Children's Privacy Protection Policy
Update Date: April 30,2024
Effective Date: April 30,2024
We are well aware of the importance of children's personal information and privacy security, and we appreciate your trust in us. We will take corresponding security protection measures as required by laws and regulations to protect the security and controllability of children's personal information. Based on this, Pipilong Enlightenment products and service providers Hangzhou Guangran Digital Technology Co., Ltd. (hereinafter referred to as "Guangran" or "we") have formulated this policy to explain to children and their guardians how we collect, use, store, share, transfer, and disclose children's personal information, as well as the rights of children and their guardians. We may update or modify this policy based on changes in the context of information handling. Please be aware of this policy and any supplementary policies before using any services provided by Guangran. This policy is a special policy formulated on the basis of the "Pipilong Enlightenment Privacy Policy" and is only applicable to products or services where we can identify users as children. For products or services that do not actively identify user age, do not identify user age, or require users to be at least 14 years old, the "Guangran Privacy Policy" or specific business privacy policies apply. In case of conflict between this policy and the "Guangran Privacy Policy", this policy shall prevail; for matters not covered by this policy, the "Guangran Privacy Policy" shall prevail. Unless otherwise agreed, the terms and abbreviations used in this policy have the same meaning as those in the "Pipilong Enlightenment User Agreement", "Pipilong Enlightenment Membership Service Agreement", and "Pipilong Enlightenment Privacy Policy". Special Instructions for Guardians: If you are a guardian of a child (parent or other guardian), please read this policy carefully and decide whether to agree to this policy. We hope that you will work with us to protect the personal information of children and educate and guide children to enhance their awareness and ability to protect personal information. Special Instructions for Children: If you are a child, you need to read this statement carefully with your guardian (parent or other guardian) and use our products, services, or provide us with information after obtaining the guardian's consent. Please have the guardian and child read and fully understand the "Pipilong Enlightenment Privacy Policy" and this policy, and then the guardian can choose whether to agree to the relevant privacy policies and whether to agree to the child using our products and services. If the guardian does not agree with the content of the relevant privacy policies and this statement or does not agree to provide the necessary information for the service, it may result in our products and services not functioning properly, or not achieving the service effects we intend to achieve, and the guardian and child may not be able to use our products, services, or related specific business functions normally. The guardian's click of "Agree" means that the guardian agrees to our collection, use, and processing of the guardian's and child's information in accordance with the "Pipilong Enlightenment Privacy Policy" and this policy. This privacy policy will help you understand the following content: What information we collect How we use this information How we share, transfer, and publicly disclose children's personal information How we protect children's personal information Correcting and deleting children's personal information How this privacy policy is updated How to contact us 1. What information we collect We strictly follow the provisions of laws and regulations and the agreement with users to collect the following personal information of guardians and children based on the specific situation of the products and services chosen by users. （1）When we need to configure protection measures for child users in accordance with laws and regulations and industry management requirements, we may prompt you to provide the guardian's mobile phone number, email address, or establish contact with us through "scan code verification" and other methods. In some products and services involving payment, we may require the guardian to fill in and bind the guardian's bank card-related information to keep the guardian informed of and manage the child's payment behavior. （2）In the process of children using products and services, we will require you to provide necessary information. For details, please refer to the "How We Collect and Use Your User Information" section of the "Guangran Privacy Policy". （3）If we need to collect other personal information of guardians or children, we will inform the guardian and child again and obtain the guardian's consent. Guardians can choose whether to fill in or provide specific information to us. Please understand that if guardians do not fill in or provide certain specific information, it may cause our products and services to not function properly, or not achieve the service effects we intend to provide, and guardians and children may not be able to use our products, services, or related specific business functions normally. 2. How we use this information We strictly follow the provisions of laws and regulations and the agreement with users to use the collected information of guardians and children for the following purposes: （1）Verify the identity of children and guardians （2）Provide necessary products and services, and specific functions of products and services （3）Used for optimizing products and services, and security protection If we need to use the personal information of guardians or children beyond the above purposes, we will inform the guardian and child again and obtain the guardian's consent. 