Children Privacy Protection Notice
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Last Updated Date:28/06/2022
If you are a child and live in Europe or the United Kingdom, please see our 南宫ng·28 Children Privacy Protection Statement for Kids in Europe and the UK.
If you are an adult, please review this privacy policy carefully, including the relevant information for parents and guardians about children who use our products and Services.
This Children Privacy Protection Notice (“Privacy Notice”) describes how 南宫ng·28 and/or its affiliates and subsidiaries' (collectively “南宫ng·28”, “we”, “our” or “us”) protect the Personal Information we receive and process, what types of Personal Information we collect, what we do with it, how we disclose it, and rights in relation to the processing of Personal Information in our Children Products and Service.
Certain processing activities may be subject to a separate and tailored privacy policy that will apply in addition to this Privacy Notice and which will be brought to your attention before we start to process your personal data.
WHEN DOES THIS PRIVACY POLICY APPLY?
This Privacy Notice applies to our collection and use of Personal Information when you access or use any 南宫ng·28 brand children’s products (including kids watch, 南宫ng·28 kids application and other children services provided by 南宫ng·28 Communication Technology Holdings Limited that may refer to this Privacy Notice (collectively “Services”) or when you access our website or contact us in any other manner. To find out more, please click on any of the sections below.
WHAT IS PERSONAL INFORMATION?
“Personal Information” means the information we process about you and/or your child as provided for under applicable privacy law(s).
This includes information that you provide to us directly by: (1) filling in forms; (2) enter information on our Services; (3) create a user account; or (4) communicate with us. This also includes information about you that we passively obtain and / or generate from your use of our Services, as well as information that we receive from other sources, as detailed below.
Personal Information does not include aggregate or anonymous information.
PERSONAL INFORMATION WE COLLECT
We are committed to protecting your privacy – as an adult (including parent and guardian) or child – whenever you use our Services, or otherwise interact with us. For the purposes of this Privacy Notice, we consider a “child” to be any user who is below the age of majority in his or her respective jurisdiction. Where required by applicable law, we obtain parental or guardian consent for a child to use our Children Products and Services. We do not require children to disclose more information than is reasonably necessary to use our Services.
The types of Personal Information we collect from adults and/or children differ depending on the Services they use. For more information, please click below:
Kids Watch
We collect the following types of Personal Information from adults and/or children when they use our Kids Watch or otherwise interact with us：
南宫ng·28 Kids Application
The following types of Personal Information are collected from adults and/or children when they use our Children Products and Services or otherwise interact with us:
Basic information and contact details, which may include name, address, email address, month and year of birth, gender, nationality, and account name or account ID.
HOW WE USE PERSONAL INFORMATION AND ON WHAT LEGAL BASIS WE RELY ON
We may collect, store, process or otherwise used Personal Information for the purposes set out in the table below. For clarity, we have also specified the type(s) of Personal Information and the legal basis we rely up (where applicable data protection law requires a legal basis to process Personal Information) for each processing purpose.
To comply with local laws, we may ask for your consent or permission as a parent/guardian before your child can use our Services. If your jurisdiction is one of those requiring consent and you believe your child is participating in an activity that collects Personal Information and you or another parent/guardian have NOT provided consent or permission, please contact us through the ways provided in the Contacting Us section at the end of this Privacy Notice. We will not use the parent(s) or guardian(s) email address or any other Personal Information provided for parental consent purposes to send them marketing, unless the parent has opted in or has separately participated in an activity that permits us to send him or her marketing communications in accordance with applicable privacy laws.
