Children's Privacy Statement
UBTECH Robotics Corp Ltd(hereinafter referred to as "UBTECH", "we") deeply understands the importance of protecting children's personal data and data security. We will take corresponding security protection measures as required by laws and regulations to do our best to protect the security and controllability of children's personal data. This Statement mainly explains to you what children's personal data we collect, the uses of the collected children's personal data, the protection measures for children's information, etc., and declares our commitment to protecting children's personal data.
This Statement only applies to our products or services specifically designed for children under 14 years old, products or services with functional modules specifically designed for children under 14 years old, or products or services that require users to input birthday, age information, etc. to identify the user's age. For products or services that cannot identify or do not actively identify the user's age, only the <AI Wukong Robot Privacy Policy> applies. Please understand that in the case of applying This Statement, if there are inconsistencies in the provisions of similar clauses between This Statement and the <AI Wukong Robot Terms of Use> , the <AI Wukong Robot Privacy Policy> , this Statement shall prevail. For matters not covered, the <AI Wukong Robot Privacy Policy> shall prevail.
Special Instructions for Child Guardians:
If you are the guardian of a child user, please carefully read and choose whether to agree to This Statementline. We hope that you will join us in protecting children's personal data, educating and guiding children to enhance their awareness and ability to protect personal data, and instructing, reminding, and requiring them not to provide any personal data to any online product or service provider without your consent.
Special Instructions for Children:
If you are a minor under 14 years of age, you need to carefully read This Statement together with your guardian, and use our products, services, or provide information to us only after obtaining your guardian's consent.
Please carefully read and fully understand This Statement before using any of the functions or services provided by AI Wukong Robot, and choose whether to consent to children users using our products or services. If you do not agree to the content of This Statement or do not agree to provide the information necessary for the services, it may result in the inability to use our products, services, or related specific business functions properly. We would like to remind you that we have used bold font to specifically draw your attention to the important clauses in this Statement that (may) be closely related to the rights and interests of guardians and children users. Please pay special attention to them.
If you have any questions or rights requests regarding personal data-related matters during the process of reading This Statement, we have provided a dedicated feedback channel for you. Please refer to the "Contact Us" section of This Statement for details, and we will respond to you as soon as possible.
This Statement mainly provides the following information to you and children:
1. How We Collect and Use Children's personal data
2. How We Provide, Transfer, and Publicly Disclose Children's personal data
3. How We Store and Protect Children's personal data
4. How do you manage children's personal data?
5. Update to This Statementline
6. How to Contact Us
1. How We Collect and Use Children's personal data
We strictly abide by the provisions of laws and regulations and the agreements with users, and collect the following personal data of guardians and child users based on the specific circumstances of the products or services selected by child users.
1.1 For our products and services specifically targeting children under 14 years of age, or for certain functional modules of products and services, or products or services that require users to input date of birth, age information and other information that can identify the user's age, if registering or using such products or services, we may require users to fill in their personal date of birth to identify whether the user is a child under 14 years of age, and in accordance with laws and regulations, only allow children to continue using the relevant products or services after obtaining the consent of the guardian. Please note that the relevant functions of our generative artificial intelligence services are not open to child users under 14 years of age. If you, as a guardian, confirm that the user of the AI Wukong Robot is a child, or may include children, please be sure to carefully read and understand This Statement, the "AI Wukong Robot Privacy Policy", the "AI Wukong Robot Terms of Use", and ensure that children use the relevant functions under your explicit consent and guardianship guidance.
1.2 When we identify a user as a child under 14 years old based on the above information provided by the user, we may collect your contact information, such as your mobile phone number and email address, and use this information to contact you to verify the guardianship relationship between you and the child user . Depending on the specific implementation plan for verifying the guardianship relationship and obtaining your consent, we will (such as mobile phone number) associate you with the child to protect the personal data rights and interests of the guardian and the child user. If the product or service involves functions such as uploading avatars, we strongly recommend that you guide the child not to upload information such as real portrait photos of themselves during the use of our products or services .
