SimulLink Privacy Policy
Special Notice: This SimulLink Privacy Policy (hereinafter referred to as "this Policy") only applies to Shenzhen Sensei Technology Co., Ltd. (hereinafter referred to as "Sensei Tech" or "we") products and services. Before using this software, please read this Policy carefully to ensure you fully understand and accept all terms. Otherwise, please do not register, log in, or use our services. Important content regarding personal sensitive information and your personal data rights has been highlighted in bold for your special attention. If you are a minor under 18, please read and fully understand this Policy under the guidance of your guardian and obtain their consent before using Sensei Tech products and services. Our company is committed to protecting the privacy of children under fourteen (hereinafter referred to as "Children"), as detailed in the Children's Privacy Protection Agreement at the end of this document.
This policy will help you understand:
- I. Definitions and Interpretation
- II. How We Collect and Use Your Personal Data
- III. How We Use Cookies
- IV. How We Share, Transfer, and Disclose Your Personal Data
- V. How We Protect and Store Your Personal Data
- VI. How You Can Manage Your Personal Data
- VII. Protection of Minors' Personal Information
- VIII. Notifications and Revisions
- IX. How to Contact Us
- X. Children's Privacy Protection Agreement
I. Definitions and Interpretation
1. Sensei Tech Products and Services: Include the SimulLink App (hereinafter referred to as "this Software").
2. Translation Services: Refers to the translation and other services provided by Shenzhen Sensei Technology Co., Ltd., the operator of Sensei Tech, hereinafter referred to as "this Service".
3. Shenzhen Sensei Technology Co., Ltd.: The operator of Sensei Tech, a high-tech company specializing in artificial intelligence, software and hardware services to solve cross-language communication barriers. Registered address: 201, Building B6, Third Industrial Zone, Fenghuanggang Community, Xixiang Street, Bao'an District, Shenzhen. Contact telephone: 0755-23204570; For more detailed information about our company and platform, you can contact us using the methods provided in Section IX of this Policy.
4. User: Refers to any individual who registers, logs in, or uses this software by enabling, browsing, or uploading data to Sensei Tech, hereinafter referred to as "You" in this Policy.
5. Account: Refers to the user account you obtain after completing real information registration. You are responsible for maintaining the confidentiality of this account; You shall be legally responsible for all activities conducted under your account.
6. Personal Data: Personal data refers to any information recorded electronically or otherwise that can identify a natural person individually or in combination with other information, including but not limited to name, date of birth, identity document number, personal biometric information, address, and telephone number. For avoidance of doubt, personal data includes but is not limited to personal sensitive information.
7. Personal Sensitive Information: Personal sensitive information refers to personal data that, if leaked, illegally provided, or misused, may endanger personal and property safety, and is highly likely to cause damage to personal reputation, physical and mental health, or discriminatory treatment. Personal sensitive information includes but is not limited to identity document numbers, personal biometric information, bank account numbers, communication content, and health physiological information.
8. Personal Data Subject: Refers to the natural person identified by personal data.
9. De-identification: Refers to the technical processing of personal data so that the personal data subject cannot be identified without additional information.
10. Anonymization: Refers to the technical processing of personal data that makes the personal data subject unidentifiable, and the processed information cannot be restored.
11. Device: Refers to equipment that can be used to access Sensei Tech, such as desktop computers, laptops, tablets, or smartphones.
12. Unique Device Identifier: A unique device identifier (exclusive ID or UUID) is a string of characters programmed into the device by the manufacturer that can uniquely identify the device. Unique device identifiers have multiple purposes, including providing advertisements when cookies cannot be used. We identify devices or applications through information such as device startup time, system version, device model, physical memory, hard disk capacity, system update time, carrier, time zone, country, language, IP address, OAID, and advertising identifiers (such as IDFA).
13. IP Address: Each device connected to the internet is assigned a number called an Internet Protocol (IP) address. These numbers are usually assigned based on geographical regions. IP addresses can usually be used to identify the location of the device when connected to the internet.
14. SSL: SSL (Secure Socket Layer), also known as secure socket layer, is a security protocol implemented on the Transport Communication Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which achieve information confidentiality through the use of public key and symmetric key technology.
15. Information Collection Technologies: "Automatic collection" mentioned in this Policy by Sensei Tech includes the following methods:
- (1) Cookie: A cookie is a small text file placed on the client (your computer, mobile phone, or other smart terminal) by a website server when you browse a webpage, which can be used to improve your experience.
