Children's Personal Information Protection Agreement


Published:March 8, 2024
Updated:March 8, 2024
Effective Date:March 8, 2024


In order to effectively protect the personal information of Secret Space child users and optimize user experience, Secret Space (hereinafter referred to as "we", refers to xiaolanmao Co., Ltd.. According to current regulations and policies, this "Secret Space Children's Personal Information Protection Agreement" ("this Policy") is formulated.
This policy will detail Secret Space's policies and measures in collecting, storing, using, transferring, disclosing and protecting children's personal information. 《Secret Space Privacy Policy》 applies to the protection of personal information not specified in this policy. Before you read and agree to this policy, please confirm that you are the legal guardian of the child subject (“child”) whose personal information you intend to submit belongs to, otherwise you have no right to agree to this policy.
In order to make this policy clearer and easier to read, we have highlighted the terms that have a significant relationship with you or children's rights, please read carefully.
If you have any questions about this policy or matters related to the protection of children's personal information, you can contact us at any time through the methods provided in "Contact Us" in this policy.
Special Instructions for Child Custody:
If you are a minor under the age of 14, please invite your guardian to read this policy together and obtain your guardian's consent before using our services or providing us with personal information.
Please read "Secret Space Privacy Policy" and this policy (especially the content in bold font) carefully, and make the choice you think is appropriate after confirming your understanding of our protection and processing rules for personal information. By clicking Agree or entering the verification code representing consent, you agree to our collection, use, storage, sharing, transfer and disclosure of guardian and children under guardianship in accordance with 《Secret Space Privacy Policy》 and this policy.
Please Note: This policy does not apply to products and services independently operated by any third parties. The products and services we provide may contain links to third-party products or services (including websites, applets, or other service forms). The third-party products or services accessed by such links are independently operated by relevant third parties. Before using them, guardians should carefully read the terms and policies of such third-party products or services to understand what data they may collect from children under guardianship and how they may use such data. If guardians and children find that these third-party products or services may be risky, it is recommended to terminate the relevant operations to protect the legitimate rights and interests of children.


1. How do we collect children's information
2. How we use children's information
3. How do we store and protect children's information
4. How do we share, transfer and disclose children's personal information
5. How to access and manage children's information
6. Application and update of this policy
7. How to contact us


1. How do we collect children's information
We will strictly abide by the provisions of laws and regulations and the agreement with users, and collect the following personal information of children according to the specific circumstances of users' selection of products or services:
When children use products or services, the scope of personal information we collect from children is detailed in "Secret Space Privacy Policy".
Please understand that the child-related services we provide are constantly being updated and changed. If we collect children's personal information beyond the scope of "Secret Space Privacy Policy" and this policy, we will separately inform you of the scope, purpose and use of the information collection through page prompts, interaction processes, and agreed methods, and obtain the guardian's consent.

2. How we use children's information
1. In strict accordance with the agreement with users, we use the collected children's information for the following purposes within the scope permitted by laws and regulations:
(1) Provide common gadget services for children;
(2) Other purposes agreed in 《Secret Space Privacy Policy》.
2. When we need to use children's personal information beyond the above scope, we will obtain the guardian's consent again in accordance with the requirements of laws, regulations and national standards.

3. How do we store and protect children's information
1. We will follow the principles of justifiable necessity, informed consent, clear purpose, security, and legal use, strictly follow the requirements of laws and regulations such as the "Regulations on the Protection of Children's Personal Information Network" and the agreement of "Secret Space Privacy Policy", and the storage of children's information will not exceed the period necessary to achieve the purpose of information collection and use, and expires Afterwards, we will delete or anonymize the personal information of children.
2. We have appointed a special person to be responsible for the protection of children's information, control the scope of children's personal information, strictly set information access rights, adopt the principle of minimum sufficient authorization for staff who may come into contact with children's information, record authorization approval and information access, and take technical measuresto avoid illegal copying and downloading of children's personal information.
3. We have formulated an emergency plan for children's information security incidents and regularly carry out emergency drills. In the unfortunate event of a children's information security incident that causes or may cause serious consequences, we will immediately report to the relevant competent authorities in accordance with the requirements of laws and regulations, and promptly inform the children and their guardians of the incident by means of PUSH messages, in-site letters, emails, and text messages. When it is difficult to notify one by one, we will take a reasonable and effective way to issue relevant warning information. If the legitimate rights and interests of children and their guardians are damaged, we will bear corresponding legal responsibilities.

