Oohla Children's Personal Information Protection Policy

Effective Date: July 28, 2021

In order to effectively protect the personal information of Oohla minors, Oohla (according to current regulations and policies, has formulated this "Oohla Children's Personal Information Protection Policy" ("this Policy").

This policy is Oohla's special functional terms for the protection of minors' personal information. For the protection of personal information not specified in this policy, the "Oohla Personal Information Protection Policy" shall apply. This policy will describe Oohla's policies and practices regarding the collection, storage, use, transfer, disclosure and protection of children's personal information under the youth account. Please be sure to read this policy carefully, and choose whether to accept the content of this policy and open a youth account on the premise of fully understanding the entire content of this policy.

If you are a minor under the age of 14, please ensure that you read this policy accompanied by a guardian, and the guardian agrees to this policy and opens a youth account; if you are the guardian of a minor under the age of 18, please confirm that you are The legal guardian of the child subject ("child") to whom the child's personal information you intend to submit belongs, otherwise you have no right to agree to this policy. If you do not agree with any of the terms of this policy, you should immediately stop using the Youth Account.

In order to make this policy clearer and easier to read, we have highlighted the terms that are of great concern to you or children's rights, please read them carefully.

If you have any questions about this policy or matters related to the protection of children's personal information, you may contact us at any time through the means provided in the "Contact Us" section of this policy.

This policy will help you understand the following:


2. Collection of Children's Personal Information

3. Notification of Cookies and Related Technologies

4. Use of Children's Personal Information

5. Protection and security measures for children's personal information

6. Where children's personal information is stored, for how long, and how it will be processed after expiration

7. Sharing, Transfer and Public Disclosure of Children's Personal Information

8. Management of Children's Personal Information

9. How to modify this policy

10. Contact us

Conditions to which this policy applies

1.1. How Oohla identifies children's personal information

1.1.1. The term “children” in this policy refers to minors under the age of 18. You should understand that we can only reasonably determine whether a user is a minor based on the information submitted by the user or the user's statement or statement, if and only when we reasonably determine that a user is a minor, the personal information we collect through the youth account Information is considered children's personal information. The rules of this Policy apply to the collection, storage, use, transfer, disclosure and protection of the information we collect if and only if the information we collect is deemed to be children's personal information.

1.1.2. At present, we only recognize the user of the youth account you create as a child when you register for an Oohla youth account and the child information you fill in shows that the child is under 14 years old.

At the same time, the personal information of children under the age of 14 is personal sensitive information. Oohla's processing of personal information of children under the age of 14 will be carried out in accordance with relevant laws and regulations on sensitive personal information and relevant national standards and requirements.

1.2. Scope of application of this policy This policy applies to all services provided by Oohla to children under a youth account, whether the service is obtained through a computer device, mobile terminal or other device.

Collection of Children's Personal Information

2.1. You know and agree that Oohla will record the relevant personal information of the child, such as account number, password, etc., when you open a youth account and the child uses the services provided by Oohla through the youth account. the basis for providing services.

2.2. Before you open a youth account, we will guide you to read this policy and obtain relevant personal information of children on the basis of your acceptance of this policy. If you do not agree to provide children's relevant personal information, children will not be able to use all or part of the functions and services of the youth account, or will not be able to obtain more personalized functions, or unable to participate in certain activities, or unable to receive our notices, etc.

2.3. Children's personal information will only be collected under the following circumstances under the youth account:

2.3.1. When you open a youth account, we will record the relevant children's personal information you provide, including account name, date of birth, and child's gender. We collect this information to help you open an Oohla Youth account. If you refuse to provide the above information, you will not be able to open a youth account.

2.3.2. When children post or forward Oohla, leave comments or send private messages under the youth account, we will collect the content (including text, pictures or videos) posted by children. If a child chooses to tag a geographic location when publishing Oohla, we will collect the child's location information. If you refuse to provide the child's location information, the child will not be able to tag the location information on the published content.

2.3.3. When a child uses the search service provided by Oohla, we will collect the child's query keyword information, search history, and device information. In order to provide an efficient search service, some of this information will be temporarily stored in the child's local storage. among the equipment. Here, you need to pay attention that the child's keyword information cannot identify the child's personal identity alone, it does not belong to the child's personal information, so we have the right to use it for other purposes; only when the child's search keywords When the information is linked to other information of the child and can be used to identify the child's personal identity, during the combined use, we will use the child's search keyword information as the child's personal information, together with the child's search history, in accordance with this policy. Handling and Protection.

