New Wanaka Limited and its
affiliated companies (hereinafter referred to as "we") respect and
protect the privacy rights of users of The ONE Smart Piano Classroom. When you use the services we
provide, we may collect and use your relevant information. Through this Privacy
Policy ("this Policy"), we aim to explain how we collect, store,
protect, and use your personal information, and clearly outline our approach to
handling your personal data.
We remind you that this Privacy
Policy is closely related to your use of our services. Therefore, we strongly
recommend that you carefully read and understand this policy before using
any services provided through our platform website and/or by logging into the
relevant client applications (collectively referred to as the
"Platform"). Please use our services only
after confirming your full understanding and agreement. Your use of our
products or services shall be deemed as your acceptance and acknowledgment of
the contents of this policy. If you do not agree to the terms of this policy,
it may affect the effectiveness of providing you with the corresponding
products and/or services.
It should be specifically noted that
this policy does not apply to services provided to you by other independent
third parties. For example, when third parties on our platform provide services
to you through our platform, the personal information you provide to such third
parties is not covered by this policy. We assume no responsibility for any use
of the information you provide by any third party.
This policy will help you understand
the following:
1. How we collect and use your personal information
2. How we use cookies and similar technologies
3. How we share, transfer, and publicly disclose your personal information
4. How we protect your personal information
5. Your rights
6. How we handle children's personal information
7. How your personal information is transferred globally
8. How this policy is updated
9.
How to contact us
We fully understand the importance
of your personal information and will make every effort to ensure its security
and reliability. We are committed to maintaining your trust by adhering to the
following principles in protecting your personal information: the principle of
consistency between rights and responsibilities, the principle of purpose
limitation, the principle of choice and consent, the principle of data
minimization, the principle of security assurance, the principle of user
participation, and the principle of transparency. Furthermore, we pledge to
implement appropriate security measures in accordance with established industry
standards to safeguard your personal information. Please carefully read and
understand this policy before using our services.
1. How We Collect and Use Your Personal
Information
1.1. Personal information refers to any information recorded electronically or otherwise that can identify a specific natural person either alone or in combination with other information, or reflects the activities of a specific natural person. This does not include information that has been anonymized.
1.2. We
collect and use your information for the following purposes:
(1) To provide, maintain, and improve our products or services for you.
(2) To send you important notifications.
(3) To activate or verify products or services.
(4) To promote or introduce products to you within the scope permitted by laws
and regulations.
(5) For other purposes with your consent.
Before accepting services, we will
display the information you need to submit on our platform pages. The information displayed on the platform pages shall
prevail. If you do not use certain services, you are not required to
provide the relevant information.
1.3 We will only collect and use
your personal information for the following purposes described in this policy:
(1) Piano Lessons. To ensure you can
complete The ONE Smart Piano Classroom's sessions smoothly, you need to
check before class whether your device's network, Bluetooth functionality (for
Bluetooth piano connection scenarios), and USB functionality (for USB cable
piano connection scenarios) are working properly. When using these features,
you must grant your device permission to access Bluetooth functionality (for
Bluetooth piano connection scenarios. Note: On Android 6.0 and later, Bluetooth
and location permissions are combined. Enabling Bluetooth also activates
location permissions. When you enable Bluetooth, location information is
accessed solely for searching nearby Bluetooth devices. We will not collect
your location information for any other purpose.) / USB functionality access
(for USB-connected piano scenarios). By enabling these features, we provide you
with the full piano lesson service. You authorize us to collect and use the
corresponding personal information to fulfill the aforementioned functions, by enabling these permissions. You
may disable these access permissions at any time within your device settings.
Disabling permissions constitutes revocation of authorization, after which we
will cease collecting and using your personal information for these purposes
and will be unable to provide the corresponding functions. Should you wish to
continue using these functions, you must re-enable the access permissions. Your
decision to disable permissions will not affect the processing of personal
information previously conducted based on your authorization. The
aforementioned location information constitutes sensitive data. You may choose
to grant or revoke location system permissions within your mobile operating
system. Disagreeing or revoking authorization may render location-related
features inaccessible, but will not impact your use of other functionalities.
