Version Release Date: April 16, 2024
Effective Date: April 16, 2024
EyeCareAngel (hereinafter referred to as "we") fully recognizes the importance of children's personal information and privacy security and appreciates your trust in us. We will take appropriate security measures as required by laws and regulations to strive to ensure the safety and control of children's personal information. Based on this, Guanglang (Hainan) Biotechnology Co., Ltd. (hereinafter referred to as "Guanglang"), the provider of EyeCareAngel platform products and services, has established this policy. This policy primarily explains what children's personal information we collect, the purposes for which it is collected, the protective measures we take, and declares our commitment to protecting children's privacy. We may update or modify this policy in the future according to changes in information processing scenarios. Please be aware of this policy and any supplementary policies before using any services provided by EyeCareAngel. Unless otherwise specified, the terms and abbreviations used in this policy have the same meanings as those in the "User Service Agreement" and "Privacy Policy."
If you are the guardian of a child user, please read and decide whether to agree to this policy carefully. We ask you to join us in protecting children's personal information, educating and guiding children to enhance their awareness and ability to protect personal information, and advising, reminding, and requiring them not to provide any personal information to any online product and service provider without your consent. If you do not agree to the contents of this policy, it will result in our products and services not functioning properly or achieving the intended service effects, and you should instruct your child to immediately stop accessing/using EyeCareAngel products/services. If your child uses or continues to use EyeCareAngel services and submits personal information, it indicates that you agree to our collection, use, storage, and sharing of your child's personal information according to this policy (including updated versions).
If you are a child under the age of 14, you must carefully read this statement with your guardian and use our products, services, or provide us with information only after obtaining your guardian's consent. If you use or continue to use EyeCareAngel services and submit personal information, it indicates that you have obtained permission from your guardian, and both you and your guardian agree to our collection, use, storage, and sharing of your personal information according to this policy.
This policy applies to "EyeCareAngel" products and services (including but not limited to: EyeCareAngel website www.huyantianshi.cn, EyeCareAngel app, EyeCareAngel mall mini program, EyeCareAngel alliance mini program, etc.).
We adhere to the following principles to protect children's personal information: the principle of accountability, principle of clear purpose, principle of consent, principle of minimal sufficiency, principle of transparency, principle of security, and principle of subject participation. Additionally,we promise to take appropriate security measures to protect children's personal information according to industry-standard security practices.
When children use any "EyeCareAngel" service, guardians agree to accept this policy. If there is any inconsistency between this policy and similar provisions in the "User Service Agreement" or "Privacy Policy," this policy prevails. Matters not addressed here are governed by the "Privacy Policy."
We remind you that important terms closely related to your and your child's rights and interests in this statement have been highlighted in bold for your attention.
If you have any questions, comments, or suggestions about the contents of this policy, please contact us using the methods provided at the end of this document.
This Privacy Policy will help you understand the following:
We collect and use children's personal information for the following purposes described in this policy, after obtaining consent from their guardians:
（1）Becoming a User of EyeCareAngel
If a child wishes to register as an EyeCareAngel user, they will need to provide their name, gender, date of birth, mobile number, and medical records as basic registration information. They must also create an EyeCareAngel platform account and password, which will be used to log into the platform.
（2）Providing Products or Services
- User Experience Improvement Program
When you use EyeCareAngel services, in order to ensure the normal use of our services, maintain the regular operation of our services, improve and optimize our service experience, and secure your account, we will collect data about your device type, such as configuration settings generated during your use of EyeCareAngel. This information is essential for providing services. As Guanglang's products are upgraded, the scope of our data collection may change. The act of a child downloading/installing/using our subsequent product versions will be seen as the guardian and child consenting to relevant changes at that time.
- Customer Service and After-Sales
Our customer service and after-sales function will use the child's account information to provide consultation services.