- (2) Log files: Log files store automatically collected data. This data includes Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
- (3) ET Tag (Entity Tag): An ET Tag is an HTTP protocol header transmitted behind the scenes between internet browsers and internet servers, which can replace cookies to track individual users, enabling us to better understand and improve our services.
16. The laws, regulations, and administrative rules applicable to this Policy are all laws, regulations, and administrative rules of the People's Republic of China.
II. How We Collect and Use Your Personal Data
You understand and agree that:
- 1. We will use the collected personal data according to the provisions of this Privacy Policy to achieve our product and service functions.
- 2. After collecting your personal data, we will de-identify the data through technical means. De-identified information cannot identify the subject. Please understand and agree that in this case, we have the right to use the de-identified information and analyze the user database for commercial purposes without disclosing your personal data.
- 3. Please note that all personal data you provide while using our products and/or services will continue to be authorized for our use during your use of our products and/or services unless you delete it or refuse collection through system settings. When you cancel your account, we will stop using and delete your personal data.
- 4. We may conduct statistics on the use of our products and/or services and may share these statistical results with the public or third parties to demonstrate the overall usage trends of our products and/or services. However, these statistical results do not contain any personally identifiable information.
- 5. When we display your personal data, we will desensitize your information using methods including content replacement and anonymization to protect your information security.
- 6. When we want to use your personal data for other purposes not described in this Policy, or use information collected for specific purposes for other purposes, we will seek your consent in advance by asking you to actively check a box.
When you use our products and/or services, we may need to collect and use your personal data in the following two ways:
- 1. To achieve the basic functions of providing you with our products and/or services, you must authorize us to collect and use necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally.
- 2. To achieve additional functions of our products and/or services, you can choose to authorize us to collect and use information. If you refuse to provide it, you may not be able to use the relevant additional functions or achieve the functional effects we have achieved, but it will not affect your normal use of the basic functions of our products and services.
Sensei Tech will only collect and use your personal data for the following purposes described in this Policy:
(A) Sensei Tech Account Registration
When you register for a Sensei Tech account, we collect the personal email address you filled in during registration and the account password you set to create your Sensei Tech account. After successful registration, your personal email address becomes your Sensei Tech account. You can log in to the SimulLink App by entering your account and password.
If you log in to the SimulLink App using WeChat, Google, or Facebook, we will collect your avatar, nickname, and email account. In this case, your WeChat, Google, or Facebook account becomes your Sensei Tech account. You can log in to Sensei Tech through the associated account. The success of the associated login depends on your relevant account being in the correct login status. If your account is not logged in or logged into another account, you can only log in using the bound personal email address.
For services that require logging into the SimulLink App account, we may verify your identity based on the information you provide to ensure that we are providing services to you.
(B) Translation Function
When using Sensei Tech's translation functions, including but not limited to Simultaneous Interpretation Mode, Touch Mode, and Speaker Mode. To better provide headphone connection, recording, translation, text-to-speech, speech-to-text and other related services, we will collect necessary user information according to the specific functions you use:
- 1. Location information. Used to intelligently allocate the most suitable server.
- 2. System default language. Used to match the App's default language and translation default language for you.
- 3. Information about other Bluetooth devices currently connected. Used to determine whether headphone functions can operate normally.
- 4. Custom translation information. Used to save professional terms, place names, fixed collocations, idioms and other information set by the user so that it can be synchronized through the user account after changing mobile phones.
- 5. Custom setting information. Used to save the headphone parameter information set by the user in specific functions so that it can be synchronized through the user account after changing mobile phones.
(C) Display and Purchase of Goods
1. Ordering and payment for virtual goods
Paid virtual goods in Sensei Tech, including but not limited to offline packages, require you to pay the corresponding amount of currency to place an order and complete payment before use. To achieve the ordering function for paid virtual goods, we need to obtain your Sensei Tech account. After placing an order, you can choose to use Sensei Tech account balance or payment services provided by third-party payment institutions cooperating with Sensei Tech (such as Google In-App Purchase and other non-balance payment methods, hereinafter referred to as "Google In-App Purchase"). The payment function only collects your Sensei Tech account, but we need to share your SimulLink order number and transaction amount with these payment institutions to confirm your payment instructions and complete the payment.