We will not disclose the aforementioned information externally unless you
voluntarily choose or consent to such disclosure, or unless required by
applicable laws and regulations.
(2) Optimizing user experience. With
your prior consent, we may collect your information or obtain system
permissions for the purposes of analyzing your use of our products and/or
services, optimizing network quality in different regions, and improving advertising
effectiveness. This includes:
a) Device or software information,
including configuration details provided by your mobile device, web browser, or
other programs used to access our products and/or services, as well as relevant
information such as the version of your mobile device and device identifiers
(IP address, Wi-Fi access points capable of providing relevant information,
Bluetooth, etc.); b) Information searched or browsed while using our products
and/or services, including web search terms you use, URL addresses of social
media pages you visit, and other information and content details you browse or
request while using our products and/or services;
(3) To provide you with more
professional and secure basic and additional business functions, we integrate
third-party software development kits (SDKs) for technical reasons. SDK
technical service providers will obtain necessary permissions and information
to provide the corresponding functions or services. Please carefully review the
SDK list below to understand the specific SDK names we integrate, their
respective SDK technical service providers,
application scenarios (i.e., SDK types), and the permissions and
personal information types each SDK obtains. We have conducted security
monitoring on all SDKs integrated into this software to protect your personal
information security. By clicking to agree to this policy, you simultaneously
authorize and consent to the SDK technical service providers obtaining and
processing your permissions and information as outlined in the table below. You
may view the third parties' data usage and protection rules via the relevant
links. Please note that the types of personal information processed by
third-party SDKs may change due to version upgrades, policy adjustments, or
other reasons. Please refer to their officially published statements for the
most accurate information.
(4) Anonymization of Personal
Information: After collecting your personal information, we will promptly
anonymize the data through technical means. We will store anonymized data
separately from information that can be used to re-identify individuals and ensure
that individuals are not re-identified in subsequent personal information
processing. Without disclosing your personal information, we reserve the right
to mine, analyze, and utilize (including for commercial purposes) the
anonymized user database. Should we use your personal information for purposes
or within a scope not specified in this policy, or employ transmission methods
inconsistent with the data collection purpose, we will notify you and obtain
your consent.
Additionally, in accordance with
relevant laws, regulations, and national standards, we may collect and use your
relevant personal information without seeking your authorization or consent
under any of the following circumstances:
(1) Necessary for the conclusion or
performance of a contract to which you are a party;
(2) Necessary for the performance of
statutory duties or legal obligations;
(3) Necessary to respond to public
health emergencies or protect the life, health, and property safety of
individuals in urgent situations;
(4) Where the personal information
controller is a news organization lawfully conducting news reporting, public
oversight, or similar activities in the public interest, processing personal
information within reasonable limits;
(5) Processing personal information
voluntarily disclosed by individuals or otherwise lawfully made public within
reasonable limits as prescribed by national laws;
(6) Other circumstances stipulated
by laws and administrative regulations.
Please understand that the features
and services we provide to you are continuously updated and developed. If a
feature or service not covered in the foregoing description collects your
information, we will separately explain the content, scope, and purpose of the
information collection to you through page prompts, interactive processes,
website announcements, or other means to obtain your consent.
2. How We Use Cookies and Similar
Technologies
2.1 To ensure the proper functioning
of our website, we store small data files called cookies on your computer or
mobile device. Cookies typically contain an identifier, the site name, and some
numbers and characters. Cookies allow websites
to store
data such as your preferences or items in your shopping cart.
2.2 We do not use cookies for any
purpose beyond those described in this policy. You may manage or delete cookies
according to your preferences. You can clear all cookies saved on your
computer, and most web browsers offer the option to block cookies. However, if
you do so, you will need to manually adjust your user settings each time you
visit our website.
2.3 In addition to cookies, we use
other similar technologies on our website, such as web beacons and pixel tags.