2.3.4. When children participate in Oohla's related marketing activities, we may collect children's names, school names, mailing addresses, contact information, and bank account information. This information is the basis for a child to receive a transfer or gift, and if you refuse to provide this information, we will not be able to transfer or issue a gift to that child.

2.3.5. In order to enable children to obtain relevant information about their city, we will collect the specific location information of children's devices. No other information about the children's device will be included in the information we collect. If you refuse to provide the above information, you will not be able to obtain the above related services.

2.4. In order to achieve effective protection of children's information, we will de-identify the collected children's information to protect the security of children's information. I hope you understand and accept that, on the premise of de-identifying the collected children's information and not disclosing the children's personal information, Oohla has the right to de-identify the children's personal information that cannot be identified and cannot be recovered. Analyzed and used commercially.

2.5. When a child logs in to a third-party application through Oohla, the third party may obtain the child's personal nickname, avatar and other information through Oohla. If you refuse to provide such information, children will not be able to use the services provided by this third party. For details on the collection and use of user information by third-party SDKs connected to the Oohla client, please refer to the List of Third-Party SDKs Accessed by Oohla.

2.6. When it involves national security, public interest, related activities related to criminal investigation, or involves the safety of children or other people's life and property but cannot obtain your timely authorization under special circumstances, and can obtain it from other legal and public channels or in legal Under other circumstances stipulated by regulations, Oohla may collect children's personal information without your consent or authorization.

2.7. When children use Mini Programs in Oohla, we may obtain necessary children's personal information from Mini Program developers and their technical service providers for the purpose of providing technical support for docking (for example: device information, operation behavior log information) ), which involves children’s personal information, we will obtain your separate authorization. If you refuse us to collect relevant personal information, it may result in the failure of the overall function or part of the function of the Mini Program. When children use Mini Program services through Oohla, Mini Program developers and technical service providers will collect and use children's personal information in accordance with their privacy protection policies. It is recommended that you read and confirm your understanding of the relevant agreements before accepting relevant services.

2.8. If Oohla needs to obtain children's personal information in addition to the above scenarios, we will obtain your consent separately, and fully explain the application scenarios and the purpose and scope of obtaining children's information to you before obtaining your authorization and consent.

Notification of Cookies and Related Technologies

3.1. Cookies and related technologies can help websites identify registered users and count the number of users. They are usually used by websites to determine whether users who have completed registration have logged in. We use cookies and related technologies to achieve the following functions or services:

3.1.1. Ensure the safe and efficient operation of products or services. We may set authentication and security cookies in order to confirm that you are securely logged in to the Services or have experienced theft, fraud and other wrongdoing. These technologies also help us improve the efficiency of our services and improve login and responsiveness.

3.1.2. Simplify your operation steps. Using such technologies can help you save the steps and processes of repeatedly filling in personal information and entering search content, and help you get an easier access experience.

3.2. At the same time, if you do not want children's personal information to remain in cookies, you can configure the browser of children's devices: select "reject cookies" or "notify you when a website sends cookies". Given that our services are implemented by supporting cookies, after completing the operation of turning off cookies, children's access to Oohla may be affected or their services may not be fully available. When you do not disable cookies, you may be prompted, such as whether to retain user information the next time you enter this site, in order to simplify login procedures (such as automatic login).

Use of Children's Personal Information

In order to provide better services or products to children, Oohla will use children's personal information in the following situations:

(1) According to the requirements of relevant laws and regulations;

(2) In accordance with your authorization.

Protection and security measures for children's personal information

5.1. Oohla will make every reasonable effort to protect the children's personal information it obtains in accordance with the relevant laws and regulations, and will protect children's personal information by specialized data security departments. In order to prevent children's personal information from being illegally accessed, copied, modified, transmitted, lost, destroyed, processed or used in unexpected and unauthorized circumstances, Oohla has and will continue to take the following measures to protect children's personal information:

5.1.1. Our network services adopt encryption technologies such as transport layer security policies, and provide browsing services through https and other methods to ensure the safety of minors' data during transmission.

