Children's Privacy Protection Statement

This English version is provided for reference only. If there is any inconsistency between the English and Chinese versions, the Chinese version shall prevail.

Last Updated: November 22, 2023

Effective Date: November 22, 2023

Introduction

This Statement applies only to the product "Conbrie" of Wuxi Houlang Information Technology Co., Ltd. (hereinafter referred to as "we" or "us") and its related services. We are fully aware of the importance of protecting the security and privacy of the personal information of children (meaning minors under the age of fourteen, the same below). On the basis of the "Privacy Policy", we hope to explain, through the "Conbrie Children's Privacy Protection Statement" (hereinafter referred to as "this Policy"), the processing rules and other related matters applicable when we collect and use children's personal information. As the parent or other guardian of your child (hereinafter collectively referred to as the "Guardian"), before you or your child uses the products and services of Conbrie (as defined in the "Privacy Policy", hereinafter collectively referred to as "our products and services"), please be sure to read carefully and fully understand this Policy, and begin using, or allow your child to use, them only after confirming that you fully understand and agree to all of its terms.

If you have any questions, requests to exercise your rights, or other matters relating to personal information while reading this Statement, we provide a dedicated feedback channel for you; please refer to the "How to Contact Us" section of this Statement for details, and we will respond to you as soon as possible.

How We Collect and Use Children's Personal Information
How We Share, Transfer, and Publicly Disclose Children's Personal Information
How We Store Children's Personal Information
How We Protect Children's Personal Information
How We Manage Children's Personal Information
How This Policy Is Updated
How to Contact Us

1. How We Collect and Use Children's Personal Information

(1) We will strictly perform the obligations and responsibilities for the protection of children's personal information as prescribed by laws and regulations We follow the principles of legitimacy and necessity, informed consent, clear purpose, security assurance, and lawful use, and collect and use children's personal information only after obtaining the consent of the Guardian. Please note that in the vast majority of cases we are unable to identify, and will not determine, whether the personal information collected and processed is children's personal information; we will collect and process users' personal information in accordance with the "Privacy Policy".

In addition, we will also automatically collect personal information of the Guardian or the child through Cookies, SDKs, and similar technologies. For details, please refer to the sections "How We Use Cookies and Other Technologies" and "Third-Party SDK Statistical Services" in the "Privacy Policy". If we need to collect and use children's personal information beyond the above scope, we will obtain the Guardian's consent again.

(2) Exceptions to obtaining authorization and consent In accordance with relevant laws and regulations, the collection of children's information in the following circumstances does not require the authorization and consent of the child and/or the Guardian:

Where it is directly related to national security, national defense security, public security, public health, or major public interests;
Where it is directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
Where it is for the purpose of safeguarding the life, property, or other major lawful rights and interests of the information subject or other individuals, but it is difficult to obtain the consent of the Guardian;
Where the information collected has been disclosed to the public by the child or the Guardian on their own;
Where the information is collected from legally and publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels;
Where it is necessary for entering into a contract at the request of the Guardian;
Where it is necessary for maintaining the safe and stable operation of the services, such as detecting and handling service failures;
Where the information is automatically retained and processed through a computer information system and it cannot be identified that the retained and processed information is children's personal information;
Where it is necessary for conducting statistical or academic research in the public interest, and the information contained in the results is de-identified when the results of the academic research or description are provided externally;
Other circumstances prescribed by laws and regulations.

(1) Sharing We will not share children's personal information with any other company, organization, or individual without your consent, except in the following circumstances:

With the explicit consent or authorization of the Guardian: after obtaining the explicit authorization of the Guardian, we will share children's personal information with other parties.
Sharing under statutory circumstances: we must share your personal information externally in accordance with laws and regulations, the needs of litigation or dispute resolution, or the mandatory requirements of competent government authorities or judicial rulings.
To the extent required or permitted by law, where it is necessary to provide your personal information to third parties in order to protect the interests, property, or safety of Conbrie, its users, or the public from harm.

(2) Transfer We will not transfer children's personal information to any company, organization, or individual without the consent of the Guardian, except in the following circumstances:

With the explicit consent or authorization of the Guardian: after obtaining the explicit authorization of the Guardian, we will transfer children's personal information to other parties.
In the event of a merger, acquisition, or bankruptcy liquidation, a transfer of personal information may be involved. In such a case, we will require the new company or organization holding children's personal information to continue to be bound by this Policy. If there is any change to the methods of collecting and processing personal information as agreed in this Policy, such company or organization shall seek the authorization and consent of the Guardian again.