Kids Watch
|
Processing Purpose(s) |
Type(s) of |
Legal Basis |
|
To obtain parental or guardian’s consent, where legally required by law |
Basic information and contact details; profile information and identifiers |
Necessary to comply with a legal obligation (where applicable) AND Necessary to perform a contract (i.e., our Terms of Service) |
|
To authenticate users |
Basic information and contact details; profile information and identifiers; device and system usage information |
Necessary to perform a contract (i.e., our Terms of Service) |
|
To provide, manage and facilitate your use of our products and Services, including to help you set up and manage an adult or child account (including pairing and un-pairing devices, enabling or disabling certain features on a device, managing contact lists, sending health reminders, and so forth) |
Basic information and contact details; profile information and identifiers; physical characteristics (e.g., when you activate the pedometer feature); device and system usage information; internet or similar network activity; geolocation data (e.g., to track the location of your child or activate the weather feature); inferences drawn from other Personal Information |
Necessary to perform a contract (i.e., our Terms of Service) We process your physical characteristics on the basis of your (parental) explicit consent. |
|
To conduct ordinary business operations and for associated administrative purposes, including to facilitate internal purposes such as auditing, data analysis, and research to improve our products and Services, user experience and customer communications |
Profile information and identifiers; device and system usage information; internet or similar network activity; inferences drawn from other Personal Information |
Our legitimate interests to facilitate internal purposes such as auditing, data analysis, and research to improve our products, Services, user experience and customer communications. |
|
To provide software updates, maintenance services, and support for Services |
Device and system usage information; internet or similar network activity |
Necessary to perform a contract (i.e., our Terms of Service) |
|
To provide customer support To respond to any questions or concerns that may arise in connection with Services |
Basic information and contact details |
Our legitimate interests to provide customer support and resolve questions or concerns in relation to our products and Services |
|
To send you marketing information about Services and help to make that information more relevant to you To administer contests, promotions, events, market research, and surveys in relation to Services |
Basic information and contact details of parents or guardians. |
Consent |
|
To protect against and prevent fraud and other legal or information security risks, as well as to defend and exercise legal rights
|
Basic information and contact details; profile information and identifiers; physical characteristics (e.g., when you activate the pedometer feature); device and system usage information; internet or similar network activity; geolocation data (e.g., to track the location of your child or activate the weather feature); inferences drawn from other Personal Information |
Our legitimate interests to protect against and prevent fraud and other legal and information security risks We process your physical characteristics for these purposes on the basis of your (parental) consent. Moreover, when we collect information stored on the Watch for these purposes, we rely on your (parental) consent. |
|
To comply with applicable laws, regulations, directives and court decisions (for example, tax and accounting laws, consumer protection laws), including to contact you in relation to Services, for example, in the event that any Services have changed or present issues |
Basic information and contact details; profile information and identifiers; physical characteristics (e.g., when you activate the pedometer feature); device and system usage information; internet or similar network activity; geolocation data (e.g., to track the location of your child or activate the weather feature); inferences drawn from other Personal Information |
To comply with applicable law, regulations, directives and court decisions |
南宫ng·28 Kids Application
|
Processing Purpose(s) |
Type(s) of |
Legal Basis |
|
To obtain parental or guardian consent where legally required by law |
Basic information and contact details; profile information and identifiers |
Necessary to comply with a legal obligation (where applicable) AND Necessary to perform a contract (i.e., our Terms of Service) |
|
To authenticate users |
Basic information and contact details; profile information and identifiers; device and system usage information |
Necessary to perform a contract (i.e., our Terms of Service) |
|
To provide, manage and facilitate your use of our products and Services, including to help you set up and manage an adult or child account |
Basic information and contact details; profile information and identifiers; device and system usage information; inferences drawn from other Personal Information |
Necessary to perform a contract (i.e., our Terms of Service) |
|
To conduct ordinary business operations and for associated administrative purposes, including to facilitate internal purposes such as auditing, data analysis, and research to improve our products, Services, user experience and customer communications |
Profile information and identifiers; device and system usage information; internet or similar network activity; inferences drawn from other Personal Information |
Our legitimate interests to facilitate internal purposes such as auditing, data analysis, and research to improve our products, Services, user experience and customer communications When we collect information stored on the device you use to access the App for these purposes, we rely on your consent. |
|
To provide software updates, maintenance services, and support for Services |
Device and system usage information; internet or similar network activity |
Necessary to perform a contract (i.e., our Terms of Service) |
|
To provide customer support To respond to any questions or concerns that may arise in connection with Services |
Basic information and contact details |
Our legitimate interests to provide customer support and resolve questions or concerns in relation to our products and Services When we collect information stored on the device you use to access the App for these purposes, we rely on your consent. |
|
To send you marketing information about Services and help to make that information more relevant to you To administer contests, promotions, events, market research, and surveys in relation to Services |
Basic information and contact details |
Consent |
|
To protect against and prevent fraud and other legal or information security risks, as well as to defend and exercise legal rights
|
Basic information and contact details; profile information and identifiers; device and system usage information; internet or similar network activity; inferences drawn from other Personal Information |
Our legitimate interests to protect against and prevent fraud and other legal and information security risks When we collect information stored on the device you use to access the App for these purposes, we rely on your consent. |
|
To comply with applicable laws, regulations, directives and court decisions(for example, tax and accounting laws, consumer protection laws) , including to contact you in relation to Services, for example, in the event that any Services have changed or present issues |
Basic information and contact details; profile information and identifiers; device and system usage information; internet or similar network activity; inferences drawn from other Personal Information |
To comply with applicable law, regulations, directives and court decisions |
Please note that if you and/or your child do not provide certain Personal Information, we may not be able to accomplish some purposes outlined in this Privacy Notice; consequently, you and/or your child may not be able to use or access certain Services that require the use of such Personal Information.