For example, emails we send to you may contain clickable URLs linking to
content on our website. If you click such a
link, we track the click. This helps us understand your preferences and improve
customer service.
Web beacons are typically transparent images embedded in websites or emails.
Pixel tags in emails allow us to determine whether an email has been opened. If
you do not wish your activities to be tracked in this manner, you may
unsubscribe from our mailing list at any time.
2.4 Many web browsers include a Do
Not Track feature that sends a Do Not Track request to websites. Currently,
major internet standards organizations have not established policies requiring
websites to respond to such requests. However, if your browser has Do Not Track
enabled, all our websites will respect your choice.
3. How We Share, Transfer, and Disclose
Your Personal Information
3.1 Share
We will not share your personal
information with any companies, organizations, or individuals outside our
organization, except in the following circumstances:
(1) Sharing with explicit consent:
We will share your personal information with other parties only after obtaining
your explicit consent;
(2) We may share your personal
information externally as required by laws and regulations or in compliance
with mandatory requests from government authorities.
(3) Sharing with Affiliated
Companies: Your personal information may be shared with our affiliated
companies. We will only share necessary personal information, and such sharing
is subject to the purposes stated in this Privacy Policy. Should an affiliated
company wish to change the purpose of processing your personal information, it
will seek your authorization and consent again.
Our affiliates refer to any company
or legal entity that is now or in the future controlled by, under the control
of, or under common control with us. "Control" means the power to
determine the financial and operational policies of a company, directly or
indirectly holding more than 50% of the management or decision-making rights in
that company, and thereby deriving benefits from its business activities.
(4) Sharing with Authorized
Partners: To fulfill the purposes stated in this Policy, certain services may
be provided by authorized partners. We may share some of your personal
information with these partners to deliver better customer service and user experience.
We will only share your personal information for legitimate, reasonable,
necessary, specific, and clearly defined purposes, and only the information
necessary to provide the service. Our partners are prohibited from using shared
personal information for any other purposes.
For companies, organizations, and
individuals with whom we share user information, we enter into strict
information protection agreements, requiring them to process user information
in accordance with our instructions, this Privacy Policy, and any other relevant
confidentiality and security measures.
3.2 Transfer
We will not transfer your personal
information to any company, organization, or individual except in the following
circumstances:
(1) Transfer with explicit consent:
We will transfer your personal information to other parties after obtaining
your explicit consent;
(2) Transfer in Mergers,
Acquisitions, Asset Transfers, or Bankruptcy Liquidation: If personal
information transfer occurs during such transactions, we will notify you of the
relevant circumstances and continue protecting your personal information in accordance
with laws and regulations, or require the new controller to do so at least to
the standards required by this policy. Otherwise, we will require the company
or organization to obtain your authorization and consent again.
3.3 Public Disclosure
We will only publicly disclose your
personal information under the following circumstances:
(1) After obtaining your explicit
consent;
(2) Disclosure based on legal
requirements: We may publicly disclose your personal information when required
by law, legal proceedings, litigation, or mandatory requests from government
authorities.
3.4 Exceptions to Prior
Authorization for Sharing, Transferring, or Publicly Disclosing User
Information
The following scenarios exempt us
from obtaining your prior authorization for sharing, transferring, or publicly
disclosing your user information:
(1) Matters related to national
security or defense security;
(2) Matters related to public
safety, public health, or significant public interests;
(3) Matters related to criminal
investigation, prosecution, trial, and enforcement of judgments;
(4) Situations where it is necessary
to protect your or another individual's vital legal rights and interests (such
as life or property) but obtaining your consent is impractical;
(5) Personal information you have
voluntarily disclosed to the public;
(6) Personal information collected
from legally disclosed sources, such as legitimate news reports or government
information disclosure channels. How
We Use Cookies and Similar Technologies
4. How We Protect Your Personal
Information
4.1 We take the security of your
information seriously. We strive to implement various reasonable physical,
electronic, and administrative security measures to protect your user
information. This prevents unauthorized access, public disclosure, use, modification,
damage, or loss of user information. We employ encryption technology to enhance
the security of user information; utilize trusted protection mechanisms to
prevent malicious attacks on user information; deploy access control mechanisms
to ensure only authorized personnel can access user information; and conduct
security and privacy protection training courses to strengthen employees'
awareness of the importance of protecting user information.
