Last updated: January 29, 2023
Effective date: February 28, 2023
Hangzhou Tuya Information Technology Co., Ltd. and its affiliates (collectively, "we," "us," or "Tuya") are committed to protecting the personal privacy of children (i.e., minors under the age of fourteen) who use our products and services. This Children's Privacy Statement (including any subsequent updated versions, hereinafter referred to as this "Statement") and Tuya Privacy Policy are intended to explain to parents and other guardians of children (hereinafter referred to as "Guardians" or "you") how we collect and use children's personal information in connection with our products and services, the rules for processing such personal information, and how guardians can access, correct, delete, and protect such information.
Special Note for Guardians:
We will protect children's personal information and privacy security in accordance with this Statement. We also ask you to help us protect your children's personal information and privacy security by requiring them to read and accept this Statement under your supervision and use our products and services with your consent and guidance. Please note that by agreeing to this Statement, or by your child starting or continuing to use our products or services, or submitting their personal information, you consent to our collection, use, storage, sharing, transfer, and disclosure of your child's personal information in accordance with this Statement.
Special Note for Children:
We recommend that all children use our products or services only with their guardian's prior consent. If you are a child, you should carefully review this Statement with your guardian and obtain their consent before using our products or services or providing us with information.
**We remind you to carefully read and fully understand this Statement and the Tuya Privacy Policy (especially the terms in bold) before deciding whether to agree to all terms and whether to consent to your child's use of our products or services. If you disagree with the relevant terms of the Tuya Privacy Policy and/or this Statement, or disagree with providing the necessary information for specific features or scenarios of our products or services, please understand that you and your child may not be able to properly use our products or services or the relevant specific features or scenarios. With respect to children's privacy protection, if there is any inconsistency between this Statement and the Tuya Privacy Policy, this Statement shall prevail. For any matters not addressed in this Statement, the Tuya Privacy Policy shall prevail.
This Statement applies to products or services that require users to enter information such as birthdays and age that can identify their age, or to specific devices and their functions and scenarios designed and developed for children that are intelligently controlled through our software (including mobile applications, mini-programs, etc.). Our products and services may include products or services provided by third parties, and you may also log in and use third-party products and services through our software or products (such as Tuya). Such third parties may collect, use, or process information related to children. We recommend that children obtain your consent before authorizing third parties to collect and process any of their personal information.
If you have any questions about the terms in this Statement, or if you or your child has any requests regarding personal information rights when using our products or services, please contact us through the dedicated channels we have established. Please refer to the "Contact Us" section of this Statement for details. We will address your questions or requests as soon as possible after receiving your message.
1. What Information We Collect
We will strictly adhere to the obligations and responsibilities for protecting children's personal information as stipulated by laws and regulations, as well as the relevant privacy policies and this Statement. We will collect and use children's personal information based on the specific needs of the relevant products and services, with the consent of their guardians.
When providing you and your children with certain products or services specifically targeted at children, we may require users to provide their birthdate information to identify whether they are under the age of 14. We will only allow children to continue using the relevant products or services after obtaining their guardian's consent, as required by laws and regulations.
When you and your children use specific devices intelligently controlled by our software, we may collect and use necessary personal information about children, including age, exercise, and location, for certain functions or scenarios. The specific types and scope of information involved will be determined by the functions and intelligent scenarios of the products used.
We may collect other relevant information when children use our products or services. Please refer to the "What Personal Information We Collect" section of the Tuya Privacy Policy for details on other personal information we collect from children.
If we need to collect personal information about you or your child(ren) beyond the scope of collection described above, we will notify you again and obtain your consent.
Please understand that you can choose whether to fill in or provide us with specific information. However, if you do not fill in or provide certain information, our products or services may not function properly or achieve the intended service results. You and your child(ren) may not be able to use our products, services, or related specific business features properly.
II. How We Use This Information
We strictly abide by laws and regulations and our agreements with users and use the information collected about you and your child(ren) for the following purposes:
a) Providing necessary products or services, and specific features of products or services;
b) Optimizing products or services, ensuring security, and conducting service research.
If we need to use your or your child's personal information beyond the purposes described above, we will notify you again and obtain your consent.