4. How do we share, transfer and disclose children's personal information
1. Share with guardians. Guardians can access and manage the personal information of children under guardianship.
2, 《Secret Space Privacy Policy》 stipulated sharing, transfer and public disclosure. We will obtain the consent of the guardian in accordance with the requirements of laws, regulations and national standards, or confirm that the recipient of the information has obtained the consent of the guardian.
3. Based on "Secret Space Privacy Policy" and the purpose stipulated in this policy, we may entrust affiliated companies or other professional service agencies to process children's information on our behalf. We will conduct a security assessment of the entrusted institution and entrusted behavior, and specify the responsibilities of both parties, processing items, processing period, processing nature and purpose, etc. in the written entrustment agreement, prohibit the entrusted institution from using information beyond the scope of authorization, and require the entrusted company to perform the following obligations according to law:
(1) Process children’s information in accordance with laws, administrative regulations and our requirements;
(2) to assist us in responding to requests from guardians of children;
(3) Take measures to ensure information security, and give us timely feedback in the event of children's information leakage security incidents;
(4) Delete children's information in time when the entrustment relationship is terminated;
(5) Cannot be delegated;
(6) Other children's information protection obligations that should be fulfilled in accordance with the law.

5. How to access and manage children's information
1. During children's use of our services, in order for guardians and children under guardianship to access and manage personal information more conveniently, and at the same time protect the right to withdraw consent and cancel accounts, children under guardianship can follow the guidelines of "Secret Space Privacy Policy" or contact customer service directly. Guardians can guide children under guardianship to operate or contact us to ask us to correct Correction or deletion of children's information.
2. Under the following circumstances, children and their guardianscan contact us to request deletion of the corresponding children's information:
(1) We collect, store, use, transfer, and disclose children's personal information in violation of laws, administrative regulations, or the agreement between the two parties;
(2) Collecting, storing, using, transferring, and disclosing children's information beyond the scope of the purpose or the necessary period;
(3) The child's guardian withdraws his consent;
(4) The child or his guardian terminates the use of the product or service by means of cancellation or other means.

6. Application and update of this policy
1. In order to provide better services, we may update this policy in due course. However, without the explicit consent of children and guardians, we will not reduce their rights under this policy. We will issue an updated version on the Secret Space APP and remind children and guardians of relevant content updates through website announcements or other appropriate methods before it becomes effective.
2. For major changes, we will also provide more noticeable notices to children and their guardians. We will explain the specific changes in the rules through emails, text messages, PUSH pushes, in-site letters, or special reminders on the browsing page. In order for children and their guardians to receive notifications in a timely manner, it is recommended that children and their guardians notify us in time when their contact information is updated. If children continue to use Secret Space services after this policy update takes effect, it means that children and their guardians have fully read, understood and accepted the updated rules and are willing to be bound by the updated rules. Major changes referred to in this policy include, but are not limited to:
(1) Significant changes have taken place in our ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers, etc.;
(2) Substantial changes in the purpose, method and scope of collecting, storing, using and providing children's information;
(3) Substantial changes have occurred in the storage location, period and processing method of children's information after expiration;
(4) Substantial changes have taken place in the security measures for children's information;
(5) Substantial changes in the consequences of refusal of consent;
(6) Substantial changes in the channels and methods of user complaints and reports;
(7) Substantial changes have occurred in the ways and methods of correcting and deleting children's information;
(8) Other changes that may have a significant impact on children's information rights.
When the above-mentioned major changes occur, or the matters we inform you based on this policy have substantial changes, or we need to use children's personal information beyond the agreed purpose and scope, we will ask for your consent again.

7. How to contact us
1. If you have 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:
(1) Email: [email protected];
We will resolve your issue in a timely manner.
2. Guardians please understand that in order to ensure safety, we may require guardians to provide relevant materials to prove their status as guardians before responding to the feedback from guardians. We will properly handle the guardian's request within fifteen working days after receiving the feedback and verifying the guardian's identity.