We have established dedicated
management systems, processes, and organizational structures to safeguard
information security.
In the event of a security incident
such as a personal information leak, we will activate emergency response plans
to prevent the incident from escalating and notify you via push notifications,
announcements, or other appropriate means.
We will make every effort to protect
your personal information. We also ask for your understanding that there are no foolproof security measures to protect information.
4.2 We will take all reasonable and
feasible measures to ensure that irrelevant personal information is not
collected.
Information Retention Period: We
will retain your personal information only for the period necessary to fulfill
the purposes stated in this policy, unless law requires or permits a longer
retention period. After the aforementioned retention period expires, we will
delete or anonymize your personal information.
However, we may alter the storage
period of personal information to comply with legal requirements under the
following circumstances:
· To comply with applicable laws,
regulations, and other relevant provisions;
· To comply with court judgments,
rulings, or other legal proceedings;
· To comply with requests from
relevant government agencies or legally authorized organizations;
· Where we reasonably believe
compliance with laws, regulations, or other relevant provisions is necessary;
· To enforce relevant service
agreements or this Statement, protect public interests, safeguard the personal
and property safety or other legitimate rights and interests of our customers,
us, our affiliates, other users, or employees, or for other reasonable and
necessary purposes.
When our products or services cease
operations, we will notify you via push notifications, announcements, or
similar means. Within a reasonable timeframe, we will delete your personal
information or anonymize it (Anonymization refers to the process of rendering
personal information unidentifiable to specific individuals and irreversible.
Information obtained through anonymization is no longer considered personal
information.).
4.3 Please use complex passwords to
help us ensure your account security. We will make every effort to safeguard
the security of any information you send to us. To more effectively protect
your information security, we also encourage you to enhance your self-protection
awareness. We shall only be liable for personal information leaks directly
caused by us. Therefore, please safeguard your account and password information
to prevent personal information leaks.
4.4 The internet environment is not
100% secure. While we strive to ensure the safety of any information you send
to us, we cannot guarantee it. In the unfortunate event of a personal
information security incident, we will promptly notify you in accordance with
legal requirements. This notification will include: the basic details and
potential impact of the security incident; the measures we have taken or will
take to address it; recommendations for you to independently prevent and
mitigate risks; and the remedial measures available to you. We will promptly
notify you of incident-related details via email, letter, phone call, SMS, push
notifications, or other means. When it is impractical to notify each individual
data subject individually, we will publish an announcement through reasonable
and effective channels. Additionally, we will proactively report the handling
status of personal information security incidents to regulatory authorities as
required.
5. Your Rights
You should ensure that all personal
data submitted is accurate. We will make every effort to maintain the accuracy
and completeness of personal data. In accordance with relevant Chinese laws,
regulations, standards, and common practices in other countries and regions, we
guarantee your rights to exercise the following over your personal information:
You may (1) have the right to access
specific personal data we hold about you, subject to exceptions prescribed by
laws and regulations; (2) request that we update or correct inaccurate personal
data about you; and (3) request that we delete your personal data in accordance
with legal provisions. If you wish to exercise these rights, please contact us.
For security purposes, you may be required to submit a written request. We may
refuse to process such requests if we have reasonable grounds to believe they are
fraudulent, impracticable, or would harm the privacy or rights of others.
You may request deletion of your
personal information under the following circumstances:
(1) If our processing of personal
information violates laws and regulations;
(2) If we collect or use your
personal information without obtaining your explicit consent;
(3) If our processing of personal
information seriously breaches our agreement with you.
For security purposes, you may be
required to submit a written request or provide other proof of identity. We may
first ask you to verify your identity before processing your request.
