Volcano Technology Limited and its Affiliates (as hereinafter defined) (“we”, “us”, “our”, or “Volcano”)are committed to protecting the personal privacy of children (i.e., minors under the age of 14) who use our products and services. This Children’s Privacy Protection Statement (including any subsequent updates, hereinafter referred to as “this Statement”), together with the Smart Light Privacy Policy, explains to parents and other guardians (“guardians” or “you”) how we collect and use children’s personal information in connection with our products and services, the rules governing how we process such information, and how guardians may access, correct, delete, and protect such information.
Special Notice to Guardians
We will protect children’s personal information and privacy in accordance with this Statement. At the same time, we ask for your assistance in safeguarding your child’s personal information and privacy. You should ensure that your child reads and accepts this Statement under your supervision, and that your child uses our products and services only with your consent and guidance.
Please note that your consent to this Statement — or your child’s initiation or continued use of our products or services, or submission of personal information — signifies that you agree to our collection, use, storage, sharing, transfer, and disclosure of your child’s personal information in accordance with this Statement.
Special Notice to Children
We recommend that all children obtain prior permission from their guardians before using our products or services.
If you are a child, you should read this Statement carefully together with your guardian and use our products or services or provide information to us only after obtaining your guardian’s consent.
Please read this Statement and the Smart Light Privacy Policy carefully and thoroughly—especially the terms highlighted in bold—before deciding whether to consent to all provisions and whether to allow the child under your guardianship to use our products or services.
If you do not agree to the relevant terms of the Smart Light Privacy Policy and/or this Statement, or if you choose not to provide certain required information for specific features or scenarios, please understand that you and the child under your guardianship may not be able to normally use certain products, services, or functionalities.
In the event of any inconsistency between this Statement and the Smart Light Privacy Policy regarding the protection of children’s privacy, this Statement shall prevail. For matters not addressed herein, the Smart Light Privacy Policy shall apply.
This Statement applies to products or services that require users to input information such as date of birth or age to determine the user’s age, as well as specific devices designed for children that are controlled through our software (including mobile applications and mini-programs) and their associated intelligent features or scenarios.
Some of our products or services may include third-party offerings, and you may also access third-party products or services (e.g., through Smart Light) via our software or products. Such third parties may collect, use, or process children’s personal information. We recommend that you ensure your child obtains your consent before granting any third party permission to collect or process their personal information.
If you have any questions while reading this Statement, or if you have any requests regarding personal information during your or your child’s use of our products or services, please contact us through the dedicated channels provided in the “Contact Us” section of this Statement. We will respond as soon as possible after receiving your inquiry or request.
1. Information We Collect
We strictly adhere to applicable laws and regulations regarding the protection of children’s personal information, and we collect and use such information only with the guardian’s consent and only as necessary for specific products and services.
For certain children-oriented products or services, we may require users to provide their date of birth in order to determine whether they are under 14 years old. According to legal requirements, only after obtaining guardian consent will we permit children to continue using such products or services.
When you and the child under your guardianship use specific devices controlled through our software, we may collect and use essential children’s personal information for certain features or scenarios, including age/month-age information, motion data, and geolocation information. The specific types and scope of information collected will depend on the functions and intelligent scenarios of the product in use.
We may also collect other relevant information during the child’s use of products or services. Please refer to the “Personal Information We Collect” section of the Smart Light Privacy Policy for details.
If we need to collect children’s personal information beyond the scope described above, we will notify you again and obtain your consent.
Please note that while you may choose whether to provide certain information, failure to provide specific necessary information may result in some products or services not functioning properly or not achieving their intended effect. The child under your guardianship may be unable to use certain products, services, or features.
2. How We Use Children’s Information
We use the personal information collected from you and the child under your guardianship in strict compliance with applicable laws and regulations and our agreement with users, for the following purposes:
a) Providing necessary products or services and their specific features;
b) Optimizing products or services, ensuring security, and conducting service-related analysis or surveys.
If we need to use children’s personal information for purposes beyond those listed above, we will notify you again and obtain your consent.