5.1.2. Ensure information security by strictly storing children's information in a manner that meets legal requirements.

5.1.3. When using children's personal information, such as children's personal information display, children's personal information associated calculation, we will use a variety of data desensitization technologies including content replacement, encryption desensitization, etc. to enhance the security of children's personal information in use .

5.1.4. Establish a strict data use and access system, adopt strict data access authority control and multiple identity authentication technology to protect children's personal information and prevent children's data from being used in violation of regulations.

5.1.5. Implement special data and technical security audits, and take multiple measures of log audits and behavior audits.

5.2. Other security measures taken to protect children's personal information

5.2.1. Manage and regulate the storage and use of children's personal information by establishing a data classification and grading system, data security management specifications, and data security development specifications.

5.2.2. Establish a special data security department, an organization responsible for security emergency response, to promote and ensure the security of children's personal information.

5.2.3. Strengthen safety awareness. We also conduct safety and personal information protection training courses to enhance employees' awareness of the importance of protecting children's personal information.

5.3. Notification of Children's Personal Information Security Incidents

5.3.1. In the event of security incidents such as leakage, damage, or loss of children's personal information, Oohla will immediately initiate an emergency response plan, take effective remedial measures, and report to the corresponding competent authority as soon as possible;

5.3.2. We will send notifications to all users to remind them to change their passwords, or reach users' knowledge through various means such as phone calls and text messages, and publicize them on the Oohla public operation platform to prevent data leakage.

5.3.3. Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, Oohla still cannot guarantee the information security of children's personal information when they are communicated through unsafe channels. Therefore, you should educate and guide children to enhance their awareness and ability to protect personal information, and take active measures to ensure the security of children's personal information, such as: regularly changing the passwords of youth accounts, and not disclosing children's personal information such as youth account passwords to others.

5.3.4. You know: the personal information protection measures provided by Oohla for youth accounts are only applicable to the Oohla platform. Once children leave Oohla and browse or use other websites, services and content resources, Oohla has no ability and obligation to protect children in Oohla. Any personal information submitted to a website other than that, whether or not a child's access to or browsing the above website is based on a link or guidance from Oohla.

5.3.5. There are always various risks of information leakage in the network environment. When unexpected events, force majeure and other circumstances lead to the leakage of children's personal information, Oohla will try its best to control the situation and inform you of the incident in a timely manner in accordance with relevant laws and regulations. Content and impact, measures taken or to be taken, recommendations to reduce risks, etc.

Where children's personal information is stored, for how long and after expiration

6.1. Oohla will take appropriate security measures and technical means to store and protect children's personal information to prevent loss, misuse, unauthorized access or leakage, tampering or destruction. Children's personal information is stored in password-controlled servers located in China, and access is restricted. When you need cross-border information transfer services, Oohla will default that your information will continue to be stored on servers in China.

6.2.Oohla will set different storage periods according to different levels of personal information, and the storage period will be strictly in accordance with laws and relevant regulations. After the statutory retention period is exceeded, we will delete or anonymize the stored personal information of children.

6.3. If you cancel your youth account or Oohla stops operating, we will stop the collection and processing of children's personal information, and delete the collected children's personal information after meeting the storage period stipulated by law.

6.4. We only allow Oohla employees who have a need to know the information to access children's personal information and require them to fulfill corresponding confidentiality obligations.

6.5. If Oohla involves the transfer of children's personal information overseas, we will strictly abide by the relevant laws and regulations, and will clearly inform you and obtain your consent.

Entrusted Processing, Sharing, Transfer and Public Disclosure of Children's Personal Information

7.1. We treat children's personal information with a high degree of diligence.

7.2. We only entrust a third party to process children's personal information within the scope of your authorization or as required by laws and administrative regulations.

7.3. We will not share or transfer identifiable children's personal information to third parties unless with your prior express consent or as required by laws and administrative regulations. We may share and transfer the de-identified personal information of children, and ensure that the sharing third party cannot re-identify or associate the natural person subject of such information. Under certain conditions, we may share children's personal information with third parties, but we will only share necessary personal information, and third parties are bound by the purpose of collection and processing stated in this policy. We will require third parties to take protective measures for children's personal information and strictly abide by relevant laws, regulations and regulatory requirements. If a third party wants to change the purpose of processing children's personal information, it will ask for your express consent again.