Where we rely on consent as the legal basis to process Personal Information, it can be withdrawn at any time without affecting the lawfulness of the processing prior to such withdrawal. Where we rely on consent as the legal basis to process a child’s Personal Information, we make reasonable efforts to ensure we obtain valid parental consent in accordance with our parent email verification process.
南宫ng·28 may collect some of the information above stored on your device (e.g., the watch or the device used to access the app), for example, by using cookies and similar technologies. Please consult the cookie notice for more information
Your Choices
We may need consent for certain marketing activities or for other purposes. We offer various ways to opt-out of receiving certain communications from us. To opt-out of receiving email marketing communications from us, you may click the “Unsubscribe” link found at the bottom of the email and follow the instructions.
We do not sell or otherwise disclose Personal Information provided to us, except as described in this Privacy Notice (see “Sharing of Personal Information”), as disclosed at the time of the data collection, or as described in any specific privacy policy, as applicable. We will not disclose Personal Information to third parties, unless such disclosure will be necessary with reference to the legal purpose of the processing, as better described in the following section “When We Share Personal Information”.
Please note that we will collect special category Personal Information (i.e. health or biometric information) only where we obtain your explicit consent or where required or otherwise permitted by applicable law.
SHARING OF PERSONAL INFORMATION
We may disclose Personal Information with our affiliates and subsidiaries in one or more of the circumstances described below:
We may also share Personal Information with third parties in the following situations:
RETENTION OF PERSONAL INFORMATION
南宫ng·28 retains Personal Information only for as long as necessary and it will be deleted after a reasonable time according to the following criteria:
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
The use of our Services may involve the transfer, storage and processing of Personal Information within and outside of your country of residence, consistent with this Privacy Notice. The data protection laws of countries to which Personal Information may be transferred might not guarantee the same level of protection as your country does.
Transfer of Personal Information from within the European Economic Area (EEA), Switzerland and UK to outside of the EEA / UK / Switzerland
Your data is accessed by the controller, located in China. In addition, we use service providers in China and the US that they can help us provide you the Services.
When we transfer Personal Information from within the EEA, UK or Switzerland to outside the EEA, UK or Switzerland to China, we will transfer your personal data where necessary to provide the Services and perform the contract you entered into with us.
You may request additional details about how Personal Information is protected by us in case of transfer outside EEA, UK or Switzerland by contacting us as described in the “Contacting Us” section below.
SECURITY OF PERSONAL INFORMATION
We have adopted organizational, physical and technical security measures that are in line with the industry standards designed to protect the Personal Information you provide, and to prevent any unauthorized access, disclosure, use, modification, damage or loss of data. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any Personal Information you transmit to us and you understand that any Personal Information that you transfer to us is done at your own risk. If we learn of a security system breach, we will act in a timely fashion in accordance with any applicable law. We may attempt to notify you electronically regarding security, privacy, and administrative issues relating to your use of our Services. We may post a notice on the Services if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive written notice of a data privacy or security breach.