We generally do not charge fees for
reasonable requests. However, for repeated requests that exceed reasonable
limits, we may charge a cost-based fee based on the circumstances. We may
refuse requests that are groundless and repetitive, require disproportionate
technical means (e.g., developing new systems or fundamentally altering
existing practices), pose risks to the legitimate rights and interests of
others, or are impractical (e.g., involving information stored on backup
tapes).
We will be unable to respond to your
request under the following circumstances:
(1) Where it relates to the personal
information controller fulfilling obligations prescribed by laws and
regulations;
(2) Where it is directly related to
national security or defense security;
(3) Where it is directly related to
public safety, public health, or significant public interests;
(4) Where it is directly related to
criminal investigation, prosecution, trial, or enforcement of judgments;
(5) Where the personal information
controller has sufficient evidence indicating the data subject's malicious
intent or abuse of rights;
(6) Where consent is difficult to
obtain but the request is necessary to protect the vital legitimate interests
(e.g., life, property) of the data subject or other individuals;
(7) Where fulfilling the request
would cause severe harm to the legitimate interests of the data subject or
other individuals/organizations;
(8) Where the request involves trade
secrets.
6. How We Handle Children's Personal
Information
Children may not create their own
user accounts or use our services without the consent of their parent or legal guardian (collectively referred to as
"guardian").
Where we collect a child's personal
information with guardian consent, we will only use or publicly disclose such
information when permitted by law, explicitly authorized by the guardian, or
necessary to protect the child.
Although local laws and customs may
define children differently, we consider anyone under the age of 14 to be a
child. If we discover we have collected a child's personal information without
first obtaining verifiable guardian consent, we will take steps to delete the
relevant data as soon as possible.
7. How Your Personal Information is Transferred Globally
We store the information we collect about you within the People's Republic of China. If business needs require transferring personal information overseas in compliance with applicable laws, we will obtain your prior consent and inform you of the purpose of the transfer, the recipient, security safeguards, and associated risks.
8. How This Policy is Updated
Our privacy policy may change.
We will not reduce your rights under
this privacy policy without your explicit consent. We will post any changes of this policy on our platform.
For significant changes, we will
provide more prominent notice (including, for certain services, sending email
notifications detailing the specific changes to the privacy policy).
Significant changes referred to in
this policy include but not limited to:
(1) Significant changes to our
service model, such as the purpose of processing personal information, the
types of personal information processed, or the manner of using personal
information;
(2) Significant changes in our
ownership structure or organizational architecture, such as changes in
ownership due to business restructuring, bankruptcy, or mergers and
acquisitions;
(3) Changes in the primary
recipients of personal information sharing, transfer, or public disclosure;
(4) Significant changes in your
rights regarding personal information processing and the methods for exercising
those rights;
(5) Changes in the department
responsible for personal information security, contact information, or
complaint channels;
(6) When the personal information security impact assessment report
indicates high risk.
9. Contact Us
If you have any questions or
comments regarding the content of this policy, or if you have any questions or
comments about our practices and operations concerning this Privacy Policy, you
may contact us via our platform email address:[classroom@xiaoyezi.com]
We will generally reply within 15
business days.
Last Updated: March 13, 2026
Children's Privacy Protection Statement
New Wanaka Limited and its
affiliated companies (hereinafter referred to as "we") fully
recognize the importance of children's personal information and privacy
security. We respect and protect the personal information of children who use The ONE Smart Piano Classroom. The Children's Privacy Protection
Statement (hereinafter referred to as "this Statement") and our
Privacy Policy aim to explain to guardians (hereinafter referred to as
"you") and children the relevant processing rules and matters related
to our collection and use of children's personal information. Before using any
of our products or services, children, their parents, or other guardians
(hereinafter collectively referred to as "Guardians") must carefully
read and fully understand this Statement, paying particular attention to the
terms highlighted in bold or underlined. Use should only commence after
confirming full understanding and agreement to all terms.
