Bekids Privacy Policy

 Effective date: Jul 01 2022

Preamble

Bekids Products and/or Services provided by iHuman Online Limited

 (registered address: 9/F., MW Tower, No.111 Bonham Strand. Sheung Wan, Hong Kong, 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 our official websites (hereinafter referred to as "Official Website") and Bekids 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. Bekids 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 Bekids Products and/or Services are governed by this Policy. Bekids 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 Bekids 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.

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 Terms of Service. If You do not acknowledge and agree to this Policy, You shall stop using Bekids 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 Terms of Service, unless explicitly stated otherwise. In addition, we set out interpretations of capitalized terms in Section 11 below as definition of key words.

3. Pursuant to the Applicable Laws, You confirm and undertake that You are the parent of the Child who uses Bekids Products and/or Services or an adult User who is at/over the legal age threshold in your jurisdiction or above.

4. 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 Bekids 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 Bekids 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 CONTENTS

I GENERAL TERMS

1 How We collect and use personal information about You and/or Your Child

2 How We use cookies/similar technologies

3 How We subcontract the processing, share, transfer or publicly disclose 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

9 How We update this Policy

10 How to contact Us

11 Definition of Key Words

II SPECIAL TERMS——JURISDICTION SCHEDULE

Speical Terms for U.S.A Users

Special Terms for EU Users

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.

I GENERAL TERMS

1 How We collect and use personal information about You and/or Your Child

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

When You register an account in any Bekids Children App as a new User, 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 Bekids Children Apps, but You may browse the contents that are available to unregistered Users. After We obtained Your verifiable consent, You need to create a password as required to log in to Bekids 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.

Please note: When You create an account in any App of our company or its affiliates (such as AHA WORLD LIMITED, Tianjin Hongen Perfect Future Education Technology Co., Ltd.), the same login credentials can be used across all Apps of our company or its affiliates.

1.1.1.2 Profile creation

To ensure that You and/or Your Child have a favorable experience with Bekids Children Apps, You can, but are not required to, provide profile photo, nickname, date of birth or age, gender, height, weight, 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 other 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.

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 Bekids 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 other app functions.

We may, to the extent permitted by the Applicable Laws, also collect other personal information in connection with, if any, your voluntary participation in our surveys and other activities.

1.1.1.6 Promotion

In order to better provide services to You and/or Your Child, We may cross promote our other products or the products on our affiliated companies (such as AHA WORLD LIMITED, Tianjin Hongen Perfect Future Education Technology Co., Ltd.) through App notifications, emails, etc.

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.

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, usage history, duration of use and order information with your account for the purpose of data analysis, so as to recommend Bekids 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 Bekids 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 Bekids 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. 

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 Bekids 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 Bekids Children Apps, optimize Bekids 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 Bekids 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 Bekids 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

 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 Bekids 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.

1.4 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 Bekids Products and/or Services, such as troubleshooting, discovering and resolving issues in relation with any Bekids Products and/or Services; or

1.4.10 Other circumstances specified or permitted under the Applicable Laws.

How We use cookies/similar technologies

This cookie section describes the cookies and similar technologies that will be applied in Bekids Children Apps provided by us. 

A cookie is a data file, which often includes a unique identifier, that is sent to your browser from a web server and is then stored on the hard drive of the device you are using to browse the app.

We only use strictly necessary cookies. These cookies are essential in order to enable you to move around the app and use its features, such as remember your log-in status and accessing secure areas of the app. Without these cookies, services you have asked for cannot be provided. These cookies do not contain any personal information. We use the following strictly necessary cookies on our products:

Name of the cookie

The duration of the operation of cookie

 

Purpose

User id

1 month

We use these cookies to remember Your id and keep You logged in when you use Bekids Children Apps. these cookies to  remember Your id and keep You logged in when you use Bekids Children Apps. 

token

1 month

We use these cookies to remember Your token and keep You logged in when you use Bekids Children Apps.

How We subcontract the processing, share, transfer or publicly disclose personal information about You and/or Your Child

3.1 Subcontract the processing

To provide You and/or Your Child with integral Bekids 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 data processing agreement 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 Bekids 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 Bekids 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 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 Bekids 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 Bekids 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 Bekids 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 terms of service, 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 Bekids 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 Bekids Products and/or Services is available here. Please direct Your inquiries about any operator's privacy practices and use of Children's information to iHuman Online Limited 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 iHuman Online Limited 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.

How You can manage personal information about You and/or Your Child

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 Bekids Children Apps, 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" 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 Bekids 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", and then click "Personal Information Management" - "Manage Personal Information about You and/or Your Child" - "Delete Personal Information about You and/or Your Child" 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", 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 Bekids 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", 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 Bekids 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, You may go to "Legal Terms and Privacy Center", 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. 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

4.6.1 We may provide personalized push. If You do not want to receive personalized push, You may request to unsubscribe the personalized push service by contacting Us through the contact information provided in Section 10 hereunder.