7.4. We will not publicly disclose children's personal information unless it is required to be disclosed by laws and administrative regulations or can be disclosed according to an agreement with you.

7.5. You agree that we share information with the following categories of third-party authorized partners:

7.5.1. We may share children's personal information with business partners for certain functions. Some of our services will be provided by authorized partners. We may share certain personal information of children with our partners to provide better customer service and user experience. We share this information only for the purposes stated in this policy. For example, when third-party software, device systems are combined with Oohla products or services to provide children with location-based services, "Oohla" may collect children's location information and device information (such as Hardware model, operating system version number, International Mobile Equipment Identity (IMEI), network device hardware address (MAC)), which will be provided to the aforementioned partners after de-identification processing. In special circumstances, it will also include the information you filled out separately. Contact information. If you refuse the collection and use of such information, you need to set it in the device system or close the software that provides services. Oohla cannot automatically or manually set and close related services. We will only share children's personal information for legitimate, legitimate, necessary, specific and explicit purposes, and only share children's personal information necessary to provide services. Our partners are not authorized to use shared children's personal information for any other purpose.

7.5.2. Under the youth account, Oohla will not recommend personalized advertisements for children. Advertising Oohla is only displayed to youth accounts through the basic mechanism of information flow when guardian accounts, other youth accounts and whitelisted accounts forward, like, privately message or publish them.

7.5.3. To help children participate in marketing promotions, we may share children's personal information with third parties. When children choose to participate in relevant marketing activities, you may need to provide us with the child's name, mailing address, contact information, and bank account number according to the needs of the activity. With your express consent, we will share the above information with third parties so that we can entrust third parties to provide services to children in a timely manner.

7.6. For companies, organizations and individuals with whom we share personal information, we will conduct a personal information security impact assessment for them in advance, and sign strict confidentiality agreements with them, requiring them to follow our instructions, this policy and any other related confidentiality. and security measures to handle children's personal information.

7.7. As our business continues to develop, we and our affiliates may conduct mergers, acquisitions, asset transfers or similar transactions, and children's personal information may be transferred as part of such transactions. Before notifying you, we will continue to protect or require new controllers to continue to protect children's personal information in accordance with laws and regulations and standards no lower than those required by this policy, or delete or anonymize at your request.

7.8. Oohla will not disclose (including sharing, transfer, public disclosure, etc.) children's personal information to any third party without your prior express consent, except in the following cases:

(1) Oohla has obtained your authorization or consent;
(2) You share, transfer or disclose to third parties by yourself;
(3) Those directly related to national security, national defense security, public security, public health, and public interests;
(4) Disclosure or provision in accordance with applicable laws and regulations, the requirements of legal procedures, and mandatory administrative and judicial requirements, or the personal information of children provided to the outside world is directly related to criminal investigation, prosecution, trial and execution of judgments. In the foregoing circumstances, we will provide or disclose children's personal information in accordance with the type and manner of information requested or disclosed. Under the premise of compliance with laws and regulations, when we receive the above request for information disclosure, we will require the requesting party to issue corresponding legal documents, such as subpoenas or investigation letters. We will carefully review all requests to ensure that they have a lawful basis, and the requested data is limited to the data that the administrative and judicial departments have the legal right to obtain for specific investigation purposes;
(5) To the extent permitted by laws and regulations, it is necessary to maintain the legitimate rights and interests of other Oohla users, companies and their affiliates, control the life and property of the company, or maintain the safe and stable operation of products or services, such as finding, preventing, Deal with illegal activities such as fraud and reduce credit risk, etc.; however, this does not include disclosing or providing children's personal information for profit purposes in violation of the commitments made in this policy;
(6) The company files a lawsuit or arbitration against the user in order to safeguard its legitimate rights and interests;
(7) When involving mergers, divisions, acquisitions, asset transfers or similar transactions, if the transfer of children's personal information is involved, the company will require new companies and organizations that hold children's personal information to continue to be bound by this policy, otherwise, Oohla will require the company or organization to obtain your authorization again;
(8) Collecting children's personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
(9) For academic research purposes, or for academic research institutions, when it is necessary to carry out statistical or academic research in the public interest, and when the results of academic research or description are provided externally, the personal information contained in the results shall be de-identified. of;
(10) Other circumstances stipulated by laws and regulations.