2. Order management function
To facilitate your understanding and query of order information and manage order information, we will collect order information generated during your use of our services to display to you and facilitate your order management.
(D) Customer Service Function
When you contact us or apply for after-sales service, dispute resolution, etc., to ensure the security of your account, we need you to provide necessary personal data to verify your user identity. When using the customer service system, if you need to provide feedback with photos, camera permission is also required.
To facilitate contact with you and help you solve problems as soon as possible or record the processing solutions and results of related problems, we may save your communication records and related content with us (including account information, order information, other information you provide to prove relevant facts, or contact information you leave). If you consult, complain, or make suggestions regarding a specific order, we will use your account information and order information.
For reasonable needs to provide services and improve service quality, we may also use your other information, including relevant information you provide when contacting customer service.
(E) Data Statistics Function
To provide better products and/or services and improve user experience, we will collect device attribute information (such as your hardware model, operating system version, device configuration, unique device identifier, International Mobile Equipment Identity IMEI, Media Access Control address MAC, advertising identifier IDFA, etc.), device connection information (browser type, telecom operator, language used), and device status information (such as device sensor data, device application installation list). For information collected from your various devices, we may associate them to provide you with consistent services across these devices.
(F) Ensuring Transaction Security
To improve the security of the services we and our affiliated companies and partners provide to you, protect the personal and property safety of you, other users or the public from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions and other security risks, and more accurately identify violations of laws and regulations or Sensei Tech's relevant agreement rules, we may use or integrate your account information, transaction information, device information, software usage records, click records, and information shared by our affiliated companies and partners with your authorization or according to law to comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures according to law.
The above services may require you to enable access to your unique device identifier, geographic location (position information), location (access approximate location), microphone, and phone storage on your device to achieve the collection and use of information involved in these functions. You can decide to enable or disable these permissions in your phone or device settings at any time.
Please note that enabling these permissions means you authorize us to collect and use this personal data to achieve the above functions. Disabling permissions means you cancel these authorizations, and we will no longer continue to collect and use your personal data and will not be able to provide you with the functions corresponding to these authorizations. Your decision to disable permissions will not affect the previous processing of personal data based on your authorization.
Please note that according to relevant national laws and regulations, Sensei Tech may collect and use your personal data without your authorization and consent in the following circumstances:
- 1. Directly related to national security and national defense security;
- 2. Directly related to public security, public health, and significant public interests;
- 3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
- 4. Necessary for protecting the life, property, and other significant legitimate rights and interests of you or other individuals but difficult to obtain your consent;
- 5. The personal data involved is publicly disclosed by you to the public;
- 6. Collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc.;
- 7. Necessary for maintaining the safe and stable operation of the provided products or services, such as discovering and handling failures of products or services;
- 8. Related to Sensei Tech's fulfillment of legal obligations stipulated by laws and regulations.
Please note that according to applicable laws, if we take technical measures and other necessary measures to process personal data so that the data recipient cannot re-identify specific individuals and cannot restore it, or if we may conduct de-identified research, statistical analysis, and prediction on collected information to improve Sensei Tech's content and layout, provide product or service support for business decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training), then the use of such processed data does not require separate notification and consent from you.
III. How We Use Cookies
We will not use Cookies for any purpose other than those stated in this Privacy Policy. You can manage or delete Cookies according to your preferences. You can also clear all Cookies saved in the software.
IV. How We Share, Transfer, and Disclose Your Personal Data
(A) Sharing
1. We will not share your personal data with any company, organization, or individual outside Sensei Tech and its partners, except in the following cases:
- (1) With your explicit consent or authorization in advance;
- (2) When necessary to comply with applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements;
- (3) Within the scope permitted by laws and regulations, to protect the rights, property, or safety of "Sensei Tech" or "Sensei Tech" partners, you or other Sensei Tech users, or the public from damage;
- (4) Only by sharing your information can we achieve the core functions of our products and/or services or provide the services you need;
- (5) To handle disputes or controversies between you and others at your request;
- (6) As provided in the relevant agreements signed with you (including electronically signed electronic agreements and corresponding rules) or other legal documents;
- (7) For academic research purposes;
- (8) For social public interests that comply with laws and regulations.
2. We may share your personal data with our affiliated companies, but we will only share necessary personal data and be bound by the purposes stated in this Privacy Policy. If our affiliates want to change the purpose of personal data processing, they will seek your authorization and consent again.
