iHuman Privacy Policy
Effective Date: April 30, 2020
Preamble
iHuman Products and/or Services provided by Human and Perfect Future Education Co., Ltd. (registered address: Room 2B15, Building 29, No. 89 Heyuan Avenue, Jing-Jin Technology Valley Industrial Park, Wuqing District, Tianjin City; contact address: Building K2, North America Business Center, B No.108 Beiyuan Road, Chaoyang District, Beijing, hereinafter referred to "We" "Our" or "Us") to Users (hereinafter referred to as "You" or "Your") and/or Your Child include online children education products and/or services, including but not limited to the official website at https://www.ihuman.com (hereinafter referred to as "Official Website") and iHuman Children Apps (see Definition of Key Words for details), as well as other products and/or services provided by Us to You from time to time. iHuman Privacy Policy (as amended from time to time) (hereinafter referred to as "this Policy") is hereby formulated by Us in accordance with the Applicable Laws to protect the security of personal information about You and/or Your Child as well as to safeguard lawful processing activities.
All iHuman Products and/or Services are governed by this Policy. iHuman Products and/or Services are applicable to children and Users who have reached the age threshold of adult under the Applicable Laws. We will provide a Child with iHuman Products and/or Services only after his/her parent or guardian (hereinafter referred to “parent”) has read this Policy, fully acknowledge and agree to all the contents specified hereunder, and give the parental consent required by the Applicable Laws, and unless otherwise permitted or required by law, We will not collect, use, or disclose any personal information of a Child without obtaining verifiable consent from that Child’s parent. Parents can review personal information collected about the Child, have this information deleted, and request Us about no further collection or use of the Child’s Personal Information. We take steps to verify the identity of anyone requesting information about a Child and to ensure that the person is in fact the Child’s parent or legal guardian. We also set a parent verification feature for certain iHuman Products and/or Services, and You may use these products or services, only after completing the parent verification.
This Policy sets out why, how and what personal information We collect, use, store, entrust processing, share, transfer and publicly disclose about You and/or Your Child, the information security protection measures We take, and the rights and methods We make available to You for Your access, update, deletion and control of Your and/or Your Child’s personal information. Please read this Policy in combination with iHuman User Service Agreement. If You do not acknowledge and agree to this Policy, You shall stop using iHuman Products and/or Services.
Please note the following which are very important to remind you:
1. All key contents are "in bold".
2. Capitalized terms used in this Policy have the same meanings given in the User Service Agreement, unless explicitly stated otherwise. In addition, we set out interpretations of capitalized terms in Section 11 below as definition of key words.
3. Sensitive personal information is "in bold and italicized", but the definition of sensitive personal information may be subject to the definition in Your jurisdiction. Please pay special attention thereto when reading.
4. Pursuant to the Applicable Laws, You confirm and undertake that You are the parent of the Child who uses iHuman Products and/or Services or an adult User who is at/over the legal age threshold in your jurisdiction or above.
5. This Policy consists of two parts: (I) the General Terms; and (II) the Special Terms which are set forth in the Jurisdiction Schedule. Please note that the Special Terms, forming part of this Policy, contain terms and conditions which are specific to the relevant jurisdictions in which iHuman Products and/or Services are being made available. For the avoidance of doubt, the terms and conditions in the Special Terms shall apply specifically only to the Users who are using iHuman Products and/or Services in the corresponding jurisdictions. In the event that there is any inconsistency between the General Terms and the Special Terms, the Special Terms shall prevail to the extent necessary to resolve such inconsistency.
TABLE OF
CONTENT
1 How We collect and use personal information about You and/or Your Child
4 How You can manage personal information about You and/or Your Child
5 How We keep personal information about You and/or Your Child secure
6 How We retain personal information about You and/or Your Child
7 How We protect children's personal information
8 International transfer of personal information about You and/or Your Child
II SPECIAL TERMS——JURISDICTION SCHEDULE
Please note that, for easy access, You may click on the relevant link above to be directed to a particular section, but We recommend You could read this Policy in full to ensure You are fully informed.
We will collect personal information from You and/or Your Child for the purpose hereof in line with the principles of legality, legitimacy, necessity and transparency. If We use personal information about You and/or Your Child for any purpose other than those contained herein, or collect personal information from You and/or Your Child for any other specific purpose, We will notify You of the same in a reasonable manner and obtain Your acknowledgement or agreement again through Your clicking on pop-up window or any other methods permitted by the Applicable Laws prior to such use or collection. We do not require You or Your Child to disclose more information than it is reasonably necessary to participate in an activity, and We do not condition Your or Your Child’s participation on the disclosure of more personal information than is reasonably necessary.
Please note: We may synchronize Your and/or Your Child’s personal information on Your different mobile clients (such as Your mobile phone and tablet PC), in order to provide You and/or Your Child with successive services.
1.1 Personal information You provide during the use of Our Products and/or Services
1.1.1 In order to provide the basic app features, it is necessary for Us to collect certain personal information from You and/or Your Child, and if You refuse to provide such information, You will not be able to use such app features.
Please note: if You provide personal information that is not about You and/or Your Child, please ensure that You have obtained the due authorization from the concerned data subject.
