Apple Apps & Google Play
Last Updated: October 1, 2024
Effective Date: October 1, 2024
START WIRELESS and its affiliates (hereinafter referred to as "we" or "START") are committed to protecting the personal privacy of children (those under the age of 14) who use our products and services. This Children’s Privacy Protection Statement (including subsequent updates, hereinafter referred to as "this Statement") and the START Privacy Policy aim to inform the parents and other guardians of children (hereinafter referred to as "Guardians" or "you") about how we collect and use children’s personal information related to our products and services, the rules for processing this personal information, and how Guardians can access, correct, delete, and protect this information.
Special Note to Guardians:
We will protect children's personal information and privacy according to this Statement. We also request that you help us protect your child's personal information and privacy by asking them to read and accept this Statement together with you, and that they use our products and services with your consent and guidance. Please note that by agreeing to this Statement, or by allowing your child to start or continue using our products or services or to submit their personal information, you agree that we may collect, use, store, share, transfer, and disclose your child's personal information as described in this Statement.
Special Note to Children:
We recommend that any child uses our products or services only after obtaining prior consent from their Guardian. If you are a child, you need to carefully read this Statement together with your Guardian and use our products, services, or provide information to us only after obtaining your Guardian’s consent.
We remind you to carefully read and fully understand this Statement and the START Privacy Policy (especially the terms marked in bold) before choosing whether to agree to all terms and whether to allow the child under your guardianship to use our products or services. If you do not agree with the relevant terms of the START Privacy Policy and/or this Statement, or if you do not agree to provide the necessary information in certain features or scenarios of our products or services, please understand that you and the child under your guardianship may not be able to use our products, services, or related specific features or scenarios properly. In terms of children's privacy protection, if there is any inconsistency between this Statement and the START Privacy Policy, this Statement shall prevail. If something is not mentioned in this Statement, the START Privacy Policy shall apply.
This Statement applies to products or services that require users to input birthday or age information to identify the user’s age or to specific devices designed and developed for children, controlled through our software (including mobile applications, etc.), and their features and scenarios. The products and services we provide may include third-party products or services, and you may also log in and use third-party products and services through our software or products (such as START Connect, Web UI, etc.); such third parties may collect, use, or process information related to children. We recommend that you provide your consent before allowing the child to authorize a third party to collect or process any personal information.
If you have any questions about the content of this Statement while reading it, or if you have any requests regarding personal information during your or your child's use of our products and services, please contact us through the specialized channels we have provided. Refer to the "Contact Us" section of this Statement for details. We will handle and respond to your inquiries or requests as soon as possible after receiving your message.
1. What Information We Collect
We will strictly adhere to the legal obligations and responsibilities for protecting children’s personal information as specified by laws and regulations, and as stipulated in the relevant privacy policies and this Statement. After obtaining the Guardian's consent, we will collect and use children's personal information as needed for specific products and services.
In the process of providing certain products or services specifically for children, we may require users to provide personal birthday information to determine if the user is under 14 years of age. According to legal requirements, children are allowed to continue using relevant products or services only after obtaining Guardian consent.
When you and the child under your guardianship use specific devices controlled through our intelligent software, we may collect and use necessary children’s personal information, including age/month information, activity data, and geographical location information, in certain features or scenarios. The types and scope of information involved will depend on the functions of the product and the intelligent scenarios used.
For other relevant information collected during the use of products or services, please refer to the "What Personal Information We Collect" section in the START Privacy Policy for more details.
If we need to collect additional personal information beyond the scope mentioned above, we will inform you again and obtain your consent.
Please understand that you can choose whether to provide specific information to us. However, if you do not provide certain information, our products or services may not function properly, or may not achieve the intended service effect. Consequently, you and the child under your guardianship may not be able to use our products, services, or related specific business features properly.
2. How We Use This Information
We strictly adhere to the regulations and our agreements with users, using the collected information from you and the child under your guardianship for the following purposes:
a) Providing necessary products or services and specific functions of products or services;
b) For optimizing products or services, security assurance, and service surveys.
If we need to use your or the child’s personal information beyond the purposes mentioned above, we will notify you again and obtain your consent.