Special Notice for Child Guardians:
If you are the guardian of a child
user, please carefully review this statement and decide whether to consent. We
ask for your cooperation in protecting children's personal information. Help us
safeguard your child's personal information and privacy security by requiring
them to read and accept this statement under your supervision. They should use
our products and services and submit personal information only with your
consent and guidance. Additionally, please instruct, remind, and require your
child not to provide any personal information to any online product or service
provider without your consent.
If we learn that your child is a
minor, we will implement special measures under this Statement to protect the
personal information we collect from them.
Special Note for Children:
We recommend that any child
participating in online activities first obtain their guardian's consent. If
you are under 14 years of age, please have your guardian review this Statement
with you. Only after obtaining your guardian's consent should
you use our products or services, or provide us with any information.
Please carefully read and fully
understand the Privacy Policy and this Statement before deciding whether to
agree to the relevant privacy policies and whether to consent to your use of
our products or services, as well as the use by children under your guardianship.
If you do not agree with
the content of the relevant privacy policies and this Statement, or if you do
not consent to providing the information necessary for service delivery, it may
result in our products or services failing to operate normally or failing to
achieve the intended service outcomes. You and the children under your
guardianship may be unable to use our products, services, or specific business
functions as intended.
By clicking to agree (or confirm)
this Statement online, you consent to our collection, use, and processing of
your information and the information of the children under your guardianship in
accordance with the Privacy Policy and this Statement.
Please understand that this
Statement applies only to our products or services specifically designed for
children under 14 years of age, products or services containing functional
modules specifically designed for children under 14, or products or services
requiring users to input information such as birthdays or ages that can
identify the user's age. For products or services that cannot identify or do
not actively identify user age, the Privacy Policy applies. Our products and
services may include offerings from third parties, and you may also access and
use third-party products and services through our platforms. Please note that
such third parties may collect, use, or process information related to
children, requiring separate consent from you. We recommend that children seek
your consent before authorizing any third party to collect or process their
personal information.
We remind you that important terms
in this Statement that may closely relate to your rights and interests and
those of the children under your guardianship are highlighted in bold font for
your special attention. Please review these sections carefully.
If you have any questions or
requests regarding your personal information while reading this Statement, we
provide dedicated feedback channels. Please refer to the "Contact Us"
section of this Statement for details. We will respond to your inquiries as
promptly as possible.
What Information We Collect
We strictly adhere to laws,
regulations, and agreements with users, following the principles of legitimacy
and necessity, informed consent, clear purpose, security safeguards, and lawful
utilization. Based on the specific products or services you choose, we collect
the following personal information about you and the children under your
guardianship.
(1) For products and services
specifically designed for children under 14 years of age, or specific
functional modules within such products and services, or products and services
requiring users to input age-identifiable information such as birthdays or ages,
we will request users to provide their personal birthday information upon
registration or use. This is to identify whether the user is a child under 14
years of age. In accordance with laws and regulations, we will only permit the
child to continue using the relevant products or services after obtaining the
guardian's consent.
(2) When we identify a user as a
child under 14 based on the above information, we will collect the guardian's
contact details (e.g., mobile number, email address) and contact the guardian
to verify their guardianship relationship with the child. Depending on the
specific verification methods and consent requirements for the product or
service, we may also link your account to the child's account to protect the
personal information rights of both you and the child under your guardianship.
When we identify a user as a child, we may collect additional information from
the guardian (e.g., name) to further verify the guardianship relationship and
better protect the child's rights.
For certain products or services
involving transactions, we may require collection and binding of your bank card
information to enable you to monitor and manage the child user's transaction
activities. If a product or service involves features such as uploading
profile pictures, we strongly recommend guiding children not to upload real
portrait photos or similar information while using our products or services.
(3) During a child's use of our
products or services, we may also collect and use other relevant personal
information. For details on other personal information collected from
children, please refer to the "How We Collect and Use Your Personal
Information" section of our Privacy Policy.