1.3 During the process of the product or service being used by the child himself/herself or by the guardian on behalf of the child, we will collect relevant information. For details, please refer to the "How We Collect and Use Your personal data" section of the <AI Wukong Robot Privacy Policy> to learn in detail about other personal data of children that we collect through the App and smart hardware terminals respectively.
1.4 If we need to collect or use the personal data of guardians or children beyond the above collection scope, we will inform you again and obtain your consent.
1.5 Please understand that you may choose whether to fill out or provide us with specific information. However, if you do not fill out or provide certain specific information, it may result in the product or service related to that information not operating properly, or failing to achieve the intended functionality or service effectiveness as designed.
1.6 Some features in our products or services may require children to enable specific access permissions (such as microphone, location, etc.) on their devices to collect and use the information related to these permissions. When children and guardians need to disable such features, most mobile devices will support this requirement. For specific methods, please refer to the product manual or contact us. Once any permission is enabled on the device, it represents that the guardian has authorized us to collect and use relevant information to provide corresponding services for children. Once any permission is disabled on the device, it represents that the guardian has revoked the authorization, and we will no longer continue to collect and use relevant information based on the corresponding permission, nor will we be able to provide the services corresponding to that permission for children. However, the decision to disable permissions does not affect the information collection and use previously carried out based on the guardian's authorization.
2. How We Provide, Transfer, and Publicly Disclose Children's personal data
We comply with the provisions of laws and regulations and strictly restrict the provision, transfer, disclosure, and other situations of children's personal data.
2.1 Under normal circumstances, we will not provide children's personal data to third parties unless prior authorization and consent from the guardian have been obtained.
2.2 Provision to Guardians. We may share some personal data of children with guardians, who can access and manage the relevant personal data of children. You may refer to Chapter 4 of This Statement to learn about the specific operating procedures.
2.3 To provide more comprehensive and high-quality products and/or services to child users, certain of our services will be provided by partners. If we entrust a third party to process children's personal data, we will conduct a security assessment of the entrusted party and the entrusted behavior, sign an entrustment agreement, require that the entrusted party's processing behavior does not exceed our authorized scope, and adopt means such as encryption, anonymization, and de-identification to safeguard the security of children's personal data. For specific details on how third parties process children's personal data, please refer to the "How We Collect and Use Your personal data" section of the <AI Wukong Robot Privacy Policy>.
2.4 The products and services we provide may include those provided by third parties, and children may also log in to and use third-party products and services through our products. Please note that such third parties may collect, use, or process relevant information about children, and they need to obtain your consent separately. We recommend that you ask children to seek your consent before authorizing third parties to collect and process any of their personal data.
2.5 In the event of a merger, acquisition, asset transfer, or similar transaction, a child's personal data may be transferred as part of such a transaction. We will require the new company or organization that holds the child's personal data to continue to be bound by the <AI Wukong Robot Privacy Policy> and This Statementline; otherwise, we will require the company or organization to seek authorization and consent from you again.
2.6 Under normal circumstances, we will not disclose children's personal data externally, but we may disclose children's personal data for the following purposes:
(1) Comply with applicable laws, regulations, and other relevant provisions;
(2) Comply with the provisions of court judgments, rulings, or other legal proceedings;
(3) Comply with the requirements of relevant government agencies or other legally authorized organizations;
(4) We have reason to believe that we need to comply with relevant regulations such as laws and regulations;
3. How We Store and Protect Children's personal data
3.1 We guarantee that children's personal data has the highest level of security protection. We will adopt technical measures such as encryption to store children's personal data to ensure information security.Please refer to the "AI Wukong Robot Privacy Policy" section "How We Protect Your personal data" for detailed information on how we store and protect children's personal data.
3.2 In addition, we adhere to the principle of least privilege, allowing only employees and third-party service providers with relevant business needs and a legitimate need to know this information to access children's personal data, and have established strict access control and monitoring mechanisms for this purpose. Similarly, we have dedicated access control measures for cloud-based data storage. We regularly review information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.
3.3 When our products or services cease operation, or when the storage period of the personal data of guardians and children expires, we will notify you in forms such as push notifications, announcements, etc., and delete or anonymize your personal data within a reasonable period.