When guardians and children contact us, we may save communication or call records and content or contact details left by the child to help resolve issues or record the handling of relevant problems. Our customer service will use the child's account information to verify their identity. Guardians and children may provide additional information beyond the aforementioned details during communications with our customer service staff.
- Basic and Additional Business Functions
Basic Business Functions:
Registration/Login: You need to register and log in to use EyeCareAngel features. When registering an EyeCareAngel account, you will need to provide your name, gender, date of birth, mobile number, and medical records. We tailor different training programs based on the user's age and medical history. Login uses the account verification code.
Vision Training: In vision training, we may need to collect some training-related information, mainly including clicks, error reports, training times, and conditions—data generated during your training sessions. We use your training-related information to provide service-related content and continually optimize functionalities.
Additional Business Functions:
Use of the Scan function to scan myopia and amblyopia treatment devices requires access to your camera and Bluetooth permissions; connecting to "Tong Xiao Ai" amblyopia smart eye mask also requires Bluetooth permission.
Viewing and Editing Personal Profiles: You can choose whether to complete personal information on EyeCareAngel, and you can personally modify your name, gender, date of birth, glasses prescription, height, and location. Your personal information will be displayed in some interactive scenarios, such as leaderboards.
Purchasing Goods: When purchasing goods in the EyeCareAngel mall mini-program, postal services are required. You must provide the recipient's name, mobile number, and address to ensure your order is delivered safely and accurately. If you do not provide this information, we cannot mail the purchased goods.
（3）Providing Safety and Security Protections
The child's network identity information helps maintain the normal use and security of the software.
Based on the specific permissions granted by the child during the software installation and use, we receive and record the child's commonly used device information, such as operating system version, device identifiers (AndroidID/IMEI/OAID/IMSI/IDFA), hardware features, and device location-related information (e.g., IP address).
We may collect, use, or aggregate children's account information, transaction information, device information, log information, and information authorized or shared according to law, to comprehensively assess the risk of children's accounts and transactions, perform identity verification for children or guardians, detect and prevent security incidents, and take necessary measures for recording, auditing, analyzing, and handling as required by law.
Anonymization of Children's Personal Information:After collecting children's personal information, we will promptly anonymize the data using technical methods. We store anonymized data separately from information that can be used to re-identify individuals and ensure that individuals are not re-identified in subsequent personal information processing. The anonymized information cannot identify specific children, and without disclosing children's personal information, we are entitled to mine, analyze, and utilize (including for commercial use) the anonymized user database.
（4）Exceptions to Obtaining Authorized Consent
In the following cases, we do not need to obtain consent from children and their guardians to collect and use personal information:
Note: The primary protective function of a personal information policy is to disclose the range and rules for the collection and use of personal information by the controller, and should not be regarded as a contract.
(i) Necessary for maintaining the safe and stable operation of the products or services provided, such as detecting or handling faults in products or services.
（5）Special Function Permissions
Some features in our services may require children to enable specific access permissions on their devices (such as camera, photo album, microphone, or calendar) to collect and use information related to these permissions. When children and guardians need to disable these features, most mobile devices support this requirement; specific methods can be referred to or inquired from the device's service provider or manufacturer. Enabling any such permission signifies that the guardian authorizes us to collect and use the related information to provide corresponding services to the child. Conversely, disabling any permission indicates that the guardian has revoked such authorization, and we will no longer continue to collect and use the relevant information based on that permission, nor can we provide the services related to that permission. However, the decision to disable permissions will not affect the collection and use of information based on the guardian's authorization prior to the disabling.