III. Circumstances in Which Children's Personal Information is Shared, Transferred, or Disclosed
We strictly limit the sharing, transfer, and disclosure of children's personal information in accordance with laws and regulations. Generally, we do not share children's personal information with third parties. We may only share children's personal information with third parties with their guardians' prior consent.
a) Sharing with Guardians
We will share some of a child's personal information (such as their username, account number, password, and the details of their transactions in certain of our products and services) with their guardians, who will have access and manage this personal information.
b) Sharing with Third Parties
For external processing purposes only, we may share children's personal information with third-party partners (such as third-party service providers, contractors, agents, and app developers, for example, communication service providers that send emails or push notifications on our behalf, or mapping service providers that provide location-based services for us) (they may not be located in your jurisdiction). They will process this information for us in accordance with our instructions, our Privacy Policy, and relevant confidentiality and security policies.
If we entrust a third party to process children's personal information, we will conduct a security assessment of the entrusted party and the entrusted activities, sign an entrustment agreement, and require the entrusted party to handle children's personal information within the scope of our authorization. We entrust third parties to process children's personal information primarily for the following purposes:
i. Providing our services to children;
ii. Fulfilling the purposes described in the "How We Use This Information" section;
iii. Fulfilling our obligations and exercising our rights as outlined in our Privacy Policy and this Statement;
iv. Understanding, maintaining, and improving our services.
If we share your and your child's information with such third parties, we will conduct a security assessment and employ encryption, anonymization, and de-identification measures to protect your and your child's information security.
As our business continues to develop, if mergers, acquisitions, asset transfers, or other transactions result in the sharing of your and your child's personal information with third parties, we will notify you of such sharing through push notifications, announcements, and other means. We will continue to protect, or require the new administrator to continue to protect, your and your child's personal information in accordance with laws and regulations and standards no less stringent than those required by this Statement.
We may use the collected children's information, after anonymization, for big data analysis, such as generating reports on your service usage.
c) Other Disclosures
Generally, we prohibit the disclosure of children's personal information to third parties. However, we may disclose children's personal information for the following purposes:
i. To comply with applicable laws, regulations, legal process, or requests from public and government agencies;
ii. To enforce our Terms of Use and other agreements, policies, or standards, including investigating any potential violations;
iii. To protect the rights, privacy, safety, or property of us and/or other users, including you; and to seek available means to detect, prevent, remedy, or limit damages we may be required to pay or address security, fraud, or technical issues.
IV. Storage of Children's Personal Information
We will use encryption and other technical measures to store children's personal information to ensure its security. We will not store children's personal information longer than is necessary to fulfill the purposes for which it was collected and used. Please refer to the "Storage and Duration of Information" and "Information Security" sections of Tuya's Privacy Policy for more information on how we store and protect children's personal information.
If our products or services cease operations, or if the storage period for your or your child's personal information expires as required by this Statement or the Tuya Privacy Policy, we will notify you and your child through, for example, push notifications, announcements, or emails, and delete or anonymize your or your child's personal information within a reasonable period of time.
V. Managing Children's Personal Information
During the use of our products or services by children, we have provided corresponding settings in our product design to facilitate access, correction, and deletion of relevant personal information. You can also provide feedback and inquiries through the contact information we provide. We will contact you promptly after verifying your feedback. Please understand that during the verification process, we may require you to provide personal information such as your child's account number, date of birth, and contact information so that we can continue to respond to your needs after completing identity verification and issue verification.
a) Access to Children's Personal Information
You and your children can view the personal information provided or generated by children when using our products or services, including but not limited to usernames, nicknames, gender (if any), and content that they actively post.
b) Correcting Children's Personal Information
If you or your child discovers errors in the personal information we collect, use, and process about children, you can correct it by clicking "Me" - "Personal Information" - "Nickname"/"Time Zone," or by contacting us. We will promptly take corrective measures after completing identity verification and verification.
c) Deleting Children's Personal Information
You and your child may request that we delete the personal information we collect, use, and process about children in the following circumstances. We will promptly take measures to delete the information after completing identity verification and verification.
i. If we collect, store, use, transfer, or disclose children's personal information in violation of laws, administrative regulations, or the agreement between us and you;
ii. If we collect, store, use, transfer, or disclose children's personal information beyond the scope of the purpose or the necessary period;
iii. If you withdraw your consent;
iv. If you or your child terminates your use of a product or service by unregistering.
We will first conduct identity verification and take timely deletion measures after completing the verification and verification. However, please note that if you or your child requests that we delete specific personal information about your child, this may result in that child being unable to use our products and services or certain features within those products and services. If you discover that your child's personal information has been collected without your prior consent, please contact us promptly and we will work to delete the relevant information as soon as possible.
Contact Us
If you have any questions about our practices or this Statement, please contact us through the following means:
Hangzhou Tuya Information Technology Co., Ltd.
Address: 7-12th Floor, Building A, Huace Center, Wuchanggang Road, Xihu District, Hangzhou, Zhejiang Province, China