3.4 In the event that a child's personal data security incident unfortunately occurs, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impacts of the security incident, the measures we have taken or will take to handle it, suggestions for guardians and children to independently prevent or reduce risks, remedial measures, etc. We will inform guardians and children of the relevant situation of the incident by means of email, letter, phone call, push notification, etc. When it is difficult to inform individual information subjects one by one, we will take reasonable and effective measures to issue an announcement. At the same time, we will also report the handling situation of the child's personal data security incident to the regulatory authorities as required.
4. How do you manage children's personal data?
During the period when child users use our products or services, in order to enable guardians and children to more conveniently access, correct, and delete relevant personal data, we have provided corresponding operational settings in the product design for you. You may also use the contact information we provided to provide feedback and inquire about relevant information. We will contact you promptly after verifying the issues you have reported. Please understand that during the verification process, we may need you to provide your WeChat or QQ account so that we can continue to respond to your needs after completing identity verification and issue verification.
4.1 Access to Children's personal data
You have the right to access the child's personal data through the child's account, view the personal data provided or generated by the child user during the use of our products or services, including but not limited to username, avatar, nickname, programming works, etc.
4.2 Correct Children's personal data
When you discover that the personal data of children we collect, use, and process is incorrect, you may contact us for correction. We will take timely measures to correct it after completing identity verification and problem verification.
4.3 Deleting Children's personal data
If any of the following situations occur, you may request us to delete the personal data of children that we have collected, used, and processed. We will take timely measures to delete such information after completing identity verification and problem verification:
(1) If we collect, store, use, transfer, or disclose children's personal data in violation of laws, administrative regulations, or the agreements between the two parties;
(2) If we collect, store, use, transfer, or disclose children's personal data beyond the scope of the purpose or the necessary time limit, or if you discover that your or your child's personal data has been collected without your prior consent;
(3) If you or the child no longer use our products or services, or if you have cancelled your account, after you choose to cancel your account, we will delete or anonymize all relevant personal data of the child after the cancellation, except as otherwise provided by laws and regulations;
(4) If we terminate the service and operations;
Please note that if you and the child under guardianship request us to delete specific personal data of the child, it may result in the child user being unable to continue using our products and services or certain specific business functions within the products and services.
5. Update of This Statement
Without your express consent, we will not reduce your rights under this currently effective Statement. When significant changes occur to This Statementline, we will promptly notify you through methods such as pop-up reminders, message push notifications, email notifications, or announcements posted on the official website. Situations that constitute significant changes include but are not limited to:
There are significant changes to the scope, mode, etc. of the services we provide, such as changes to the purpose of collecting and using children's personal data, the types of children's personal data processed, the methods of using children's personal data, etc.;
Significant changes occur in aspects such as our business entity, organizational structure, ownership structure, etc., including changes in ownership caused by business adjustments, mergers, acquisitions, reorganizations, etc.;
There are significant changes in your rights regarding the processing of children's personal data and the ways to exercise them;
When the risk assessment report on children's personal data indicates the existence of high risks;
The responsible department for children's personal data security, its contact information, and complaint channels have changed;
Other changes that may have a significant impact on children's personal data rights and interests.
To ensure that you receive notifications in a timely manner, we recommend that you notify us promptly when your contact information is updated. If you continue to use this product after the updated Statement take effect, it indicates that you have fully read, understood, and accepted the updated Statement and are willing to be bound by them.
You can view This Statement in the APP via "My → About → Children's Privacy Statement".
6. Contact Us
We have already assigned dedicated personnel for personal data protection. If you have any questions about this Statement, or any complaints or suggestions regarding the processing of your personal data, you can provide feedback to us through the "My → Help & Feedback → Feedback" section in the APP settings interface. You can also contact us through the following methods:
Phone: +86-400-6666-700 (Monday to Friday, 9:00-18:30 GMT+8)
Email: ucare@ubtrobot.com
Office Address: 22nd Floor, Building C1, Nanshan Zhiyuan, No. 1001 Xueyuan Avenue, Nanshan District, Shenzhen, China
We will reply to you within 40 days.