Guidelines for the Protection of Minors' Personal Information

Welcome to the services provided by "Quallenge app" (hereinafter referred to as "Quallenge")! We fully understand the importance of the personal information and privacy security of children (referring to minors under the age of fourteen, the same below), and solemnly promise to protect the personal information and privacy security of minors using Quallenge. We hope to explain through these "Guidelines for the Protection of Minors' Personal Information" (hereinafter referred to as "this Policy") the relevant processing rules and other matters when we collect and use children's personal information.

Before using Quallenge, please ensure that children and their parents or other guardians (hereinafter collectively referred to as "guardians") carefully read and fully understand this Policy, especially the terms in bold. Only after confirming full understanding and agreement with all terms should use begin.

Special Note to Guardians:

If we learn that your child is under the age of fourteen, we will take special measures to protect your child's personal information obtained by us in accordance with this Policy. Please help us protect the security of your child's personal information and privacy by requiring them to read and accept this Policy together under your supervision, and they should use Quallenge and submit personal information only with your consent and guidance. If you do not agree with the content of this Policy, it may result in our products and services not operating properly or not achieving the intended service effects. You should require your child to immediately stop accessing/using Quallenge. Your clicking to agree to this Policy, or your child's use/continued use of Quallenge and submission of personal information, signifies your agreement for us to collect, use, and process your child's personal information in accordance with this Policy (including updated versions).

Special Note to Minors:

We recommend that any child participating in online activities should obtain prior consent from their guardians. If you are a child, please notify your guardian to read this Policy together, and before using Quallenge and submitting personal information, seek your guardian's consent and guidance. Your clicking to agree to this Policy, or your use/continued use of Quallenge and submission of personal information, indicates that you have obtained your guardian's permission and that your guardian agrees for us to collect, use, and process your personal information in accordance with this Policy (including updated versions).

How We Collect and Use Children's Personal Information

1. We will strictly fulfill the obligations and responsibilities for protecting children's personal information as required by laws and regulations, following the principles of necessity, informed consent, clear purpose, security safeguards, and lawful utilization. We will collect and use children's personal information only after obtaining the consent of their guardians.

2. When we identify a user as a child, we may collect the guardian's contact information (such as mobile phone number) and contact the guardian to verify the guardianship relationship with the child. To better protect the child's rights and interests, we may also collect more information from the guardian (such as name, ID card, household register, or other proof of guardianship) to further verify the guardianship relationship.

3. During the child's use of Quallenge services, we may also collect and use other children's personal information. Please refer to the Quallenge Privacy Policy for detailed information. If we need to collect and use children's personal information beyond the above scope, we will obtain the guardian's consent again.

Children's Personal Information We May Process

Generally, we will not share children's personal information with third parties outside our company. We will only share children's information with third parties under the following conditions and with the guardian's consent; if we share children's information with third parties, we will conduct a security assessment and sign strict confidentiality agreements with them, requiring them to process information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. At the same time, we will also use encryption, anonymization, de-identification, and other means to protect children's information security.

To provide our services to children, we may share children's information with partners and other third parties. For example: providing corresponding order information to logistics service providers; providing necessary materials for real-name authentication to authentication service providers; in game recommendation center services, providing children's age range information to third-party games in accordance with anti-addiction policies to match corresponding game time limits based on their actual age range;
Sharing with third parties such as partners who commission us to conduct promotions, for the purpose of enabling such commissioning parties to understand the coverage and effectiveness of the promotion. For example, we can inform the commissioning party how many people viewed their promotional information or purchased their products after seeing the information, or provide them with statistical information that cannot identify the child's personal identity to help them understand their audience or customers.
Necessary sharing with affiliated parties. To facilitate providing children with consistent services based on a unified account system, unified management, personalized recommendations, and ensuring system and account security, children's personal information may be shared among us and our affiliated parties as necessary;
Within the scope permitted by laws and regulations, in order to comply with the law, protect our interests, property, or safety, or those of our affiliated parties, partners, children, guardians, or other users or the public from damage, such as preventing fraud and other illegal activities and reducing credit risks, we may exchange information with other companies and organizations. However, this does not include selling, renting, sharing, or otherwise disclosing information for profit-making purposes in violation of the commitments made in this Policy;
As our business continues to develop, we may undergo mergers, acquisitions, asset transfers, or similar transactions, and children's information may be transferred as part of such transactions.
Automatically updating the application on your device.
Where required by laws, regulations, mandatory administrative law enforcement, or judicial requirements to provide children's information, we may disclose children's information based on the type of information requested and the method of disclosure. Under the premise of complying with laws and regulations, when we receive a request for such disclosure, we will require the recipient to produce corresponding legal documents, such as subpoenas or investigation letters. We firmly believe that we should be as transparent as possible within the scope permitted by law regarding the information requested. 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.

How We Store and Protect Children's Personal Information

If we terminate services or operations, we will promptly cease the activities of collecting children's personal information, comply with relevant laws and regulations to notify guardians in advance, and delete or anonymize children's personal information after termination of services or operations, unless otherwise provided by laws, regulations, or regulatory authorities.
We will take encryption and other technical measures to store children's personal information and ensure information security. At the same time, we apply the principle of least privilege to our staff, strictly setting information access permissions and controlling the scope of knowledge of children's personal information. Staff accessing children's personal information must be approved by the person responsible for protecting children's personal information or authorized management personnel, record access, and take technical measures to prevent illegal copying and downloading of children's personal information. If we discover that children's personal information has been or may be leaked, damaged, or lost, we will immediately activate an emergency response plan, take remedial measures, and notify affected guardians and children via email, letter, phone call, push notification, announcement, etc.
Due to technical limitations and the limitations of risk prevention, even if we have tried our best to strengthen security measures, we cannot always guarantee 100% information security. Guardians need to understand that the systems and communication networks used by children to access our services may experience problems due to factors beyond our control.

How to Manage Children's Personal Information

When accessing, correcting, deleting the aforementioned information, or applying for account cancellation, we may require guardians and/or children to undergo identity verification to ensure information security. Unless otherwise provided by laws and regulations, when guardians and children correct or delete children's personal information or apply for account cancellation, we may not immediately correct or delete the corresponding information from backup systems, but will correct or delete such information upon backup updates.
Guardians and children can view the children's personal information provided or generated during the use of Quallenge services, such as personal profile information, part of the usage records, and published content.
We encourage guardians and children to update and modify children's personal information to make it more accurate and effective. If guardians and children discover any errors in the children's personal information we collect, use, and process, they can contact us to make corrections. We will take timely measures to correct it after completing identity verification and verifying the issue.
According to the specific circumstances of the child's choice of Quallenge services, guardians and children may delete some children's personal information on their own while using Quallenge services. Under the following circumstances, guardians and children can directly request us to delete children's personal information, and we will take timely measures to delete it after completing identity verification and verifying the issue.
We also provide the cancellation of registered accounts; guardians and children can follow the specific settings and instructions of individual services to operate or contact us for processing.

Third-Party Services

Third-party social media, third-party games, or other third-party services are operated by the relevant third parties. Children's use of such third-party services (including any information provided by children to such third parties) is subject to the third party's own terms of service and information protection statements (rather than this Policy). Guardians and children need to carefully read their terms. This Policy only applies to the personal information we collect and does not apply to any third-party services or third-party information usage rules. If guardians and children discover any risks with these third-party services, it is recommended to terminate relevant operations to protect the child's legitimate rights and interests and contact us in a timely manner.