The following sub-categories describe the extent to which Your data is required.
1.1.1.1 Registration, login, and verification
(1) When You register an account in any iHuman Children App as a new User overseas, You are required to provide Us with Your email address, and We will send a verification code and a direct notice of Our privacy practices to Your email address, to activate Your account and to obtain Your consent to Our collection, use and disclosure of the personal information We collect from You and/or Your Child. Pursuant to the Applicable Laws and for the purpose of security assurance, if You do not provide Your email address, the registration will fail; and as a result, You will not be able to use certain features of iHuman Children Apps, but You may browse the contents that are available to unregistered Users. After We obtained Your verifiable consent and You created an account, You may create a password as required to log in to certain iHuman Children Apps. When You need to retrieve Your login password, You may have to provide Us with the email address that You used during Your registration, and We will send a verification code to this email address. Upon successful verification, You may reset the password and log in again.
(2) Only if You are an existing User of certain iHuman Children Apps, You are allowed to log in to certain iHuman Children App with a third-party account (eg. Facebook account). When You log in with a third-party account at first time after this Policy is read and takes effect, You must provide Us with an email address and We will send a direct notice of privacy practices to Your email address, to activate Your account and to obtain You consent to Our collection, use and disclosure of the personal information We collect from You and/or Your Child.
1.1.1.2 Profile creation
To ensure that You and/or Your Child have a favorable experience with iHuman Children Apps, You can, but are not required to, provide profile photo, nickname, date of birth, age, or gender, to create a profile for You and/or Your Child. If You do not create a profile for You and/or Your Child with such optional information, it may hinder Our ability to provide You and/or Your Child with more personalized contents, but will not impair the basic app functions.
1.1.1.3 Fun study
To cultivate the learning interest for You and/or Your Child, We offer the Fun Study feature in some teaching interactions. When You and/or Your Child use the Fun Study feature, it may be necessary to upload You and/or Your Child’s voice. In the AR feature, to help Your Children develop enthusiasm, You can project a virtual scene or illustration into a real scene with Your camera, but please note that, this function is only for yourself amusement. In other words, no personal information will be obtained, recorded or uploaded to Our server, when You project character images, virtual scenes, etc. into real scenes via your camera.
1.1.1.4 Pronunciation assessment
To cultivate the leaning interest for You and/or Your Child and optimize the learning effect, We offer the Voice Assessment feature to test the accuracy of your pronunciation. To use this feature, Your and/or Your Child’s voice is deemed necessary to be uploaded. If You do not provide your voice, We may not be able to offer you the feature of Pronunciation Assessment.
1.1.1.5 Customer service or complaint
When You complain to, appeal to or consult Us about issues related to iHuman Children Apps through the contact information provided in Section 10, You must provide Us with Your account information so that We can verify Your User identity in order to keep Your account and system secure. During verification, You must also provide Us with relevant evidentiary materials (including but not limited to picture, video or text) and contact information. If You do not provide the aforesaid information, We may not be able to respond to You promptly, however, it will not impair the basic app functions.
When You complain to, appeal to or consult Us about issues related to iHuman Products and/or Services through "Contact Us" on the Official Website, You must provide Us with Your nickname（if applicable in certain iHuman Children Apps), email address and Your enquiries or complaints. If You do not provide the aforesaid information, We may not be able to give accurate feedback about Your issues; however, it will not impair normal use of iHuman Products and/or Services.
1.1.2 To provide You with customized services, it may be necessary for Us to collect the information set out below. Your refusal to provide the information will not impair the basic app functions described under Section 1.1.1, but We will not be able to provide You with certain advanced app features and services. Personalized display feature
To provide You and/or Your Child with more customized services, We may, to the extent permitted by the Applicable Laws, associate Your and/or Your Child's browsing records, learning history, learning duration and order information with your account for the purpose of data analysis, so as to recommend iHuman Products and/or Services that are more suitable to You and/or Your Child.
1.2 Personal information automatically collected during the use of Our products/services
To safeguard the security of Your account and better serve You and/or Your Child, We will collect and use the following information generated during the use of iHuman Products and/or Services by You and/or Your Child as long as it is in compliance with the Applicable Laws:
1.2.1 Device information
When You and/or Your Child use iHuman Children Apps, We will collect certain device information, including browser type, operator information and usage, information about device location (IP address), device model, operating system version, IDFA (for iOS only), IDFV (for iOS only), Android ID (for Android only). Such information is the unique identification of the device, and We may combine it with other personal information We collect so that We can provide You with consistent services. Please note that, We will not upload the MAC address and IMEI of Your device to Our server.
When You and/or Your Child browse the Official Website, We may receive, record, and use certain device information, including device model, device identifier, operating system information subject to specific permissions of software installed by You so that We can provide You with consistent services.
1.2.2 Log information
When You and/or Your Child use iHuman Children Apps, We will automatically collect and save the network logs, including browser type, browsing records, network diagnosis, so that We can evaluate the use of iHuman Children Apps, optimize iHuman Children Apps and provide You with better service experience.
When You and/or Your Child browse the Official Website, We will automatically collect and save the network logs, including Your IP address, browser type and browsing records, so that We can evaluate the use of the Official Website and provide You with better service experience.
