Update date: September 13, 2022
Effectiveness date: September 13, 2022
Clemen Privacy Policy for Children
Clemen is committed to protecting personal information of children who use our products or services. The Privacy Policy for Children (hereinafter referred to as “this Policy”) and the Clemen Privacy Policy are designed to explain to the guardians (hereinafter referred to as “you”) and the children how we collect, use, store and process children’s personal information, as well as the means that we provide to you and the children to access, correct, delete and protect such information. Unless otherwise agreed upon, the terms and acronyms used herein have the same meanings as those in the Clemen User Service Agreement and the Clemen Privacy Policy.
Special instructions for children’s guardians:
If you are a guardian of a child user, please read carefully and choose whether or not to agree to this Policy. We hope to ask you to work with us to protect the child’s personal information, educate and guide the child to enhance his/her awareness and ability to protect personal information and instruct, remind and require him/her not to provide any personal information to any providers of online products and service without your consent.
Special instructions for children:
If you are a minor under the age of 14, you need to read this Policy carefully with your guardian and use our products or services or provide us with information upon the consent of your guardian.
Please carefully read and fully understand the Clemen Privacy Policy and this Policy and then choose whether or not to agree to the related privacy policy and whether or not to agree to the use of our products or services by you and the child under your guardianship. If you do not agree with any content of the related privacy policy and this Policy or do not agree to provide the information necessary for the service, it may cause some of our products or services to fail to run normally, or fail to achieve the service effect that we intend to achieve; in this case, you and the child under your guardianship may be unable to use some of our products, services or related specific business functions normally.
By clicking on “Agree,” you agree to our collection, use and processing of your information and that of the child under your guardianship in accordance with the Clemen Privacy Policy and this Policy. For the important clauses in this Policy that are (possibly) closely related to the rights and interests of yours and the child under your guardianship, we have used bold fonts to remind you. Please pay special attention to them.
If you have any questions or claims or other issues related to personal information when reading this Policy, you may resort to a dedicated feedback channel that we provide. Please refer to the “Contact Us” section herein for details.
I. Scope of applicability of this Policy
II. How we collect and use children’s personal information
III. Circumstances where children’s personal information is shared, transferred and disclosed
IV. How to store children’s personal information
V. How to manage children’s personal information
VI. Contact us
I. Scope of applicability of this Policy
This Policy only applies to our products or services specifically for children under the age of 14, products or services with functional sections specifically for children under the age of 14 or products or services that require the user to enter the birthday, age and other information that can identify the user’s age. For any products or services that cannot identify or actively identify the user’s age, the Clemen Privacy Policy shall be applied/referred to as the case may be. If this Policy is applicable, in case of any inconsistency between this Policy and any terms in the Clemen Privacy Policy, this Policy shall prevail.
Special note:In most cases, we cannot identify whether the specific personal information of the person that uses our products and/or services belongs to any children. For instance, we are unable to judge whether the collected and processed equipment information, personal Internet records and other personal information that do not have obvious age identification features is the children’s personal information. In order to better protect children’s personal information, we will process and protect the personal information identified as your child’s information that is collected during your use/your child’s use of our products and/or services in accordance with this Policy.
II. How we collect and use children’s information
Clemen strictly abides by provisions under the laws and regulations and agreements with users and collects the following personal information of you and the children under your guardianship according to the specific situation of the products or services selected by the users:
For our products and services or some functional sections of products and services specifically for children under the age of 14 or products or services that require the user to input birthday, age information and other products or services that can identify the user’s age, such as registration or use of such products or services, We will require the user to provide personal birthday information, to identify whether or not the user is a child under the age of 14 and a child is allowed to continue using the related product or services only upon the consent of the guardian in accordance with the laws and regulations.
When a child uses our products or services, we will collect and use related information. For details, please refer to the “How we collect and use your personal information” section of the Clemen Privacy Policy for details about how we collect and use other personal information of children.
If we need to collect the personal information of you or the children under your guardianship beyond the above scope of collection, we will inform you again and obtain your consent.
Please understand that you may choose whether or not to fill in or provide us with specific information. If you do not fill in or provide some specific information, however, it may cause some of our products or services to fail to run normally or fail to achieve the service effect that we intend to achieve; in this case, you and the child under your guardianship may be unable to normally use some of our products, services or related specific business functions.
III. Circumstances where children’s personal information is shared, transferred and disclosed
We strictly limit the sharing, transfer and disclosure of children’s personal information in accordance with laws and regulations.
Generally, Clemen does not share children’s personal information with any third parties. We may share children’s personal information with third parties only with the prior consent of guardians.
We will share some personal information of a child (such as the child’s user name, account number and password, and transaction contents of the child user in some of our products and services) with the guardian, who can access and manage related personal information.