To enhance children's ease of access, when children visit EyeCareAngel platform products or services, we may use various technologies to collect and store data related to their use of the EyeCareAngel services. This helps us identify children, save them the step of re-entering registration information, and assist in assessing the security status of their accounts. These data files may include cookies, clickstreams, and web data, as well as other local storage provided by the children's browsers or associated applications (hereinafter referred to as "Cookies"). Guardians and children should understand that some of our services can only be provided through the use of Cookies, if allowed by the children's browsers or browser add-on services. Most browser toolbars' "Help" sections will instruct how to prevent the browser from accepting new Cookies, how to notify guardians and children when a new Cookie is received, or how to completely disable Cookies. Guardians and children can change the settings of the browser add-ons or visit the provider's webpage to disable or delete browser add-on used Flash Cookies and similar data. Guardians and children can adjust their acceptance of Cookies or refuse Cookies from the EyeCareAngel learning platform, but in some cases, refusing EyeCareAngel platform Cookies may prevent children from using certain features of the EyeCareAngel platform services that rely on Cookies. Our website may also contain certain electronic images (including "web beacons" or "single-pixel GIF files") that help the site count users who have visited pages or accessed certain Cookies. We collect information about children's webpage browsing activities through web beacons (including the address of the pages you visit, the location of the referring page you visited prior, your browsing environment, and display settings).
(1) Sharing
We do not share children's personal information with any companies, organizations, or individuals other than us and our affiliates, except under the following circumstances:
Our authorized partners include:
(2) Transfer
We do not transfer children's personal information to any companies, organizations, and individuals, except in the following circumstances:
(3) Public Disclosure
We will only publicly disclose children's personal information under the following conditions, and by taking industry-standard safety precautions:
(4) Exceptions for Prior Consent for Sharing, Transferring, and Publicly Disclosing Children's Personal Information
In the following cases, we do not need to obtain prior consent from children and their guardians to share, transfer, or publicly disclose personal information:
(1) Technologies and Measures We Use to Protect Your Personal Information
（e）All of children's personal information is stored on secure servers and protected in controlled facilities. We categorize your data based on importance and sensitivity, ensuring that children's personal information is held to the highest standard of security. We follow the principle of least privilege, allowing only necessary employees and partners who need to know this information access to children's personal information, with strict access control and monitoring mechanisms in place. Employees and third-party service providers who help provide products and services to children are bound by strict contractual confidentiality obligations; failure to fulfill these obligations results in disciplinary action or termination of cooperation. Similarly, we employ specialized access controls for cloud-based data storage. Overall, we regularly review our information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.
Despite these reasonable and effective measures and adherence to legal standards, please understand that due to technical limitations and potential malicious methods, it is not always possible to guarantee 100% security of information in the internet industry. We strive to ensure the security of personal information provided by children. You should be aware that the systems and communication networks used by children to access our services may face issues beyond our control. Therefore, we strongly advise guardians and children to take proactive steps to protect the security of children's personal information, including but not limited to using complex passwords, regularly changing passwords, and not disclosing children's personal information such as account verification codes to others. We will promptly notify relevant regulatory bodies of any personal data breaches involving children and, in certain circumstances, notify the data subjects of such incidents to comply with applicable laws, including data protection regulations relevant to guardians and children.
We are not responsible for the legality of privacy policies of third-party websites that might be accessed. Guardians and children should review the privacy policies of third-party websites to determine whether they accept them.
(2) How We Preserve Children's Personal Information
（a）Retention period: We will retain children's personal information only for the period necessary to achieve the purposes stated in this policy, unless a longer retention period is required by law. Our determination of the personal information storage period primarily considers the following criteria, opting for the longer duration where applicable:
Guardians and children have the right to view, access, modify, delete, or refuse further collection or use of children's personal information collected through the Eye Protector platform. However, requesting the deletion of such information may limit children's access to all or part of the services. In accordance with relevant laws, regulations, and standards in China, as well as common practices in other countries and regions, we ensure that guardians and children can exercise the following rights over children's personal information:
（1）Right to Access and Query
Guardians and children have the right to access and query their personal information, except where exceptions are stipulated by law. If you wish to exercise the right to access and query data, you can do so in the following ways:
（2）Right to Correct
If guardians or children find any errors in the personal information about children that we process, modifications can be made via:
（3）Right to Delete
Guardians and children may request the deletion of personal information under the following circumstances:
Deletion can be requested through:
（4）Right to Withdraw Consent
Guardians can directly withdraw their consent for collecting and using personal information through the following method:
（5）Right to Cancel
You can log into your account on the Eye Protector mobile version: Home -> Tap "My" -> Tap "Privacy Policy" -> Click on the text link "Click here" to follow the cancellation process. Before canceling your account, we will verify your identity, security status, and device information. It is important to understand that canceling an account is irreversible. After your account is canceled, we will delete or anonymize your related information unless otherwise stipulated by law.