3. Sharing, Transfer, and Disclosure of Children’s Personal Information
We strictly limit the sharing, transfer, and disclosure of children’s personal information in accordance with applicable laws and regulations. As a general principle, we do not share children’s personal information with third parties unless we have obtained prior consent from the guardian.
a) Sharing with Guardians
We may share certain children’s personal information (such as username, account information, password, and transaction activity within certain products or services) with guardians, who may access and manage such information.
b) Sharing with Third Parties
For the purpose of external processing, we may share children’s personal information with third-party partners (service providers, contractors, agents, application developers, etc.), such as communication providers sending emails or push notifications on our behalf or map service providers offering location services. These partners may be located outside your jurisdiction.
Before entrusting a third party with the processing of children’s personal information, we conduct security assessments, sign entrustment agreements, and require them to follow our instructions, privacy policy, and confidentiality and security requirements. Third-party processing is primarily for:
i. Providing services to children;
ii. Achieving the purposes described in “How We Use Children’s Information”;
iii. Fulfilling our obligations and exercising our rights under our Privacy Policy and this Statement;
iv. Understanding, maintaining, and improving our services.
We conduct security reviews and implement encryption, anonymization, and de-identification measures to safeguard information shared with third parties.
If a merger, acquisition, or asset transfer occurs that requires sharing children’s personal information with a third party, we will notify you through push notifications, announcements, or other appropriate means and ensure that children’s information continues to be protected at or above the standard required by this Statement.
We may also use anonymized children’s information for big-data analysis, such as generating usage reports for your reference.
c) Other Disclosure Circumstances
Although we generally prohibit disclosing children’s personal information, disclosure may occur under the following circumstances:
i. To comply with applicable laws, regulations, legal processes, or requests from public or governmental authorities;
ii. To enforce our terms of use or other agreements, policies, or standards, including investigating potential violations;
iii. To protect the rights, privacy, security, or property of us or other users (including you);
iv. To detect, prevent, or address security, fraud, or technical issues and to pursue available legal remedies or limit damages.
4. Storage of Children’s Personal Information
We store children’s personal information using encryption and other technical measures to ensure security. We will not retain children’s personal information longer than necessary to achieve the purposes described in this Statement.
For more details on how we store and protect personal information, please refer to the “Location and Duration of Information Storage” and “Information Security” sections of the Smart Light Privacy Policy.
If our products or services cease operation, or if the retention period expires in accordance with this Statement or the Smart Light Privacy Policy, we will notify you and your child (via push notifications, announcements, or email) and delete or anonymize the relevant personal information within a reasonable period.
5. Managing Children’s Personal Information
During the child’s use of our products or services, we provide interfaces and settings that allow you to conveniently access, correct, or delete their personal information. You may also contact us for assistance through the channels described below. After verifying your identity and request, we will respond promptly.
Please note that identity verification may require information such as the child’s account, date of birth, and contact information.
a) Accessing Children’s Personal Information
You and your child may view the personal information provided or generated during use of our products or services, including (but not limited to) username, nickname, gender (if applicable), and content actively submitted.
b) Correcting Children’s Personal Information
If you or your child discover that inaccurate personal information has been collected or processed, you may correct it via “Me” → “Personal Information” → “Nickname” or contact us for assistance. After verifying your identity, we will promptly make the necessary corrections.
c) Deleting Children’s Personal Information
You or your child may request deletion of personal information in the following circumstances:
i. We collect, store, use, transfer, or disclose personal information in violation of laws, regulations, or agreements;
ii. We collect, store, use, transfer, or disclose personal information beyond the required scope or duration;
iii. You withdraw your consent;
iv. You or your child terminates the use of our products or services by deleting the account.
Please note that deleting certain information may affect your child’s ability to use some features. If you discover that we have collected your child’s information without prior consent, please contact us immediately so we may delete it as soon as possible.
Contact Us
If you have any questions about our practices or this Statement, please contact us through the following channels:
Volcano Technology Limited
Postal Mailing Address: Suite 603, 6/F Laws Commercial Plaza, 788 Cheung Sea Wan Road, Kowloon, Hong Kong