3. Sharing, Transfer, and Disclosure of Children’s Personal Information
We strictly limit the circumstances under which children's personal information can be shared, transferred, or disclosed as specified by laws and regulations. Generally, we do not share children’s personal information with third parties. We will only share children’s personal information with third parties after obtaining prior consent from the Guardian.
a) Sharing with Guardians:
We may share some children’s personal information (such as the child’s username, account number, password, and transaction details in some of our products and services) with Guardians. Guardians can access and manage the relevant personal information.
b) Sharing with Third Parties:
To achieve external processing purposes, we may cooperate 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, or map service providers who provide location services for us) (they may not be located in your jurisdiction) to share children’s personal information. These partners will handle the information based on our instructions, privacy policies, and relevant confidentiality and security policies.
If we entrust third parties to process children's personal information, we will conduct a security assessment of the entrusted party and their actions, sign an entrustment agreement, and require that their processing activities do not exceed our authorized scope. We primarily entrust third parties to process children's personal information for the following purposes:
i. To provide our services to children;
ii. To achieve the purposes described in the "How We Use This Information" section;
iii. To fulfill our obligations and exercise our rights in the START Privacy Policy and this Statement;
iv. To understand, maintain, and improve our services.
When sharing information with the aforementioned third parties, we will conduct a security assessment and use encryption, anonymization, de-identification, and other means to ensure the security of your and the child's information.
With the continuous development of our business, if a merger, acquisition, asset transfer, or other transaction results in sharing your and the child’s personal information with a third party, we will notify you through push notifications, announcements, etc., and continue to protect or require the new administrator to continue protecting your and the child’s personal information in accordance with laws, regulations, and the standards required by this Statement.
We may use anonymized children’s information for big data analysis, such as forming usage reports of your services.
c) Other Disclosure Circumstances:
Generally, we prohibit the external disclosure of children’s personal information, but we may disclose children’s personal information for the following purposes:
i. To comply with applicable laws, regulations, legal procedures, or requests from public institutions and government authorities;
ii. To enforce our terms of use, 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 detection, prevention, remedial measures, or to limit any damages or address security, fraud, or technical issues.
4. Storage of Children’s Personal Information
We will use encryption and other technical measures to store children’s personal information to ensure information security. We will not store children’s personal information for longer than necessary to achieve the collection and use purposes. Please refer to the "Storage Location and Duration" and "Information Security" sections in the START Privacy Policy for detailed 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 and the child’s personal information expires according to this Statement or the START Privacy Policy, we will notify you and the child through methods such as push notifications, announcements, or emails, and delete or anonymize your and the child’s personal information within a reasonable period.
5. Management of Children’s Personal Information
During the use of our products or services by children, we provide operational settings in our product design to facilitate easier access, correction, and deletion of related personal information. You can also contact us through the methods provided for feedback and inquiries about related information. We will contact you promptly after verifying your feedback. Please understand that during the verification process, we may need you to provide the child's account, date of birth, contact information, and other personal information for identity verification and issue verification before continuing to respond to your needs.
a) Access to Children’s Personal Information:
You and the child under your guardianship can view the personal information provided or generated during the use of our products or services, including but not limited to username, nickname, gender (if applicable), actively posted content, etc.
b) Correction of Children’s Personal Information:
If you and the child under your guardianship find errors in the children’s personal information we collect, use, and process, you can correct the information by clicking "Me" - "Personal Information" - "Nickname" or by contacting us for corrections. We will promptly take corrective measures after verifying the identity and verifying the issue.
c) Deletion of Children’s Personal Information:
In the following situations, you and the child under your guardianship can request us to delete the children’s personal information we collect, use, and process. We will promptly take deletion measures after verifying the identity and verifying the issue.
i. If we violate the provisions of laws, regulations, or our agreements to collect, store, use, transfer, or disclose children's personal information;
ii. If we collect, store, use, transfer, or disclose children’s personal information beyond the purpose scope or necessary duration;
iii. If you withdraw consent;
iv. If you or the child under your guardianship terminates the use of the product or service by cancellation.
For your request, we will first conduct identity verification and verification, and promptly take related deletion measures after verification. However, please note that if you and the monitored child request us to delete specific children’s personal information, it may lead to the child user not being able to continue using our products and services or specific business functions in our 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 strive 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 methods:
START WIRELESS, INC.
Address: 5600 Tennyson Parkway, Suite 390, Plano, TX 75024, USA
Email: support@startwireless.com