1.2.3 Browsing records
When You and Your Child use iHuman Products and/or Services, We will collect browsing information about You and/or Your Child, including browser type, browsing records, and click records. Such information is collected to improve certain features of iHuman Products and/or Services so as to provide You with better service experience.
1.3 Personal information We obtain from a third party about You and/Your Child
1.3.1 We may collect and use personal information about You and/or Your Child from a third party upon Your consent. We process Your and/or Your Child’s personal information in accordance with the contract with the third party, and We ask that You carefully read the privacy policy and user agreement of such third party. Your refusal to a third party's collection, use or sending of Your personal information may result in Your failure to use certain iHuman Products and/or Services. Please note that We do not condition Your use of Our services on the disclosure of more personal information than is reasonably necessary.
1.3.2 Login through a third party: when You log in with social plug-in, to register, You will be redirected to the website of the third-party provider, where You can register an account of respective third-party platforms. When login through the registered account of a permitted third party, Your profile of that third-party account will be bound with an automatically created iHuman account. Currently We offer the Social Sign-in for Facebook. Through the link between two accounts, We only collect name and profile picture from the third-party provider. Please note that even if the third-party provider may collect Your device version, system version, generated ID, phone style, phone name, iccid (for iOS only), bssid(for iOS only), MAC(for iOS only), IMSI(for iOS only), IMEI (for iOS only) for their purpose, these information will not be needed and transferred to us. If You do not want the data to be collected by the third-party provider or being a registered user of a third-party platform prior to use iHuman Products and/ or Services, You can choose using Our own registration services instead. You may contact Us through the contact information provided in Section 10 hereunder if You want to cancel the binding relationship between third-party account and iHuman account.
1.4 Exceptions in acquiring Your consent
Subject to the Applicable Laws, We may not need to obtain Your consent when We collect and use personal information about You and/or Your Child only if:
1.4.1 It is related to performance of the obligations required by the Applicable Laws;
1.4.2 It is directly related to national security;
1.4.3 It is directly related to public safety, public health, and significant public interests;
1.4.4 It is directly related to crime investigation, prosecution, trial and execution of judgment, or is required by the competent authorities or other circumstances required by the Applicable Laws including but not limited to in response to court orders and subpoenas;
1.4.5 It is required for safeguarding Your or any other User's life, property and other significant legal interests but it is difficult to obtain Your consent, or We have reason to believe that someone is or may be causing injury to or interference with Our rights or property, other Users, or anyone else that could be harmed by such activities;
1.4.6 The information was made available to the general public by You;
1.4.7 It is necessary for execution and performance of a contract between You and Us per Your request;
1.4.8 The information is collected from legally and publicly disclosed channels, such as legal news reports, published government information or other channels;
1.4.9 It is necessary for maintaining the operation of iHuman Products and/or Services, such as troubleshooting, discovering and resolving issues in relation with any iHuman Products and/or Services; or
1.4.10 Other circumstances specified or permitted under the Applicable Laws.
We do not use cookies or other similar tracking technologies.
3.1 Subcontract the processing
To provide You and/or Your Child with integral iHuman Products and/or Services with higher quality, some features may be provided by Our technical service providers, and We may therefore subcontract the processing of personal information to such service providers. We will enter into a strict confidentiality agreement and data processing agreement respectively with relevant service providers in the formality of companies, organizations or individuals to which (or whom) We subcontract the processing of personal information about You and/or Your Child. The agreement should be specified the responsibilities of the parties, the matters to be processed, and the period, nature and purpose of processing, and We also require these service providers to process personal information only as per Our request, this Policy and any other relevant confidentiality and security measures. Our service providers include:
3.1.1 Analytical and/or statistical service SDK provider. To better analyze and/or evaluate the usage of the iHuman Users, We may engage a data analysis and/or statistical service provider to process Your device information and User click records for the purpose of maintaining or improving iHuman Products and/or Services and optimizing the User experience.
3.1.2 Technical service SDK provider. We may engage a partner for this service, such as voice-related technical service provider or cloud service provider, to process the voice from You and/or Your Child so that We can evaluate the accuracy of pronunciation and better optimize the User experience. We may also engage a kind of service provider(s) to handle Your system version, generate ID, and phone style, so as to analyze and resolve the abnormal technical issues of iHuman Children Apps.
3.2 Share
We will only collect and use personal information about You and/or Your Child for such purpose and within such scope as set out herein or as required by the Applicable Laws. We will keep such information strictly confidential. Except as otherwise provided by the Applicable Laws, We will not share personal information about You and/or Your Child with a third-party company, organization or individual unless:
3.2.1 You propose the request for doing so or We obtained Your prior express authorization or consent;
3.2.2 It is related to Our performance of the obligations provided by the Applicable Laws;
3.2.3 It is directly related to national security;
3.2.4 It is directly related to public safety, public health, and significant public interests;
3.2.5 It is directly related to crime investigation, prosecution, trial and execution of judgment, or is required by the competent or law enforcement authorities or other circumstances required by the Applicable Laws including but not limited to in response to court orders and subpoenas;
3.2.6 It is required for safeguarding Your and/or Your Child's life, property and other significant legal interests, but it is difficult to obtain Your consent, or We have reason to believe that someone is or may be causing injury to or interference with Our rights or property, other Users, or anyone else that could be harmed by such activities;
3.2.7 The information was made available to the general public by You;
3.2.8 The information is collected from legally and publicly disclosed channels, such as legal news reports, published government information or other channels;
3.2.9 It is shared with Our business partners as needed.
Please note: except as otherwise provided herein, We share personal information about You and/or Your Child only for the purpose of providing You and/Your Child with iHuman Products and/or Services. Besides, We will not share personal information that can be used to directly identify You and/or Your Child, unless otherwise provided by the Applicable Laws.