3. We may share your order information, account information, device information, and location information with third parties such as partners to ensure the smooth completion of services provided to you. However, we will only share your personal data for legitimate, proper, necessary, specific, and clear purposes, and will only share personal data necessary to provide services. Our partners have no right to use shared personal data for any other purpose.
Our partners include the following types:
Suppliers of goods or technical services. We may share your personal data with third parties that support our functions. This support includes providing us with infrastructure technical services, translation recognition services, payment services, data processing, etc. The purpose of our sharing this information is to achieve the core shopping functions of our products and services. For example, we need to share your order number and order amount with third-party payment institutions to confirm your payment instructions and complete payment. We will strictly monitor the security of the software development kits (SDKs) and application programming interfaces (APIs) used by our partners to obtain information to protect data security.
The currently integrated third-party SDKs are as follows:
| SDK Name | Application Scenario | Data Collected | Privacy Policy |
|---|---|---|---|
| WeChat SDK | Used to implement WeChat authorization login and sharing functions | Unique device identifier | View Policy |
| Apple SDK | Used to implement Apple ID authorization login | Unique device identifier | View Policy |
| Facebook SDK | Used to implement Facebook authorization login | Unique device identifier | View Policy |
| Google SDK | Used to implement Google authorization login | Unique device identifier | View Policy |
| iFlyTek SDK | Used for offline package download statistics | Unique device identifier | View Policy |
| ReadSpeaker SDK | Offline voice playback | Unique device identifier | View Policy |
| Tencent Bugly | Used to collect crash logs and exception data | Unique device identifier, Android ID | View Policy |
| Sensors Analytics SDK | To provide better products/services and improve user experience | Device information, Android ID, log information, location information, unique application number | View Policy |
| Guance Mobile SDK | Used to track abnormal service data and report logs | Device information, network information, application information, app permissions | View Policy |
| Tencent Browser SDK | Provides built-in browser for users to view instructions, official website, etc. | Device information, app information, Wi-Fi status and parameters, location information, nearby Wi-Fi, CellID | View Policy |
| Qiniu Cloud SDK | Upload operation logs | Manufacturer, model, system version, network type (e.g. Wi-Fi, 3G, 4G) | View Policy |
| Agora SDK | Provides real-time audio/video business functions | IP address, signal strength information, network type, user agent, Bluetooth enablement information | View Policy |
4. To comply with laws, execute or apply our terms of use and other agreements, or to protect the rights, property or safety of Sensei Tech, you, or other Sensei Tech users, such as to prevent fraud and other illegal activities and reduce credit risks, and exchange information with other companies and organizations. However, this does not include selling, renting, sharing or otherwise disclosing personal data in violation of the commitments in this Privacy Policy for profit purposes.
(B) Transfer
We will not transfer your personal data to any company, organization or individual, except in the following circumstances:
- 1. With your explicit consent or authorization in advance;
- 2. When necessary to comply with applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements;
- 3. As provided in the relevant agreements signed with you (including electronically signed electronic agreements and corresponding platform rules) or other legal documents;
- 4. In connection with mergers, acquisitions, asset transfers or similar transactions, if personal data transfer is involved, we will require the new company or organization holding your personal data to continue to be bound by this Privacy Policy, otherwise we will require such company or organization to seek your authorization and consent again.
(C) Public Disclosure
We will only publicly disclose your personal data in the following circumstances:
- 1. According to your needs, disclose the personal data you specify in the disclosure method you explicitly agree to.
- 2. When required by laws, regulations, mandatory administrative law enforcement or judicial requirements to provide your personal data, we may publicly disclose your personal data according to the required type of personal data and disclosure method. Within the scope permitted by laws and regulations, when we receive such disclosure requests, we will require the presentation of corresponding legal documents such as subpoenas or investigation letters. We firmly believe that the information requested should be as transparent as possible within the limits permitted by law. We carefully review all requests to ensure they have a legal basis and are limited to data that law enforcement agencies have the legal right to obtain for specific investigation purposes. With the permission of laws and regulations, the documents we disclose are protected by encryption keys.