3. How we share, transfer, and publicly disclose children's personal information Sharing We do not share children's personal information with any company, organization, or individual other than us and our affiliates, except in the following situations: （1）With the prior explicit consent or authorization of the guardian; （2）As required by laws and regulations, legal procedures, mandatory administrative or judicial requirements; （3）In accordance with the relevant agreements signed with the guardian and child (including online electronic agreements and corresponding platform rules) or other legal documents; （4）We may share children's personal information with our affiliates. However, we will only share necessary children's personal information and are subject to the purposes declared in this privacy policy. If our affiliates want to change the purpose of processing children's personal information, they will seek the guardian's authorization and consent again; （5）At the guardian's request to handle disputes or controversies with others; （6）Sharing with authorized partners: Within the scope allowed by laws and regulations, to protect the interests, property, or safety of Guangran, Guangran's partners, you, or other Guangran users, or the public from damage, we only provide certain services in conjunction with authorized contract partners. We may share some children's personal information with partners to provide better customer service and user experience. We will only share children's personal information for legitimate, proper, necessary, specific, and clear purposes, and will only share the personal information necessary to provide services. Our partners will not have the right to use the shared children's personal information for any other purposes. For companies, organizations, and individuals with whom we share children's personal information, we will sign strict confidentiality agreements with them, requiring them to handle children's personal information according to our instructions, this privacy policy, and any other relevant confidentiality and security measures. Transfer We will not transfer children's personal information to any company, organization, or individual, except in the following situations: （1）With the prior explicit consent or authorization of the guardian; （2）As required by laws and regulations, legal procedures, mandatory administrative or judicial requirements; （3）In accordance with the relevant agreements signed with the guardian and child (including online electronic agreements and corresponding platform rules) or other legal documents; （4）In the event of a merger, acquisition, asset transfer, or similar transactions, if the transfer of children's personal information is involved, we will require the new company or organization holding children's personal information to continue to be bound by this privacy policy; otherwise, we will require the company or organization to seek the guardian's authorization and consent again. Public Disclosure We will only publicly disclose children's personal information under the following circumstances and take security protection measures that meet industry standards: （1）At the guardian's or child's request, disclose the child's personal information specified by the guardian in the disclosure method explicitly agreed to by the guardian; （2）As required by laws and regulations, mandatory administrative or judicial requirements, we may disclose children's personal information based on the type and method of children's personal information requested. In accordance with laws and regulations, when we receive requests for disclosure of information, we will require the recipient to provide corresponding legal documents, such as subpoenas or investigation letters. We carefully review all requests to ensure they have a legal basis and are limited to the specific purposes and data that law enforcement agencies are entitled to obtain for specific investigations. Exceptions to obtaining prior consent for sharing, transferring, and publicly disclosing children's personal information The following circumstances do not require prior consent from the guardian for sharing, transferring, and publicly disclosing children's information: （1）Related to the performance of legal obligations by the personal information controller; （2）Directly related to national security or defense security; （3）Directly related to public safety, public health, or significant public interests; （4）Directly related to criminal investigation, prosecution, trial, and execution of judgments; （5）To protect the life, property, or other significant legal rights and interests of children or others, but it is difficult to obtain their consent; （6）Personal information that children or guardians have disclosed to the public; （7）Collecting children's personal information from legally disclosed information, such as legitimate news reports, government information disclosure, etc. According to the law, sharing, transferring, or disclosing de-identified personal information, and ensuring that the data recipient cannot re-identify the information subject, does not constitute sharing, transferring, or publicly disclosing children's personal information. The storage and processing of such data will not require separate notification and consent from the guardian 5. Authorized Processing Our authorized partners include the following types: （1）Suppliers of goods or technical services. We may entrust some of your personal information to third parties that support our functions. These supports include providing payment services and data processing for us. The purpose of sharing this information is to achieve the core functions of our products and/or services; （2）Third-party merchants. We must entrust the necessary information to third-party merchants to complete subsequent services, and provide the necessary address and personal information to third-party logistics merchants when involving physical goods mailing. The third-party logistics merchants provide mailing services under our supervision, and the control of personal information still belongs to us. 6. Third-Party SDK Integration To ensure the implementation of product/ service functions and the secure and stable operation of applications, we may integrate software development kits (SDKs) provided by third parties for the aforementioned purposes. We conduct strict security monitoring of the SDKs obtained from our cooperation partners to protect data security. 