Specifically, to provide You with integral iHuman Products and/or Services with higher quality, some services may be provided by Our partners, and therefore, We may share some personal information about You and/or Your Child with such partners. The partner of receiving the data shared by Us is deemed as an independent data controller who has been asked to obtain Your consent in its own name to process Your personal information. The partner(s) may have their independent privacy policies and user service agreements, and We suggest You to read them carefully and then make judgement after you have fully awared and acknowledged the provisions therein. Your refusal of Our partners' collection of personal information necessary during provision of services may result in Your failure to use certain functions contained in iHuman Products and/or Services that are provided by such partners.
A list of all Our partners that may collect or maintain personal information from Children through iHuman Products and/or Services is available here. Please direct Your inquiries about any operator's privacy practices and use of Children's information to Human and Perfect Future Education Co., Ltd. through the contact information provided in Section 10 hereunder.
3.2.10 Other circumstances specified or permitted under the Applicable Laws.
3.3 Transfer of Control
Please note: In principle, We will not transfer the right to control the personal information about You and/or Your Child to any other company, organization or individual, provided that transfer is indeed required as below circumstances arise, We will notify You of the purpose of such transfer, the type of the information and the recipient of the information prior to such transfer (We will also notify You of the contents of any sensitive information involved), and proceed with such transfer after obtaining Your consent, unless otherwise provided by the Applicable Laws.
3.3.1 You propose the request for doing so or We obtained Your prior express authorization or consent;
3.3.2 It is related to Our performance of the obligations required by the Applicable Laws;
3.3.3 It is directly related to national security;
3.3.4 It is directly related to public safety, public health, and significant public interests;
3.3.5 It is directly related to crime investigation, prosecution, trial and execution of judgment or is required by the competent or law enforcement authorities or other circumstances required by the Applicable Laws including but not limited to in response to court orders and subpoenas;
3.3.6 It is required for safeguarding Your and/or Your Child's life, property and other significant legal interests, but it is difficult to obtain Your own consent, or We have reason to believe that someone is or may be causing injury to or interference with Our rights or property, other Users, or anyone else that could be harmed by such activities;
3.3.7 The information was made available to the general public by You;
3.3.8 The information is collected from legally and publicly disclosed channels, such as legal news reports, published government information or other channels;
3.3.9 The company is subject to merger, acquisition or bankruptcy liquidation, or the operating entity is changed.
3.4 Disclosure for compliance with the Applicable Laws
In principle, We will not release any personal information about You and/or Your Child to the general public or the non-specific groups, unless required by the Applicable Laws. We may disclose information where we are legally required to do so in order to comply with the Applicable Laws, governmental requests, a judicial proceeding, court order and subpoenas, or other legal requirement.
4.1 Access or correct personal information about You and/or Your Child
4.1.1 You have the right to log in to and access Your account at any time to view personal information about You and/or Your Child, including Your account information and Your and/or Your Child's profile. If You discover that the personal information We collect, store, use and disclose about You and/or Your Child is incorrect, or any circumstance provided by the Applicable Laws arises, You may correct personal information about You and/or Your Child.
4.1.2 You may go to "Legal Terms and Privacy Center" of iHuman Children Apps according to the Operating Instructions, and then click "Personal Information Management" - "Access Personal Information about You and/or Your Child" to access, or click "Personal Information Management" - "Manage Personal Information about You and/or Your Child" - "Correct Personal Information about You and/or Your Child" to correct or modify, personal information about You and/or Your Child.
4.1.3 If You want to access or correct other personal information about You and/or Your Child, or resolve any difficulty in exercising the aforesaid rights, You may contact Us through the contact information provided in Section 10 hereunder, and We will respond to You upon verification of Your identity, unless otherwise provided by the Applicable Laws or stipulations herein.
4.2 Delete personal information about You and/or Your Child
4.2.1 You may request Us to delete personal information about You and/or Your Child in the following circumstances, unless the data has been anonymized or otherwise provided by the Applicable Laws:
4.2.1.1 We collect, store, use, transfer, or disclose personal information about You and/or Your Child in violation of the Applicable Laws or agreements with You;
4.2.1.2 We collect, store, use, transfer or disclose personal information about You and/or Your Child beyond the purpose, scope or a necessary period as agreed hereunder;
4.2.1.3 You withdraw Your consent and/or authorization;
4.2.1.4 You terminate Your use of iHuman Products and/or Services through cancellation or otherwise.
4.2.1.5 Other circumstances specified in the Applicable Laws arise.
4.2.2 If You want to delete personal information about You and/or Your Child, You may go to "Legal Terms and Privacy Center" according to the Operating Instructions, and then click "Personal Information Management" - "Manage Personal Information about You and/or Your Child" - "Delete Personal Information about You and/or Your Child" - "Help Center" to seek for help from the customer service personnel.