(D) Exceptional Circumstances
In the following circumstances, sharing, transferring or publicly disclosing your personal data does not require prior authorization and consent:
- 1. Related to national security and national defense security;
- 2. Related to public security, public health, and significant public interests;
- 3. Related to criminal investigation, prosecution, trial and execution of judgments and other judicial or administrative law enforcement;
- 4. Necessary to protect the life, property and other significant legitimate rights and interests of you or others but difficult to obtain consent;
- 5. Personal data that you have disclosed to the public;
- 6. Collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
Please note that according to applicable laws, if we take technical measures and other necessary measures to process personal data so that the data recipient cannot re-identify specific individuals and cannot restore it, then such sharing, transfer or public disclosure of the processed data does not require separate notification and consent from you.
V. How We Protect and Store Your Personal Data
(A) Protection of Your Personal Data
1. We have used security protection measures that meet industry standards to protect the personal data you provide, preventing data from being accessed, publicly disclosed, used, modified, damaged or lost without authorization. We will take all reasonably feasible measures to protect your personal data. For example: We use https encryption to transmit your personal data, your data exchange (such as credit card information) between the browser and "service" is protected by SSL encryption, we use encryption technology to ensure data confidentiality, we use trusted protection mechanisms to prevent data from malicious attacks, and we deploy access control mechanisms to ensure that only authorized personnel can access personal data.
2. We will use various security protection measures at a reasonable security level to ensure information security. For example, we use encryption technology (e.g., TLS, SSL), anonymization processing and other means to protect your personal data. To prevent viruses, Trojan horses or other malicious programs and websites, we may detect whether there are security risks in the applications installed on your device, the running processes, or the information stored in the device memory; to prevent fraud, account theft, impersonation of others and other illegal activities and for security checks, we may analyze and use data such as unique device identifiers, login IP addresses, operation logs, etc., to take security measures or provide security prompts to users.
3. We have established specialized management systems, processes and organizations to ensure information security. For example, we strictly restrict the scope of personnel who access information, require them to comply with confidentiality obligations, and conduct reviews.
4. We will take all reasonably feasible measures to ensure that no irrelevant personal data is collected. We will only retain your personal data for the period required to achieve the purposes stated in this Policy, unless the retention period needs to be extended or is permitted by law.
5. In the unfortunate event of a personal data security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation of the security incident and possible impact, the measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, remedies for you, etc. We will promptly inform you of the relevant situation of the incident by email, letter, phone, push notification, etc. When it is difficult to inform each personal data subject, we will release announcements in a reasonable and effective manner. At the same time, we will also voluntarily report the disposal of personal data security incidents to regulatory authorities as required.
(B) Storage of Your Personal Data
1. If we terminate the service or operation, we will notify you in advance and delete or anonymize your personal data after the termination of service or operation.
2. We will store your personal data for the period stipulated by laws and regulations or for the shortest period necessary to achieve the purpose of Sensei Tech products and/or services.
VI. How You Can Manage Your Personal Data
(A) Access Your Personal Information
You have the right to query your information. You can do so yourself in the following ways:
- 1. Open SimulLink, click "Me" to access your account.
- 2. Open SimulLink, click "Me" to view virtual goods orders, recharge records, consumption records.
(B) Correct or Supplement Your Personal Information
When you find errors in the personal information we process about you, you have the right to request us to make corrections. You can contact customer service using the contact method described in this Policy for corresponding consultation and operation.
(C) Delete Your Personal Data
In the following circumstances, you can request us to delete personal data:
- 1. If our processing of personal data violates laws and regulations;
- 2. If we collect and use your personal data without your consent;
- 3. If our processing of personal data violates our agreement with you;
- 4. If you no longer use our products or services, or you cancel your account;
- 5. If we no longer provide you with products or services.
Please note that if you have publicly published information on Sensei Tech, any user who logs in to Sensei Tech will be able to read your information, or collect and use it. You can delete it yourself in the application. If you cannot delete your personal data from the community forum yourself, contact customer service using the contact method described in this Policy for corresponding consultation and operation. Sometimes, we may not be able to delete your personal data. In this case, we will inform you of this situation and its reasons.
If we decide to respond to your deletion request, we will also notify the entities that obtained your personal data from us to delete it in a timely manner, unless otherwise stipulated by laws and regulations, or these entities obtain your independent authorization. When you delete information from our service, we may not immediately delete the corresponding information from the backup system, but will delete it when the backup is updated.
(D) How to Cancel Your Account
If you need to cancel your account, please contact our online customer service or send an email to simulinterpret@netsiot.com. After receiving the email, we will process it within 5 to 10 working days.