(3) Public Disclosure We will not publicly disclose children's personal information without the consent of you or the Guardian, except in the following circumstances:

With the explicit consent or authorization of the Guardian.
Based on laws, legal procedures, litigation, or the mandatory requirements of competent government authorities, we may disclose your personal information to competent authorities. However, we guarantee that, when the above circumstances occur, we will require the party requesting disclosure to issue the corresponding valid legal documents, and will take security protection measures that comply with laws and industry standards for the information disclosed.

3. How We Store Children's Personal Information

(1) Retention Period While the child uses this platform, we will continue to retain the child's personal information, and in principle the retention period shall not exceed the period necessary to provide services to the child. After the child stops using this platform or revokes the corresponding authorization, we will delete or anonymize your information, unless otherwise provided by laws and regulations regarding the retention period of specific information.

If we cease operations due to poor management or other reasons, we will immediately stop collecting children's personal information and delete the personal information already collected. We will announce such circumstances on the website or notify each user individually by in-app notifications, emails, or other reasonable means.

(2) Storage Location We store information obtained within the territory of the People's Republic of China within the territory of the People's Republic of China. If certain products or services involve cross-border activities and we need to transfer your personal information overseas, we will strictly comply with the provisions of laws and regulations and ensure the security of children's personal information.

4. How We Protect Children's Personal Information

We attach great importance to the privacy and security of children. We will strictly comply with relevant laws and regulations and adopt reasonable and practicable measures recognized in the industry to protect children's personal information, prevent the information from unauthorized access, disclosure, use, or modification, and avoid damage to or loss of the information.

(1) We will strictly control access to children's personal information We apply the principle of minimum necessary authorization to staff who may have access to children's personal information, and adopt technical measures to record and control the processing of children's personal information by staff, so as to prevent the illegal copying and downloading of children's personal information.

(2) We have formulated an emergency response plan for children's personal information security incidents We regularly organize emergency response training and drills for relevant internal personnel so that they master their job responsibilities as well as emergency response strategies and procedures. In the unfortunate event of a children's personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform the child and the Guardian of: the basic situation and possible impact of the security incident, the response measures we have taken or will take, suggestions for the child and the Guardian to independently prevent and reduce risks, remedial measures for the child and the Guardian, and so on.

If we discover that children's personal information has been or may be leaked, damaged, or lost, we will immediately activate the emergency response plan, take remedial measures, and inform the affected Guardians and children of the relevant circumstances of the incident by email, telephone, push notification, announcement, or other means.

If you wish to learn more, please refer to "5. How We Protect Your Personal Information" in the "Privacy Policy" to understand how we store and protect children's personal information.

5. How We Manage Children's Personal Information

In order to enable you to access and manage children's personal information more conveniently while using our products and services, and to safeguard the right to cancel accounts, we provide corresponding settings in the client for the Guardian and the child, who may operate in accordance with the guidance in the section "Your Rights to Manage Personal Information" of the "Privacy Policy".

In the following circumstances, the Guardian and the child may contact us through the channels listed in "How to Contact Us" of the "Privacy Policy" to request the deletion of the corresponding children's personal information:

Where we collect, store, use, or provide children's personal information externally in violation of laws or administrative regulations or the agreement between the parties;
Where we collect, store, use, or provide children's personal information externally beyond the scope of the purpose or the necessary period;
Where the Guardian withdraws consent;
Where the Guardian or the child terminates the use of the products or services by means such as account cancellation.

6. How This Policy Is Updated

As this Children's Privacy Protection Statement may be updated from time to time, the Guardian should review it regularly to understand our plans and procedures for protecting the personal information we collect. Your continued use of the Conbrie services constitutes your consent to this Privacy Policy and any updated version thereof.

For material changes, depending on the specific circumstances, we may also provide a more prominent notice explaining the specific changes to this Policy. Material changes include but are not limited to:

Significant changes in our service model, such as the purpose of processing personal information, the types of personal information processed, and the manner in which personal information is used;
Significant changes in our ownership structure, organizational structure, etc., such as changes of ownership caused by business adjustments, bankruptcy, mergers and acquisitions, etc.;
Changes in the main recipients of personal information sharing, transfer, or public disclosure;
Significant changes in your rights to participate in the processing of personal information and the manner in which they are exercised;
Changes in the department responsible for personal information security, its contact information, or complaint channels;
When a personal information security impact assessment report indicates a high risk.

7. How to Contact Us

If you or your Guardian have any questions, comments, or suggestions regarding this Privacy Policy, please contact us through the following means:

Submit feedback within the Conbrie app Send an email to conbrie@163.com