4.2.3 Upon Our response to the deletion request, the personal information about You and/or Your Child will be deleted.
4.2.4 Unless otherwise permitted by applicable laws, please note that We may not delete relevant personal information from the backup system immediately but will do so when the backup system is updated or upgraded.
4.3 Change the scope of Your authorized consent
4.3.1 Please note that You are required to provide Us with some basic personal information of You and/or Your Child to use the app functions. If You want to withdraw certain permissions, You may go to "Legal Terms and Privacy Center" according to the Operating Instructions, and then click "Authorization Management" to disable the permissions. If You want to change or withdraw any other consent already given by You, You may contact Us through the contact information provided in Section 10 hereunder.
4.3.2 After You change the scope of Your consent, We will no longer collect and use the personal information about You and/or Your Child, but please understand that after You change the scope of Your consent, We may not be able to provide You with related iHuman Products and/or Services. Your change to the scope of Your consent or withdrawal of Your consent will not affect Our processing and storage of personal information about You and/or Your Child based on Your prior authorization unless You request to delete such information.
4.4 Delete Your account
4.4.1 Unless otherwise provided by the Applicable Laws or agreed on herein, You may go to "Legal Terms and Privacy Center" according to the Operating Instructions, and then click "Personal Information Management" - "Manage Personal Information about You and/or Your Child" - "Delete Account" to delete Your account.
4.4.2 Please note that after the account is deleted, We will immediately delete or anonymize personal information about You and/or Your Child unless otherwise required by the Applicable Laws. Please note that We may not delete such information from the backup system immediately but will do so when the backup system is updated or upgraded.
4.4.3 Your deletion of Your account is irretrievable, and upon deletion of Your account, We will no longer collect personal information about You and/or Your Child or provide You with iHuman Products and/or Services. We suggest You should be cautious when choosing to delete Your account.
4.5 Obtain copies of personal information about You and/or Your Child
4.5.1 If You need the copies of the Child profiles and/or learning records about You and/or Your Child, You may go to "Legal Terms and Privacy Center" according to the Operating Instructions, and then click "Personal Information Management" - "Manage Personal Information about You and/or Your Child" - "Download Personal Information about You and/or Your Child", and if You have logged in and granted access to the album, to obtain the copies of information about You and/or Your Child, You may save all the Child profiles and learning records as pictures and download the same. Copies of information that You could obtain is subject to the pictures format actually generated. If You want to obtain the copies of other personal information about You and/or Your Child, You may contact Us through the contact information provided in Section 10 hereunder.
4.5.2 We may also supply personal information about You and/or Your Child to a third party as requested by You where it is technically feasible.
4.6 Refuse personalized push
4.6.2 Please note that We may send You notices or announcements about iHuman Products and/or Services, which fall outside the personalized push services, when necessary, for example, where a service is suspended for repair.
4.7 Respond to Your above requests
4.7.1 To exercise the User rights set out in Section 4.1-4.6 hereunder, please contact Us through the contact information provided in Section 10 hereunder. For security reasons, We may ask You to verify Your identity before processing Your request. In general, We will reply to Your request as soon as possible and at least no more than 30 days upon receipt of Your request and verification of Your identity.
4.7.2 In general, We do not charge any fee for dealing with Your requests as long as they are reasonable. We may refuse any requests that are not directly associated with You and Your Child or are repetitive without good causes, need excessive technical investment (for example, to develop new systems or fundamentally change existing business practices), or threaten legal interests of others, or that are unpractical.
4.7.3 If You have any question, comment or suggestion about Your rights as a data subject, please contact Us through ihuman_privacy@ihuman.com.
We use appropriate organizational, technical, and physical safeguards to protect the personal information We collect and process about You and/or Your Child. We have adopted protection measures at multiple levels, such as industry-standard technical security measures as well as supporting organizational structures and management systems, to prevent personal information about You and/or Your Child from leakage, destruction, misuse, unauthorized access, unauthorized disclosure or change to a maximum extent.
6.1 We promise that personal information about You and/or Your Child will be retained for no longer than is necessary for the purposes of Your authorized use, unless otherwise required by the Applicable Laws.
6.2 If the operation is stopped for any other reason, We will notify You of the same, stop collecting personal information from You and/or Your Child and delete or anonymize the personal information already collected, unless otherwise required by the Applicable Laws.
7.1 Please note that pursuant to the Applicable Laws, You confirm and undertake that You are the parent of the Child who uses iHuman Products and/or Services or an adult User who is at/above the legal age threshold in your jurisdiction. If You do not acknowledge and agree to this Policy, please do not continue using iHuman Products and/or Services and We will not collect personal information about You and/or Your Child.