(4) Should we need to collect or use
children's personal information beyond the scope described above, we will seek
the guardian's consent again.
Please understand that you may
choose whether to fill in or provide specific information to us. However, if
you choose not to fill in or provide certain specific information, it may
result in our products or services not functioning properly, or failing to
achieve the intended service outcomes. You and the child under your
guardianship may be unable to use our products, services, or related specific
business functions normally.
How We Use This Information
We strictly comply with applicable
laws and regulations and our agreements with users, using the information
collected from you and the child under your guardianship for the following
purposes:
(1) Verifying the identity of the
child and guardian;
(2) Providing necessary products or
services, and specific features of such products or services;
(3) Optimizing products or services,
ensuring security, and conducting service surveys.
Should we require the use of your
personal information or that of the child under your guardianship beyond the
aforementioned purposes, we will notify you again and obtain your consent.
Circumstances for Sharing, Transferring, or Disclosing Children's Personal
Information
We strictly limit the circumstances
under which children's personal information is shared, transferred, or
disclosed in compliance with applicable laws and regulations.
1. Generally, we do not share children's
personal information with third parties. We may only share such information
with third parties upon prior consent from the child's guardian.
2. Sharing with Guardians
We may share certain children's
personal information (such as the child's username, account, password, and
transaction details within our products and services) with guardians, who can
access and manage such information.
3. For External Processing Purposes Only
We may share children's personal information with third-party partners (such as
third-party service providers, contractors, agents, application developers,
etc.) solely for the purpose of processing. Examples include communication
service providers sending emails or push notifications on our behalf, or map
service providers offering location services. These third parties process the
information under our instructions, in accordance with our Privacy Policy and
relevant confidentiality and security policies.
When entrusting third parties to
process children's personal information, we conduct security assessments of the
entrusted parties and the entrustment activities, sign entrustment agreements,
and require that the entrusted parties' processing activities do not exceed our
authorized scope. We primarily entrust third parties to process children's
personal information for the following purposes:
(1) To provide our services to
children;
(2) To achieve the purposes
described in the "How We Use This Information" section;
(3) To fulfill our obligations and
exercise our rights under the Privacy Policy and this Statement;
(4) To understand, maintain, and
improve our services.
When sharing your and your child's
information with the aforementioned third parties, we will conduct security
assessments and employ measures such as encryption, anonymization, and
de-identification to safeguard your and your child's information security.
4. As our business continues to develop, we may engage in mergers, acquisitions, asset transfers, or similar transactions. Should such transactions result in sharing your and your child's personal information with third parties, we will notify you via push notifications, announcements, or similar means. We will continue to protect your and your child's personal information in accordance with laws, regulations, and standards no less stringent than those required by this Statement, or require the new controller to do so. Otherwise, we will require the company or organization to obtain renewed authorization and consent from the guardian.
5. We may use anonymized children's information for big data analysis, such as generating heatmaps or insight reports that contain no personally identifiable information. We may publicly disclose and share with our partners statistically processed information that does not contain identifying content. This is to understand how users utilize our services or to inform the public about overall usage trends of our services.
6. Generally, we prohibit the disclosure of
children's personal information. However, we may disclose children's personal
information for the following purposes:
(1) To comply with applicable laws,
regulations, and other relevant provisions;
(2) To comply with court judgments,
rulings, or other legal proceedings;
(3) To comply with requests from
relevant government agencies or other legally authorized organizations;
(4) Where we reasonably believe
compliance with laws, regulations, or other relevant provisions is necessary;
(5) For the reasonable and necessary
purposes of enforcing relevant service agreements or this Statement, safeguarding public interests, or
protecting the personal and property safety or other lawful rights and
interests of our customers, us, our affiliates, other users, or employees.
Storage
of Children's Personal Information
We employ technical measures such as
encryption to store children's personal information and ensure its security. We
store children's personal information only for the period necessary to fulfill
the purposes for which it was collected and used. Please refer to the relevant
sections of our Privacy Policy titled "How We Protect Your Personal
Information" and "Your Rights" for detailed information on how
we store and protect personal information.