For external processing only, we may share children’s personal information with third-party partners (third-party service providers, contractors, agents, application developers, etc., such as communication service providers who send emails or push notifications on our behalf), and allow them to process the above information for us in accordance with our Privacy Policy and related privacy and security policies.
If we engage a third party with the processing of children’s personal information, we will carry out a security assessment on the engaged party and the service, etc., sign an engagement agreement, and require that the engaged party’s processing behavior should not exceed the scope of our authorization. We engage a third party to process children’s personal information mainly for the following purposes:
1.To provide children with our services;
2.To achieve the purpose set forth in the “How we collect and use children’s personal information” section;
3.To perform our obligations and exercise our rights under the Clemen Privacy Policy and this Policy;
4.To understand, maintain and improve our services.
If we share any information of you and the child with any of the foregoing third parties, we will conduct a security assessment and take encryption, anonymization, de-identification and other means to ensure the security of your information and that of the child.
With the continuous development of our business, when merger, acquisition, asset transfer or any other transaction leads to the transfer of any personal information of you and the child to any third party, we will inform you of the relevant situation through push notifications, announcements, etc., to continue protecting the personal information in accordance with laws and regulations as well as any standard not lower than that required under this Policy or require the new manager to continue protecting the personal information of you and the child.
We may disclose to and share with our partners information that does not contain any identifying content upon statistical processing, to understand how users use our services or let the public understand the overall usage trend of our services.
Generally speaking, we do not allow any disclosure of children’s personal information to any third parties, but we may disclose children’s personal information for the following purposes:
1. To comply with relevant laws and regulations and other rules;
2. To comply with court judgments, rulings or other legal proceedings;
3. To comply with the requirements of competent government authorities or other legally authorized organizations;
4. Where we have reasons to believe that we need to comply with the laws, regulations and other provisions;
5. For reasonable and necessary purposes for the implementation of related service agreements or this Policy, the maintenance of social and public interests and the protection of the personal and property safety or other legitimate rights and interests of our customers, us and our affiliates, other users or employees.
IV. How to store children’s personal information
Clemen will take encryption and other technical measures to store children’s personal information to ensure information security. The storage of children’s personal information by Clemen does not exceed the period necessary to achieve the purpose of its collection and use. Please review the “How we store and protect your personal information” section of the Clemen Privacy Policy for details about how we store and protect children’s personal information.
When our products or services stop operating or when the storage period of your and the child’s personal information expires, we will notify you and the child by push notifications, announcements and other means and delete or anonymize your and the child’s personal information within a reasonable period of time.
V. How to manage children’s personal information
During the use of Clemen products or services by a child user, in order to make it easier for you and the child to access, correct and delete related personal information, we provide you with the corresponding operating settings in the product design and you may also use the contact information provided by us for feedback and consultation. We will contact you in a timely manner upon verification of your feedback. Please understand that during the verification, we may require you to provide personal information such as the child’s account number, the child’s date of birth and the contact information, so that we can continue responding to your needs upon completion of the identity verification and verification of the problem.
5.1 How to access children’s personal information
You and the child under your guardianship may view the personal information provided or generated by the child user when using our products or services, including but not limited to the user name, password, avatar, nickname, gender, content posted by the owner at your own free will, etc.
5.2 How to correct children’s personal information
When you and the child under your guardianship become aware of any errors in the personal information of the child that we collect, use and process, you may contact us to correct it. We will take measures in a timely manner to correct it upon completion of the identity authentication and verification of the problem.
5.3 How to delete children’s personal information
You and the child under your guardianship may request us to delete the personal information of the child that we collect, use and process under the following circumstances. We will take measures in a timely manner to delete it upon completion of the identity authentication and verification of the problem.
1.Where we violate provisions of laws or administrative regulations or the agreement between both parties to collect, store, use, transfer and disclose the child’s personal information;
2.Where we collect, store, use, transfer or disclose the child’s personal information beyond the scope of the purpose or the necessary period;
3.Where you withdraw your consent;
4.Where you or the child under your guardianship terminates the use of the product or service by logging out or other means.
However, please note that if you and the child under your guardianship request us to delete specific personal information of the child, so that the child user may be unable to continue using our products and services or some specific business functions in the products and services. If you find that your child’s personal information has been collected without your prior consent, please contact us promptly and we will try to delete the related data as soon as possible.
VI. How to contact us
If you have any questions, comments or suggestions about this Privacy Policy or any questions related to the security of users’ personal information, you may send a written letter (address: 20F, Building 19, 1515 Gumei Road, Xuhui District, Shanghai; zip code: 200233) or an email (support@clemenmusic.com) to us and we will reply upon receipt of the letter and verification of your user identity.
Clemen Software (Shanghai) Co.,Ltd