For details on the cancellation process and content, please refer to the Eye Protector Account Cancellation Instructions.
（6）Public Sharing
Our services allow children to publicly share their information with all users of the service, such as information uploaded or posted by children in Eye Protector, responses to information uploaded or posted by others, or information uploaded or published by children in non-specific public areas of Eye Protector, including related location data and log information. As long as the information shared by guardians and children is not deleted, it may remain in the public domain indefinitely, and even if deleted, it may still be cached, copied, or stored independently by other users or third parties not under our control, or kept by third parties in the public domain. We are not liable for any disclosure of information that arises from such public sharing by guardians and children. Therefore, we advise guardians and children to carefully consider whether to publicly share information through such channels.
（7）Obtaining a Copy of Personal Information
Guardians can obtain a copy of personal information through the following pathway:
- Guardians have the right to log into "Eye Protector" -> "My" -> "Click on Profile Picture" to access personal information and obtain a copy by taking a screenshot.
（8）Responding to Requests
If you cannot access, correct, or delete your personal information through the above methods, or you need to access, correct, or delete other personal information generated while using our products and/or services, or if you believe that Guangrong is violating legal regulations or agreements regarding the collection or use of personal information, you can contact us through the methods provided at the bottom of this agreement. For security reasons, we may require you to provide a written request or other proof of identity. We will respond to your request within 15 days after receiving your feedback and verifying your identity. We generally do not charge a fee for responding to reasonable requests, but we may impose a cost for repeated, excessive requests. For requests that are unreasonably repetitive, require excessive technical efforts, pose risks to the lawful rights and interests of others, or are extremely impractical, we may refuse to comply. We cannot respond to your request under the following legal circumstances:
The children's personal information we collect and generate within the People's Republic of China is stored within China, and we do not transfer your personal information overseas.
Our privacy policy may change.
This policy is an integral part of the "User Service Agreement" and "Privacy Policy." We reserve the right to update or modify this policy from time to time. If such modifications substantially reduce children's rights under this policy ("Significant Changes"), we will notify guardians and children through various channels, including but not limited to website announcements and private messages. If guardians do not agree with the modified privacy policy, they have the right and should immediately stop using the Eye Protector services. If children continue to use our services, it is deemed that the guardians have fully read, understood, and accepted our modifications to the terms related to this policy. All services of Eye Protector are subject to this policy. However, some services have their specific privacy policies, which more specifically describe how Eye Protector handles children's information in those services. If there is any inconsistency between this policy and the specific privacy policy of a service, the specific privacy policy shall prevail.
Significant changes referred to in this policy include, but are not limited to:
When the Eye Protector platform ceases operations, we will promptly stop collecting children's personal information, possibly notify guardians and children to cease operations via notices or website announcements, and delete or anonymize children's personal information.
The user agreement and the relationship between guardians, children, and Guangrong are governed by the laws of Mainland China, excluding its conflict of law provisions. Guardians and Guangrong agree to submit to the jurisdiction of the courts located in Guangrong's location.
If you have any questions about the content of this privacy policy, or if you have any complaints or comments about your personal information processing, you can contact us via email at huyantianshi8@163.com; you can also contact us by phone at 4006-007-818 (Monday to Sunday, 7:00-22:30).
Guangrong (Hainan) Biotechnology Co., Ltd.