DATA PROTECTION RIGHTS
Data protection laws in your jurisdiction may provide a number of legal rights in relation to the Personal Information that we hold about you and/or your child. Not all data protection laws are the same, so not all of these rights apply in all places. Also, some of these rights are subject to qualifications and limitations, and exercising these rights may impact the Services and products that we provide to you. However, we recognize that Personal Information belongs to you alone, and that enables you to control how we use it.
Your rights may include:
Parents or guardians may exercise any rights that their child may have in relation to their Personal Information. For example, at any time, parents or guardians may review their child’s Personal Information, direct us to delete their child’s Personal Information, and may refuse to allow any further collection or use of the child’s Personal Information (in all cases, subject to the requirements and restrictions set out in applicable law). Parents and guardians may also agree to the collection and use of their child’s Personal Information, but still not allow disclosure to third parties unless it’s part of the requested service. Please keep in mind that a request to delete records may lead to a termination of Services. In some jurisdictions, children may also exercise their data protection rights directly.
You can exercise your (and/or your child’s) rights by contacting us using the details set out in the “Contacting Us” section below. We may need to confirm your identity before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request. We will respond all valid requests within a reasonable time in accordance with applicable laws. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any Personal Information.
Your California Privacy Rights
California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below and put “Shine the Light” in the subject line of your request.
In addition to the above mentioned rights, from January 1, 2020, you may be entitled to the below rights:
California residents can exercise their rights by contacting us using the details set out in the “Contacting Us” section below. Whenever feasible for verification, we will match the identifying information provided to the Personal Information already maintained by us. If, however, we cannot verify the requester’s identity from the information already maintained by us, we may request additional information.
California residents may also designate an authorized agent to make a request on their behalf. Such authorized agent must be registered with the California Secretary of State and must have permission to submit such requests. We may deny a request from an agent that does not submit proof that they have been authorized to act on behalf of a California resident.
HOW WE RESPOND TO DO NOT TRACK SIGNALS
The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.
CHANGES TO THE PRIVACY NOTICE
We reserve the right to change or amend our Privacy Notice from time to time to address new issues of privacy and information security and to reflect changes to our Services or business practices. Any new change and/or amendments will be noted on this page. We will also update the Last Updated date above. If we make material changes to our Privacy Notice, we will notify you by prominently posting the changes on our Services or by using the contact information we have on file about you.
CONTACTING US
If you would like further information on the collection, use, disclosure, transfer or processing of Personal Data or the exercise of any of the rights listed above, please contact us through the specific channels indicated below.
For user residing in the EEA, our representative in the European Economic Area is TCT Mobile Europe, which has its offices at Le Capitole, 55 rue des Champs-Pierreux, 92000 Nanterre, France. Please contact us by privacy_dpo@jxhssl.com.
For users residing in the UK, our representative in the United Kingdom is TCT Mobile UK Limited, which has its offices at 10 Finsbury Square, London EC2A 1AF, England. Please contact us by privacy_dpo@jxhssl.com.
For users residing in India, our Grievance Officer in India is Mr. Sudhansu Sahu and can be reached at privacyqueryindia@jxhssl.com.
For users residing in the United States, 南宫ng·28 subsidiary is TCT Mobile (US) Inc. whose related addresses and contacts is indicated below:
TCT Mobile, Inc.
25 Edelman, suite 200
Irvine, CA 92618
Contact us by sending an email to privacy.na@jxhssl.com, or by calling our toll-free number at 1-855-368-0829
For users residing in Brazil, 南宫ng·28’s representative is Semp 南宫ng·28 Mobilidade Ltda. (Tax Payer Number 08.649.664/0001-98, whose address and related contact is indicated below:
Semp 南宫ng·28 Mobilidade Ltda
Avenida Arnaldo Rojek, nº 01, Rua 5, Galpão H - parte 1, Altos de Jordanésia, Cajamar/SP - CEP 07.786-900
Contact us by sending an email to privacidade@sempjxhssl.com.br or by calling +55 (11) 3004-7570.
For users residing in China and other regions of the world (including Brazil, EEA, UK and US), the “data controller”/“business” is 南宫ng·28 Communication Technology Holdings Limited, with its address at 10F Building F4, 南宫ng·28 Communication Technology Building, International E-City, No. 1001 Zhongshanyuan Road, Xili Street, Nanshan District, Shenzhen City, Guangdong Province, China.