Online customer service entry: Sidebar function selection - Contact Us - Online Customer Service
VII. Protection of Minors' Personal Information
1. We attach great importance to the protection of minors' personal information. If you are a minor under the age of 18, please read this Policy under the guidance of your parents or legal guardians and obtain their consent before using our products and/or services. We will protect minors' personal information in accordance with relevant national laws and regulations.
2. For the collection of minors' personal information with the consent of parents or legal guardians, we will only use or publicly disclose this information when permitted by law, with the explicit consent of parents or guardians, or when necessary to protect minors.
3. If we find that we have collected minors' personal information without obtaining verifiable parental or legal guardian consent in advance, we will try to delete the relevant data as soon as possible.
VIII. Notifications and Revisions
1. To provide you with better services and with the development of Sensei Tech's business, this Privacy Policy will also be updated. However, without your explicit consent, we will not reduce your rights under this Privacy Policy. We will release updated versions on Sensei Tech and remind you of relevant updates in other appropriate ways before they take effect. Please also visit Sensei Tech to keep up to date with the latest privacy policy.
2. For major changes, we will also provide more prominent notice (we will explain the specific changes to the privacy policy through methods including but not limited to email, SMS, or special prompts on browsing pages).
Major changes referred to in this Policy include but are not limited to:
- (1) Major changes in our service model. Such as the purpose of processing personal information, the types of personal information processed, the way personal information is used, etc.;
- (2) Changes in ownership due to business adjustments, bankruptcy, mergers and acquisitions, etc.;
- (3) The main objects of personal information sharing, transfer or public disclosure change;
- (4) Your rights and how to exercise them in terms of personal information processing change significantly.
IX. How to Contact Us
If you have any questions, comments or suggestions about this Privacy Policy or your personal information, please contact us by visiting the online customer service system, sending an email to simulinterpret@netsiot.com or calling our online customer service. We will reply to or handle the questions, comments or suggestions you raise in a timely manner.
X. Children's Privacy Protection Agreement
We recommend: Minors under fourteen (hereinafter referred to as "Children") should obtain guardian consent before participating in any online activities. If you are a Child, please notify your guardian to read this Agreement together, and seek your guardian's consent and guidance before using the service and submitting personal information. Your online consent to this Agreement, or your use/continued use of the company's services and submission of personal information, indicates that you have obtained your guardian's permission, and your guardian agrees that we collect, use, store, share, transfer and disclose your personal information in accordance with this Agreement (including updated versions).
In addition to the provisions of the Privacy Protection Agreement, our collection and processing of children's personal information will also comply with the following terms. If the following terms are inconsistent with the Privacy Protection Agreement, the provisions of the following terms shall prevail:
- 1. Children's guardians can take the initiative to contact us by calling the official customer service hotline or contacting customer service to exercise the rights granted to children's guardians by the following terms.
- 2. Before collecting, using, transferring, or disclosing children's personal information, we will notify the children's guardian in advance through the guardian's contact information left when registering the child's account, and will only collect, use, transfer, or disclose the child's information after obtaining their consent.
- 3. After receiving the above notice, the guardian may refuse. If the guardian refuses our collection, use, transfer, or disclosure of children's personal information in accordance with the Privacy Protection Agreement, we will not collect, use, transfer, or disclose the children's information. However, this may mean that the child cannot fully use some features of our product. If the children's personal information that the guardian refuses to use is the basic information necessary to run our product (location information, device identification code), the child will not be able to use our product at all.
- 4. Our staff's access to children's personal information shall be approved by the person in charge of children's personal information protection or their authorized management personnel, record the access situation, and take technical measures to avoid illegal copying and downloading of children's personal information.
- 5. The child's guardian exercises all rights granted to the child under the Privacy Protection Agreement on behalf of the child.
- 6. The child's guardian may withdraw the authorization for us to collect, use, transfer, or disclose the child's personal information, but this may mean that the child cannot fully use some features of our product. If the children's personal information for which the guardian withdraws authorization is the basic information necessary to run our product (location information, device identification code), the child will not be able to use our product at all.
- 7. If we transfer children's personal information to third parties, we will conduct a security assessment ourselves or entrust a third-party institution to do so.
- 8. If we stop operating the product or service, we will immediately stop collecting children's personal information, delete the children's personal information we hold, and promptly notify the children's guardian of the cessation of operations.
Effective Date of this Privacy Policy: October 26, 2024