7.9. You should understand that in the process of using Oohla services, children can send texts, photos and other information to specific or unspecified people by sending Oohla, messages, etc., which may contain children's personal information. We recommend that you instruct children not to upload personal information such as real portrait photos of themselves when using our products or services. Oohla does not assume relevant legal responsibility for children whose information is known to others because of these voluntary posting and sharing behaviors. At the same time, we also recommend that you provide children's personal information with caution when using our products or services, for example, you share children's photos, videos or other information in the information publishing functions such as comments we provide you, because these voluntarily published, Oohla shall not be held responsible for the relevant personal information being known to others due to the sharing behavior.

Management of Children's Personal Information

8.1. Oohla will always give top priority to the protection of children's personal information. At the same time, Oohla attaches great importance to your concern for children's personal information. After you open a youth account and perform reasonable and necessary identity verification, you and the child can view, modify, and delete the children's personal information you submit to Oohla. In general, you and the child can view, modify, or delete the child's personal information on your personal homepage at any time, or send an email to tousu@staff.weibo.com or follow the instructions on the customer service center webpage (https://kefu.weibo.com/ faqdetail?id=20930).

8.2. You have the right to update or correct children's personal information on your own, or authorize Oohla customer service to update and correct information. Before updating and correcting information, we will first verify your identity, and you can correct and update your information only after verifying your identity.

8.3. If you have comments or suggestions on this policy or its functions related to the collection, use, storage, protection and other functions of children's personal information, you can give feedback or complaints through the Oohla function page or Oohla customer service channels, and Oohla will receive After your comments and suggestions, the feedback information will be replied to you in a timely manner.

8.4. You can prevent Oohla from obtaining children's personal information by closing some functions of Oohla. After closing some functions, we will not be able to provide corresponding services to children.

8.5. You can voluntarily cancel the Oohla youth account. In this case, Oohla will no longer collect children's personal information. You can log out of the youth account through the mobile client. Before you log out of the youth account, Oohla will verify your personal identity, security status, commonly used equipment and other information. The act of cancellation is irreversible. Once you cancel the youth account, Oohla will delete the collected personal information of children after meeting the storage period stipulated by law, and guarantee that such information will not be disclosed. At the same time, children will not be able to access Oohla's services through deactivated youth accounts.

8.6. If we terminate the service or operation, we will notify you at least 30 days in advance, and delete or anonymize the personal information of children after the termination of the service or operation.

How this policy can be modified

9.1. In order to provide you with better service and as our business develops, this policy will be updated from time to time. We will not reduce your rights under the Oohla Children's Personal Information Protection Policy currently in effect without your consent.

9.2. We will issue an updated version on the website and mobile terminal and issue an announcement on the mobile terminal before it takes effect or remind you of the update of the relevant content in other appropriate ways, so that you can keep abreast of Oohla's latest children's personal information protection policy, and ask for it again. with your consent.

9.3. For major changes, we will also provide more prominent notices (we will explain the specific changes to the children's personal information protection policy by means of, but not limited to, emails, text messages, private messages, or special reminders on the browsing page).

9.4. Significant changes referred to in this policy include, but are not limited to:

(1) Significant changes to our service model. Such as the purpose of processing children's personal information, the types of children's personal information processed, and the ways of using children's personal information, etc.;
(2) Significant changes have taken place in our ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
(3) The main objects of children's personal information sharing, transfer or public disclosure have changed;
(4) Significant changes in your rights to participate in the processing of children's personal information and the manner in which they are exercised;
(5) When our responsible department, contact information and complaint channel for handling children's personal information security change;
(6) When the children's personal information security impact assessment report indicates that there is a high risk.

9.5. When the above-mentioned major changes occur, or there are substantial changes in the matters we inform you based on this policy, or we need to use children’s personal information beyond the agreed purpose and scope, we will obtain your consent again.

contact us

10.1. If you have any comments or suggestions on this policy or the collection, use, storage, protection and other functions of children's personal information, you can contact us in the following ways:

10.1.1. @Oohla customer service, contact Oohla customer service via private message, enter the keyword "children's personal information protection", or select "Oohla children's personal information protection policy" from the menu.

10.1.2. Contact email: thousxepon@gmail.com, the content of the email should include name, your comments and suggestions and contact information.

We will solve your problem promptly.