7.2 We will try effective means possible, such as parent control, to protect personal information about Your Child: (i) We offer the Parent Verification feature by virtue of particular links such as requiring You to identify traditional Chinese characters and to do difficult mathematical calculations that are beyond the general cognitive ability of a Child, all of which need to be operated by You; (ii) You may control the duration of use iHuman Products and/or Services on the setting page in the Parent Control section; (iii) We also establish the parent center in the WeChat Official Account "iHuman Children Apps."
7.3 Please note that We will not directly sell any iHuman Products and/or Services to a Child, and You shall keep safe of Your payment information to prevent misuse by Your Child. If You want to top up your iHuman account, We will use particular verification means as described in Section 7.2 (1) to prevent any disoperation caused by Your Child.
You can also find more details in Our iHuman Guideline for Children’s Privacy Protection.
8.1 In order to be able to provide iHuman Products and/or Services, personal information about You and/or Your Child will be transferred and shared globally, among iHuman and our Affiliated Companies. Personal information about You and/or Your Child will be accessible from and processed in servers located globally.
8.2 Personal information about You and/or Your Child may be transferred to and processed in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country you reside in, we ensure appropriate safeguards in place so that your personal information will remain protected in accordance with this Policy.
8.3 The data protection rules may vary from jurisdictions to jurisdictions. We listed discrepancies in connection with major jurisdictions, among others, differentiate to general terms, in Special terms hereunder. Please read them carefully when you travel to access the iHuman Products and/or Services in such specific jurisdictions.
9.1 We reserve the right to update or modify this Policy from time to time. We will notify You of any changes to this Policy. Unless otherwise You have explicitly agreed, We will not derogate Your rights under this Policy. These changes form part of this Policy.
9.2 Please read the updated Policy carefully. If You do not acknowledge and agree to this Policy, or if You have any objection to the modification or update of this Policy, You may choose to cancel Your account and no longer use iHuman Products and/or Services. However, please note that Your records and activities before You cancel Your account or stop using the service are still subject to this Policy. If You have any questions about fees when cancelling account, please read iHuman User Service Agreement.
9.3 In case of significant or material changes, We will notify You of such changes in a conspicuous manner, as appropriate.
Significant or material changes include but not limited to:
9.3.1 Significant changes to Our service model, such as the purpose of processing personal information, the types of personal information processed, the way of using personal information, etc.;
9.3.2 Significant changes to Your rights to participate in the processing of personal information and how You exercise such rights.
10.1 We have established a department dedicated to personal information protection and specially appointed a person to be responsible for Children's personal information protection. If You have any issue (including consultation and complaints) concerning privacy protection during You enjoy or use of iHuman Products and/or Services, You may contact Us by: (i) logging into iHuman Children Apps according to the Operating Instructions to submit online complaints and feedbacks; (ii) calling the service hotline 400-888-3337; (iii) sending an email to: ihuman_privacy@ihuman.com; (iv) mailing a letter to: Personal Information Protection Specialist, Building K2, North America Business Center, B No.108 Beiyuan Road, Chaoyang District, Beijing, People's Republic of China; (v) clicking the "Contact Customer Service" feature in the WeChat Official Account "iHuman Children Apps"; or (v) other contact information that We make available.
10.2 We will reply You as soon as possible and at least no more than 30 days upon receipt of Your comments/complaints/suggestions and verification of Your identity. If We are not able to respond to Your request with due cause, We will send You a notice explaining the reasons therefore within the maximum time limit permitted by the Applicable Laws.
10.3 If You feel dissatisfied with Our response or our practice on processing personal information about You and/or Your Child infringes Your and/or Your Child's legal interests, and We refuse to correct or improve Our services after You submit Your feedback to Us, You may lodge Your complaints and reports to the relevant regulatory authority.
11.1 We, Our, Us or iHuman: refers to Human and Perfect Future Education Co., Ltd.
11.2 Affiliated Company: refers to a subsidiary company or other affiliated enterprises within the scope of the consolidated fiscal statement of Human and Perfect Future Education Co., Ltd., and the company/enterprise has or will have a relationship with Human and Perfect Future Education Co., Ltd., in which one party controls, is controlled or under the joint control by other enterprises.
11.3 Control: refers to the fact or ability that a direct or indirect impact is caused to the management of the Company by means of shareholding, voting shares, contractual agreements or other legally recognized means.
11.4 User(s) or You: refers to the parent of the Child who uses iHuman Products and/or Services or an adult User who reaches the legal age threshold of adult under the Applicable Laws or above.
11.5 Child or Your Child: refers to the minor under Your guardianship who is under the age of 14 or otherwise provided by the Applicable Laws in Your jurisdiction.
11.6 iHuman Products and/or Services: refer to the following products and/or services iHuman provides to You and/or Your Child: (1) products and/or services of iHuman Children Apps provided through mobile client; (2) the Official Websites which provide introduction and ways to download products and/or services of iHuman Children Apps; (3) any software relating to the products and/or services described in (1) and (2) ; (4) other iHuman Children education products and/or services provided to You and/or Your Child by iHuman from time to time.
11.7 iHuman Children Apps: refers to the App developed by Human and Perfect Future Education Co., Ltd. and various versions thereof. For details, click here.