7. How We Protect Children's Personal Information We will take technical measures such as encryption to store children's personal information, ensuring its security. We will take reasonable and feasible measures to avoid collecting and processing irrelevant personal information as much as possible. We will only retain children's personal information for the period necessary to achieve the purposes stated in this policy, unless there are mandatory retention requirements by law. After the retention period expires, we will delete children's personal information or anonymize it according to the requirements of applicable laws. Although we have taken the aforementioned effective measures and complied with the standards required by relevant laws and regulations, please understand that due to technical limitations and possible various malicious means, in the internet industry, even if we do our best to strengthen security measures, it is impossible to always guarantee 100% security of information. We will strive to ensure the security of the personal information provided to us by children. You are aware and understand that the systems and communication networks used by children to access our services may have issues beyond our control. Therefore, we strongly recommend that guardians and children take active measures to protect the security of children's personal information, including but not limited to using complex passwords, regularly changing passwords, and not disclosing children's personal information such as account passwords to others. We will notify the relevant regulatory authorities in a timely manner in the event of a children's personal data leak and, in some special environments, notify the data subjects of the data breach to meet applicable laws, including the data protection regulations of the guardians and children's locations. We are not responsible for the legality of privacy policies of third-party websites that may be accessed, and guardians and children should check the privacy policies of third-party websites and determine whether to accept them. In the unfortunate event of a children's personal information security incident, we will notify guardians and children of the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for guardians and children to prevent or reduce risks on their own, and remedial measures as required by laws and regulations. We will inform guardians and children of the relevant situation of the incident by email, letter, phone, push notification, and other means. If it is difficult to notify each data subject individually, we will take reasonable and effective ways to publish announcements. At the same time, we will also report the handling situation of children's personal information security incidents to the regulatory authorities as required by the regulatory authorities. 5. Correcting and Deleting Children's Personal Information During the use of Guangran's products and services by children, in order to facilitate guardians and children to access, correct, and delete relevant personal information, we have provided corresponding operation settings for guardians in the product design, and guardians can also feedback and consult relevant information through the contact information we provide. We will contact guardians in a timely manner after verifying the problems feedback by guardians. Please understand that during the verification process, we may need guardians to provide children's account, children's identity information, contact information, and other personal information to continue to respond to guardians' needs after completing identity verification and problem verification. Access to Children's Personal Information Guardians and children can view the personal information provided or generated by children when using our products and services, including but not limited to usernames, passwords, avatars, nicknames, gender, and content actively published. Correcting Children's Personal Information When guardians and children find that the children's personal information we collect, use, and process is incorrect, they can contact us for correction. We will take timely measures to correct it after completing identity verification and problem verification. Deleting Children's Personal Information If the following situations exist, guardians and children can contact us to delete the collected, used, and processed children's personal information. We will take timely measures to delete it after completing identity verification and problem verification: （1）If we violate laws and regulations or the agreement between both parties in collecting, storing, using, transferring, or disclosing children's personal information; （2）If we exceed the scope of purpose or necessary period in collecting, storing, using, transferring, or disclosing children's personal information; （3）If the guardian withdraws consent; （4）If the guardian or child terminates the use of the product or service through account cancellation or other means. However, please note that if guardians and children request us to delete specific children's personal information, it may result in the child being unable to continue using our products and services or some specific business functions of the products and services. If guardians find that we have collected children's personal information without obtaining prior consent from the guardian, please contact us in a timely manner, and we will take measures to delete the relevant data as soon as possible. 6. How This Privacy Policy Is Updated Our privacy policy may be changed. This policy is an important part of the "Pipilong Enlightenment User Agreement" and the "Pipilong Enlightenment Privacy Policy". We reserve the right to update or modify this policy from time to time. If such modifications result in a substantial reduction of rights of children under this policy (i.e., "significant changes"), we will send change notifications to guardians and children through various channels, including but not limited to website announcements and private message notifications. If the guardian does not agree with the modified privacy policy, they have the right to immediately stop using Guangran's services. If the child continues to use our services, it is considered that the guardian has fully read, understood, and accepted the modifications we have made to the relevant terms of this policy. 7. How to Contact Us If you have any questions about the content of this policy or privacy-related matters when using our products and/or services, you can contact us by sending an email to jiangwenyi@holoflow.cn. We will reply to you as soon as possible within 15 working days after receiving your opinions and suggestions and verifying your user identity.