4.6.2  Please note that We may send You notices or announcements about Bekids Products and/or Services, which fall outside the personalized push services, for example, when necessary, where a service is suspended for repair or when we invite you to a voluntary survey by email.

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 privacy@bekids.com.

How We keep personal information about You and/or Your Child secure

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.

How We retain personal information about You and/or Your Child

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.

How We protect children's personal information

7.1 Please note that pursuant to the Applicable Laws, You confirm and undertake that You are the parent of the Child who uses Bekids 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 Bekids Products and/or Services and We will not collect personal information about You and/or Your Child.

7.2 Please note that We will not directly sell any Bekids Products and/or Services to a Child, and You shall keep safe of Your payment information to prevent misuse by Your Child. 

You can also find more details in Our Bekids Guideline for Children’s Privacy Protection.

8 International transfer of personal information about You and/or Your Child

8.1 In order to be able to provide Bekids Products and/or Services, personal information about You and/or Your Child will be transferred and shared globally, among Bekids 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 Bekids Products and/or Services in such specific jurisdictions.

How We update this Policy

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 Bekids 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 PolicyIf You have any questions about fees when cancelling account, please read Terms of Service.

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 How to contact Us

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 Bekids Products and/or Services, You may contact Us by: (i) logging into Bekids Children Apps to submit online complaints and feedbacks; (ii) sending an email to: privacy@bekids.com; or (iii) other contact information that We make available.

10.2 Usually, 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 Definition of Key Words

11.1 We, Our, Us or Bekids: refers to iHuman Online Limited.

11.2 Affiliated Company: refers to a subsidiary company or other affiliated enterprises within the scope of the consolidated fiscal statement of iHuman Online Limited, and the company/enterprise has or will have a relationship with iHuman Online Limited, 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 iHuman Online Limited 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 Bekids 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 Bekids Products and/or Services: refer to the following products and/or services Bekids provides to You and/or Your Child: (1) products and/or services of Bekids Children Apps provided through mobile client; (2) the Official Websites which provide introduction and ways to download products and/or services of Bekids Children Apps; (3) any software relating to the products and/or services described in (1) and (2) ; (4) other Bekids Children education products and/or services provided to You and/or Your Child by Bekids from time to time.

11.7 Bekids Children Apps: refers to the App developed by iHuman Online Limited.

11.8 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.

11.9 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. For the avoidance of doubt, personal information includes but is not limited to sensitive personal information.

11.10 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.

11.11 Anonymize: refers to the process in which personal information is processed in a technical manner to make You unidentifiable and the processed information cannot be restored.

11.12 Device: refers to the equipment that may be used to access Bekids Products and/or Services, such as tablet PC, smartphone.

II SPECIAL TERMS——JURISDICTION SCHEDULE

Special Terms for U.S.A Users

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 Bekids Products and/or Services;

1.5.2 to send You notices regarding Bekids 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 Bekids 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.

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 Bekids 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.

Special Terms for EU Users

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

1.1.1.1 Registration, login, and verification

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 Bekids in providing Bekids Products and/or Services online, in case of Your Child’s information)

1.1.1.2 Profile creation

Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of Bekids in providing Bekids Products and/or Services online, in case of Your and Your Child’s information)

1.1.1.3 Fun study

Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of Bekids in providing Bekids 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 Bekids in providing Bekids Products and/or Services online, in case of Your and/or Your Child’s information)

1.1.1.5 Customer service or complaint

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 Bekids in providing Bekids Products and/or Services online in case of Your Child’s information) 

Where processing is not necessary for the survey activities or other legal basis are inapplicable, your consent to such processing will be requested.

1.1.2.1 Personalized display feature

 Art. 6 para. 1 lit. f GDPR (necessary for the purpose of fulfilling the legitimate interests of Bekids in providing Bekids 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 Bekids in providing Bekids 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 Bekids in providing Bekids 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 Bekids in providing Bekids 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.

2 How we use cookies/similar technologies

Section 2 shall be added:

The strictly necessary cookies we use are not subject to your consent.

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 objectIn 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 Bekids 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 Bekids 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.

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 Bekids 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 PolicyIf You have any questions about fees when cancelling account, please read Terms of Service.

10. How to contact Us

Followed by Section 10.3, an additional section set forth as below shall be added:

10.4 To comply with article 27 of the GDPR, We have appointed a representative which can accept communications on behalf of Bekids, in relation to personal data processing activities falling within the scope of the GDPR. If You wish to contact them, their details are as follows:

EU Representative:

Datarologie

2nd Floor, Avenue Marnix 23,

1000 Bruxelles, Belgium

iHuman.EURep@datarologie.com

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:

11.8 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:

11.10 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 11.12, additional three sections set forth as below shall be added:

11.13 EU: refers to the European Union.

11.14 EEA: refers to the European Economic Area, namely the European Member States along with Iceland, Liechtenstein and Norway.