11.8 Products and/or Services of iHuman Children Apps: refer to the products and/or services that iHuman provides to You and/or Your Child through various mobile clients used for accessing iHuman Children Apps. Products and/or services provided by iHuman Children Apps through mobile client are one of iHuman Products and/or Services.
11.9 This Policy: refers to the iHuman Privacy Policy (including the General Terms and Special Terms) and its updated versions as amended from time to time.
11.10 Applicable Laws: refers to all applicable laws and regulations worldwide which are legally binding in order to set forth obligations of data protection to controllers and processors and right to data subjects.
11.11 Personal Information: refers to various information recorded electronically or otherwise that can be used to identify a particular person or reflect the activity of a particular person, either alone or in combination with other information. Personal information includes basic information, identity information, biometric information, photographs, videos, audio files, online contact information, a screen or User name where it functions in the same manner as online contact information, persistent identifiers that can be used to recognize Users over time and across different websites or online services, network identify information, health-related and physiological information, education and work information, property information, communication information, contact information, Internet surfing records, common device information and location information of a person. For the avoidance of doubt, personal information includes but is not limited to sensitive personal information.
11.12 Sensitive Personal Information: refers to the personal information which, once disclosed, illegally provided or abused, may endanger life and property security or is likely to cause harm to personal reputation or physical and mental health or discriminatory treatment. Sensitive personal information includes property information, health-related and physiological information, biometric information, identity information and network identify information of a person.
11.14 China or the territory of China: refers to the Mainland of People's Republic of China, excluding Hong Kong Special Administrative Region, Macao Special Administrative Region and Taiwan area, for the purpose of this Policy only.
11.15 Device: refers to the equipment that may be used to access iHuman Products and/or Services, such as desktop, laptop, tablet, smartphone, smart screen, smart watch and smart speaker.
II SPECIAL TERMS——JURISDICTION SCHEDULE
1. How We collect and user personal information about You and/or Your Child.
Followed by Section 1.4, additional section set forth as below shall be added.
1.5 Additional Uses of Your or Your Child’s Personal Information
In addition to the uses described in Sections 1.1 to 1.3, We may use Your or Your personal information for the following purposes:
1.5.1 to contact You about changes to iHuman Products and/or Services;
1.5.2 to send You notices regarding iHuman Products and/or Services;
1.5.3 to send You information We think You may find useful or that You have requested from Us;
1.5.4 to analyze and improve iHuman Products and/or Services;
1.5.5 to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Our policies, or as otherwise required by the Applicable Law;
1.5.5 for any other purposes disclosed at the time the information is collected or to which You consent; and
1.5.6 as otherwise specifically provided in this Policy.
7 How We protect children's personal information.
The following shall be added after the end of section 7.3:
7.4 We will send a verification code and a direct notice of Our privacy practices to Your email, to activate Your account and to obtain Your consent to Our collection, use and disclosure of the personal information that We collect from You and/or Your Child. Pursuant to the Applicable Laws and for the purpose of security assurance, if You do not provide Your email address, the registration will fail, and as a result, You will not be able to use certain features of iHuman Children Apps, but You may return to the homepage to browse the contents that are available to unregistered Users. Unless otherwise permitted or required by law, We will not collect, use or disclose of personal information of a Child without obtaining verifiable consent from such Child’s parent.
11 Definition of Key Words.
Section 11.5 shall be replaced with the following:
11.5 Child or Your Child: refers to a minor under Your guardianship who is under the age of 13.
Preamble.
(1) The 2nd paragraph shall be replaced with the following:
All iHuman Products and/or Services are governed by this Policy. iHuman Products and/or Services are applicable to Children and Users who have reached the age threshold of adult under the Applicable Laws. We will provide a Child with iHuman Products and/or Services only after his/her parent or guardian (hereinafter referred to “parent”) has read this Policy, and fully acknowledge all the contents specified hereunder, and give the parental consent required by the Applicable Laws, and unless otherwise permitted or required by law, We will not collect, use, or disclose any personal information of a Child without obtaining verifiable consent from that Child’s parent. Parents can review personal information collected about the Child, have this information deleted, and request Us about no further collection or use of the Child’s Personal Information. We take steps to verify the identity of anyone requesting information about a Child and to ensure that the person is in fact the Child’s parent or legal guardian. We also set a parent verification feature for certain iHuman Products and/or Services, and You may use these products or services, only after completing the parent verification.
(2) The 3rd paragraph shall be replaced with the following:
This Policy sets out why, how and what personal information We collect, use, store, entrust processing, share, transfer and publicly disclose about You and/or Your Child, the information security protection measures We take, and the rights and methods We make available to You for Your access, update, deletion and control of Your and/or Your Child’s personal information. Please read this Policy in combination with iHuman User Service Agreement. If You do not acknowledge this Policy, You shall stop using iHuman Products and/or Services.
