibilities for the protection of children's personal informationprescribed by applicable laws and regulations, as well as the provisions ofrelevant privacy policies and this Statement, and based on the specificneeds of relevant products and services, collect and use children's personalinformation after obtaining the consent of their guardians.
When providing certain child-oriented products orservices to you and your children, we may require the user to fill in theirbirth date information for the purpose of providing such products or servicesto you so as to identify whether the user is a child and, in accordance withapplicable laws and regulations, allow the child to use relevant products orservices after obtaining the consent of his/her guardian.
When you and your children use aspecific smart device controlled by our software, we may collect anduse your children's personal information necessary for certain features orscenarios, including information on years/monthsof age, movement, and geographic location. Specific types andscope of information involved will depend on the features and intelligentscenarios of the smart device(s) used.
When a child uses our products or services, we maycollect other relevant information from the child. Please refer to the"What Personal Information Do We Collect" section of the HH SmartPrivacy Policy to learn moreabout other personal information we may collect.
If we need to collect personal information about youor your children beyond the above-mentioned scope of collection, wewill notify you again and obtain your consent.
Please understand that you maychoose whether to fill in or provide us with certain information of yourchildren, but if you do not fill in or provide certain information, it maycause our products or services to fail to function properly or to achieve thedesired service effect, and you and your children may not be able tonormally use our products or services or related specific business functions.
II. How Do We Use theInformation?
We will, in strict accordance with laws andregulations and the agreements concluded with users, use the informationcollected from you and your children for the following purposes:
a) To provide necessary products or services or thespecific functions thereof; and
b) To optimize products or services, provide securityassurance, or conduct service survey.
If we need to use personal information about you oryour children beyond the above-mentioned purposes, we will notify youagain and obtain your consent.
III. Sharing, Transfer, andDisclosure of Children's Personal Information
We strictly restrict the sharing, transfer, and disclosureof the personal information of children in accordance with laws andregulations. In general, we do not share children's personal information withany third party. We may share with third parties the personal information of achild only after obtaining the prior consent of their guardian.
a) Sharing with Guardians
We will share certain children's personalinformation (such as the children's user names, account numbers, and passwords,and transaction information for some of our products and services) withtheir guardians so that the guardians may access and manage relevant personalinformation.
b) Sharing with Third Parties
For the purpose of external processing only, we mayshare a child's personal information with third-party partners,including service providers, contractors, agents, and applicationdevelopers (e.g., communications service providers that send emails or pushnotifications on our behalf, and map service providers that provide uswith location services) (they may not be located in your jurisdiction) and havethem process such information for us in accordance with our statements andprivacy policies and relevant confidentiality and security policies.
If we entrust a third party with processing ofchildren's personal information, we will conduct security assessment on thethird party and the entrustment, and sign an entrustment agreement to requirethe third party to process such personal information within the scope of ourauthorization. The children's personal information is used by such third partymainly for the following purposes:
i. To provide our services to the children;
ii. To achieve the purposes as set forth in the"How Do We Use the Information" section hereof;
iii. To fulfill our obligations under the HH SmartPrivacy Policy and this Statementand exercise our rights thereunder; and
iv. To understand, maintain, and improve ourservices.
If we share your and your child's information withthe above-mentioned third parties, we will conduct security assessment andadopt encryption, anonymization, de-identification, and other measures toprotect the security of your and your children's information.
With the continuous development of our business, wemay engage in a merger, acquisition, asset transfer, or other transaction thatresults in the sharing of your and your children's personal information with athird party, in which case we will inform you by push notification,announcement, or other means, and continue to protect or require the newmanager to continue to protect your and your children's personal information inaccordance with applicable laws and regulations and the security standardsno less stringent than those required in this Statement.
We may anonymize the collected information ofchildren for the purpose of big data analysis, for example, generating a reportfor the services that you use.
c) Other Disclosures
In general, we prohibit the disclosure of children’spersonal information, but we may disclose children's personal information forthe following purposes:
i. To comply with applicable laws and regulations,legal proceedings, or requests from public institutions and governmentauthorities;
ii. To perform our terms of use and other agreements,policies, or standards, including investigating any potential violations;
iii. To protect the rights, privacy, security, orproperty of us and/or other users, including you; and
iv. To seek available detection, prevention, orremedial measures, limit potential damages payable by us, or resolve security,fraud, or technical issues.
IV. Storage of Children'sPersonal Information
We will take encryption and other technical measuresto store children's personal information to ensure information security. Wewill store children's personal information only for a period necessary tofulfill the purposes for which we collect and use such information. For moreinformation about how we store and protect children's personal information,please refer to the "Storage Location and Period of Information" and"Information Security" sections of the HH Smart Privacy Policy.
If our products or services cease operating, or thestorage period of your and your children's personal information expires asrequired by this Statement or the HH Smart Privacy Policy, we will notify you and yourchildren by means such as push notification, announcement, and email, anddelete or anonymize your and your children's personal information within areasonable period of time.
V. Management of Children'sPersonal Information
To make it easier for you and your children toaccess, correct, or delete relevant personal information while using ourproducts or services, we provide you with the corresponding operation settingsin the product design, and you also may provide your feedback or inquiriesthrough the contact information we provide. We will contact you in a timelymanner upon verifying your feedback. Please understand that during theverification process, we may require you to provide the children's personal informationsuch as account number, birth date, and contact information, so that we cancontinue to respond to your needs after completing authentication and verifyingthe issues.
a) Accessing Children's PersonalInformation
You and your children may view the personalinformation provided or generated by the child user in the use of our productsor services, including but not limited to user name, nickname, gender (ifapplicable), and voluntarily posted contents.
b) Correcting Children's PersonalInformation
When you and your children find errors in thechildren's personal information that we collect, use, and process, you maycorrect such personal information by choosing Me &rt; Personal Information &rt;Nickname/Time Zone, or by contacting us. We will take measures in a timelymanner to correct the errors after completing the authentication andverification.
c) Deleting Children's PersonalInformation
You and your children may request us to deletethe children's personal information that we collect, use, and process, and wewill take measures in a timely manner to delete such personal information aftercompleting the authentication and verification if:
i. we collect, store, use, transfer, or disclose thechild's personal information in violation of applicable laws and regulations orrelevant agreement with you;
ii. we collect, store, use, transfer, or disclose thechildren's personal information beyond the intended scope or necessary period;
iii. you withdraw your consent; or
iv. you or your children terminates the use ofour products or services by cancelling the user account.
For your request, we will perform authentication andverification, and take measures in a timely manner to delete relevant personalinformation after completing the authentication and verification. However,please note that if you and your child require us to delete the specificpersonal information of the child, it may cause the child user to be unable tocontinue to use our products and services or certain specific businessfunctions thereof. If you find that any personal information of yourchildren has been collected without your prior consent, please contact usimmediately, and we will endeavor to delete relevant information as soon aspossible.
Contact Us
If you have any questions about our practices or thisStatement, please contact us in the following ways:
Shenzhen Hengha Smart Electronics Co., Ltd.
Correspondence Address: 302-A16, Building 4, QidiXiexin, No. 333 Longfei Avenue, Huanggekeng Community, Longcheng Street,Longgang District, Shenzhen City, Guangdong Province
Email: service@hihengha.com