We store children's personal
information only for the period necessary to achieve the purposes stated in
this statement and for the minimum duration required by applicable laws and
regulations. Should we terminate services or operations, we will promptly cease
further collection of children's personal information while complying with
legal requirements to notify guardians in advance.
When our products or services cease
operation or the retention period for your and your child's personal
information expires, we will notify you and your child via methods such as push
notifications or announcements. We will then delete or anonymize your and your
child's personal information within a reasonable timeframe.
Managing
Children's Personal Information
During the child user's use of our
products or services, to enable you and the child to conveniently access,
correct, or delete relevant personal information, we have incorporated
corresponding operational settings into our product design. You may also contact
us via the provided channels to submit feedback or inquire about related
matters. We will contact you promptly after verifying the issues you raise.
Please understand that during verification, we may require you to provide the
child's account information, date of birth, contact details, and other personal
information. This enables us to complete identity verification and issue
verification before proceeding with your request. We strive to ensure guardians
and children can access, correct, delete the child's personal information, and
cancel the child's registered account.
When accessing, correcting, deleting
the aforementioned information, or requesting account cancellation, we may
require identity verification from the guardian and/or child to safeguard
information security. Unless otherwise required by laws and regulations, when
guardians and children correct, delete personal information, or request account
cancellation, we may not immediately correct or delete corresponding
information from backup systems. However, such information will be corrected or
deleted during subsequent backup updates.
Accessing Children's Personal Information
You and the child under your
guardianship may review the personal information provided or generated by the
child user while using our products or services, including but not limited to
username, password, profile picture, nickname, gender, and content actively
posted.
Correcting Children's Personal Information
We encourage guardians and children
to update and modify children's personal information to ensure its accuracy and
validity. If guardians or children discover errors in the personal information
we collect, use, or process, they may contact us for correction. We will
promptly take corrective measures after completing identity verification and
verification procedures.
Deleting Children's Personal Information
You and the child under your
guardianship may request deletion of collected, used, or processed personal
information under the following circumstances. We will promptly take deletion
measures after completing identity verification and verification procedures.
(1) If we collect, store, use,
transfer, or disclose children's personal information in violation of laws,
administrative regulations, or our mutual agreement;
(2) If we collect, store, use,
transfer, or disclose children's personal information beyond the intended
purpose or necessary period;
(3) If the guardian withdraws
consent;
(4) When you or the child under your
guardianship terminates the use of the product or service through means such as
account cancellation.
Please note, however, that if you
and the child under your guardianship request the deletion of specific personal
information, it may result in the child user being unable to continue using our
products and services or certain specific functionalities within them.
If you discover that your child's
personal information has been collected without your prior consent, please
contact us promptly. We will endeavor to delete the relevant data as soon as
possible.
When
Children Can Manage Their Own Accounts
Once a child under guardianship
reaches the age of 14, they have the right to manage their account
independently. If a child user chooses to manage their account registered on
our products or services on their own, you will no longer be able to access or
control that account. When a child under guardianship gains the right to
independently manage the aforementioned account, we will notify both you and
the child.
Applicability
of This Statement
This Statement applies only to our
products or services specifically designed for children under 14 years of age,
products or services containing functional sections specifically designed for
children under 14, or products or services requiring users to input birthdate,
age information, or other data that can identify the user's age. For products
or services that cannot identify or do not actively identify the user's age,
only the Privacy Policy applies.
Please understand that where this
Statement does not provide specific provisions, the Privacy Policy shall apply
by reference.
Where this Statement applies, if any
provisions of this Statement conflict with those of the Privacy Policy, this
Statement shall prevail.
Contact
Us
If you have any questions or
feedback regarding this Statement, please feel free to contact us at any time
via our platform email: [classroom@xiaoyezi.com].
We will review the matter promptly
and respond within fifteen business days after verifying your identity.
Last Updated: March 13, 2026