1 How We collect and use personal information about You and/or Your Child.
(1) the following legal basis shall be added respectively after the end of each Section:
|
Section |
Legal Basis |
|
Art. 6 para. 1 lit. b GDPR (necessary for the performance of the contract under which the User account is provided, in case of Your information) & Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your Child’s information) |
|
|
Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your and Your Child’s information) |
|
|
Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your and Your Child’s information) |
|
|
1.1.1.4 Pronunciation assessment |
Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your and/or Your Child’s information) |
|
Art. 6 para. 1 lit. b GDPR (necessary for the performance of the contract under which the User account is provided, in case of Your information) & Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online in case of Your Child’s information) |
|
|
1.1.2.1 Personalized display feature
|
Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your and Your Child’s information) |
|
1.2.1 Device information |
Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your and Your Child’s information) |
|
1.2.2 Log information |
Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your and Your Child’s information) |
|
1.2.3 Browsing records |
Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of iHuman in providing iHuman Products and/or Services online, in case of Your and Your Child’s information) |
|
1.3 Personal information We obtain from a third party about You and/Your Child |
Art. 6 para. 1 lit. a GDPR (consent) |
(2) Section 1.4 shall not apply.
3 How We subcontract the processing of, share, transfer or publicly disclose personal information about You and/or Your Child.
Section 3.3 shall not apply.
4 How You can manage personal information about You and/or Your Child.
(1) Section 4.5 shall be replaced with the following:
4.5 Right to data portability: You may have the right to receive Your personal data, which You have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Us.
(2) Followed by Section 4.7, additional two sections set forth as below shall be added.
4.8 Right to restriction of processing: You may have the right to obtain from Us restriction of processing, for example, where the accuracy of the personal data is contested by You, for a period enabling Us to verify the accuracy of the personal data, or where the processing is unlawful and You oppose the erasure of the personal data and request the restriction of their use instead.
4.9 Right to object: In some situations, You may also have the right to object to the processing of Your personal data, e.g. on grounds relating to his or her particular situation if We process Your personal data on Our legitimate interest, or where personal data are processed for direct marketing purposes.
4.10 You have the right to lodge a complaint with Your competent supervisory authority in case You feel not satisfied with our handling of Your requests.
6 How We retain personal information about You and/or Your Child.
Section 6 shall be entirely replaced with the following:
6.1 We will keep personal data for as long as it is necessary for the relationship with You or otherwise permitted or required under the Applicable Law. If We are processing a specific request that You have sent to Us, We will generally keep the concerned personal data for as long as is necessary to process this request. Afterwards, We may retain personal data for an appropriate period to protect ourselves from legal claims, to administer Our business, or to the extent permitted by the Applicable Law, which may require Us to hold the relevant personal data for specific periods. If We process personal data based on consent, We will delete this personal data upon withdrawal of the consent. If a different retention period will apply to any personal data, this will be specified at the time that personal data is collected (e.g. when We ask for consent).
6.2 If We cannot entirely delete personal data due to statutory retention obligations or billing and accounting obligations, the personal data will be "blocked" (meaning that the personal data cannot be used further) until the relevant retention period expires or until the billing or accounting purpose has been fulfilled.
7. How We protect Children's personal information
Section 7.1 shall be replaced with the following:
7.1 Please note that pursuant to the Applicable Laws, You confirm and undertake that You are the parent of the Child who uses iHuman Products and/or Services or an adult User who is at/above the legal age threshold in your jurisdiction. If You do not acknowledge this Policy, please do not continue using iHuman Products and/or Services and We will not collect personal information about You and/or Your Child.
8 International transfer of personal data
Followed by Section 8.3, an additional section set forth as below shall be added:
8.4 Where personal data is transferred out of the EU/EEA to a third party in connection with the purposes set out in this Policy, We will, to the extent that no statutory level of security comparable to the European data protection laws exists in such countries, adopt appropriate measures to ensure that Your personal data will be adequately protected in these countries. In particular, We may apply the standard contractual clauses published by the European Commission or an appropriate Privacy Shield certification.
A copy of the relevant mechanism can be provided for Your review on request to Us using the contact information provided in Section 10 of this Policy.
9. How We update this Policy
Section 9.2 shall be replaced with the following:
Please read the updated Policy carefully. If You do not acknowledge this Policy, or if You have any objection to the modification or update of this Policy, You may choose to cancel Your account and no longer use iHuman Products and/or Services. However, please note that Your records and activities before You cancel Your account or stop using the service are still subject to this Policy. If You have any questions about fees when cancelling account, please read iHuman User Service Agreement.
11. Definition of Key Words.
(1) All the term “personal information” used herein shall be equivalently replaced with “personal data”.
(2) All the term “agree”, “agree to”, “accept and continue”, “consent” shall not be interpreted as constituting “consent” under the GDPR.
(3) Section 11.5 shall be replaced with the following:
11.5 Child or Your Child: refers to a minor under Your guardianship who is under the age of 16, unless otherwise provided by the Member States however such lower age is not below age of 13.
(4) Section 11.10 shall be replaced with the following:
11.10 Applicable Laws: refers to the General Data Protection Regulation (EU 2016/679) which is the European framework for the protection of personal data applicable in all European member states.
(5) Section 11.12 shall be replaced with the following:
11.5 Sensitive Personal Information: refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
(6) Followed by Section 11.15, additional three sections set forth as below shall be added:
11.16 EU: refers to the European Union.
11.17 EEA: refers to the European Economic Area, namely the European Member States along with Iceland, Liechtenstein and Norway.