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Thank you for choosing the products or services as offered by Pathea Co., Ltd. and its affiliates (hereinafter collectively referred to as "the Company" together with "Pathea").
In addition to "Pathea Games Privacy Policy", through this Pathea Games Privacy Protection Guidelines for Children ("Children's Guidelines"), we will further help you and your child ("child" or "Children" shall be under the age stipulated by the applicable laws and deemed as child under such laws) understand how we collect, use, store and share your child's personal information, as well as the relevant rights you and your child are entitled to. We will explain to you the collection of children's personal information through prompts, interaction processes, website announcements and other ways and obtain your consent. Please carefully read and fully understand "Pathea Games Privacy Policy" and the Children's Guidelines, before choosing to agree the afore-mentioned privacy policies.
1. Children's Personal Information We Collect
While your child is using Pathea Games and Service, we will only collect your child's information upon your consent or by you and your child's voluntary provision, in order to provide and optimize our services to your child and to ensure your child's account in safe security. We may collect you and your child's personal information through third party service providers, as detailed in the Pathea Games Privacy Policy. We will collect information such as your login time, length of playing games, etc., and guide the minors to play games rationally through ways such as automatically intervening and limiting the game duration of the minors in our system, enabling the function of mandatorily exiting the game, etc. Besides, we may also collect the game behavior data generated during the game (for example, the data such as the click pressure and radius, the relative position of the click, the acceleration direction, and the direction of gravity formed when you operate the game on the terminal device, and the voice data generated when you interact with other players through online voice in the game) to preliminarily determine whether the user is a minor.
Also, in order to verify your custody relationship with your child, we might collect your contact information (including phone number, email address) and other information to help us judge the existence of custody relationship. When the consumption is conducted by a person suspected to be a minor, we will then try to contact his or her guardian for reminders, confirmations and deposition, so as to help the minors have a healthy access to the Internet.
At present, aside from collecting game research information from third-party research organizations to help us upgrade our game products and provide personalized services, we do not take the initiative to obtain your child's personal information from any third party outside of Pathea. In the future, if Pathea needs to obtain your child's personal information indirectly from a third party outside of Pathea, we will strictly comply with the relevant laws and regulations and require the said third party to guarantee the legality of the information it provides.
2. How We Use Children's Personal Information
We will strictly obey the laws, regulations and the agreement with our users, and we will make use of the collected information in accordance with the Children's Guidelines, and Pathea Games Privacy Policy to provide your child with better service.
We use children's personal information as mentioned above in Section 1. We will protect the legitimate rights and interests of minors by initiating anti-addiction system in accordance with national regulations on online game anti-addiction policies. We will make a judgment on whether the real name information of an account belongs to a minor via the identification result of information such as real-name identity, based on which we decide whether the account shall be included in the anti-addiction system. If we use your child's personal information beyond the scope, or a direct or reasonably relevant scope, of the purpose we claimed when collecting that information, we will inform you once again and seek your express consent before using your child's personal information.
3. Storage of Children's Personal Information
3.1 In accordance with laws and regulations, we will store your child's personal information within the information collection territory and strictly keep that information confidential. If we need to transmit personal information collected within the information collection territory to overseas institutions for the sake of cross-border business, we will protect your child's personal information pursuant to domestic laws, administrative regulations and competent authorities' specifications.
3.2 In general, we will only store your child's information for a necessary period for achieving the purpose of providing our services or as required by laws and regulations. After the period specified by laws or competent authorities has expired, we will delete or anonymize your child's personal information in accordance with the requirements of laws and regulations.
4. Security of Children's Personal Information
4.1 In order to ensure the safety of your child's personal information, we will take reasonable and necessary measures under the current level of technology to protect children's information, and adopt measures of physical protection, security technology, management systems and so forth to reduce the risk of information loss, improper usage, unauthorized access, disclosure and alteration, including but not limited to, encrypted data transmission, firewalls and encrypted storage, physical access control, and information access authorization control.
4.2 We have established special management regulations, procedures and organizations to safeguard the security of your child's personal information. For example, we will strictly limit the scope of people that are authorized to access the information, requiring them to comply with confidential obligations and conducting audits.
4.3 If any security incident such as the leak of children's personal information occurs, we will initiate the emergency plan to prevent it from expanding and inform you the basic situation of the security incident, the treatment measures and remedies we will take or have taken as well as our advice for you via announcements, push notifications or emails, etc. in a timely manner. If it is difficult to inform every user, we will issue the warning through public announcements and other methods.
5. Rectification of Children's Personal Information
If you and your child find there is any mistake regarding the child's personal information, you may contact us for rectification.
6. Deletion of Children's Personal Information
6.1 If you and your child find we process children's personal information against the requirements of laws, administrative regulations or our agreement, or beyond the purpose scope or the necessary period, you may contact us to delete relevant personal information.
6.2 If you withdraw your consent, you may contact us and we will deal with it pursuant to relevant laws and regulations.
6.3 If you and your child take the initiative to terminate the use of Pathea Games and Service, we will stop using relevant child's personal information, except as otherwise required by laws, regulations or competent authorities. If we plan to cease any operation of products or services, we will notify you in accordance with relevant laws and regulations.; in the meantime, we will stop using children's personal information in a timely manner and delete or anonymize the stored information.
7. Transfer and Delegation of Children's Personal Information
Generally, we will not transfer to or delegate any third party to process children's personal information. In the case where we have to do so, we will take compliance measures according to laws and regulations, including but not limited to conduct a security assessment on the third party.
8. Disclosure of Children's Personal Information
Unless otherwise required by laws, administrative regulations or pursuant to our agreement, or protect you, your child and other users personal property security, we will not disclose children's personal information.
9. Others
9.1 "Pathea Games Privacy Policy" is general privacy policy uniformly applied in Pathea Games and Service, and is made under and shall be governed by and construed in all respects in accordance with the laws of the People's Republic of China. The contents specified therein, including but not limited to user rights and information security protection measures, etc., are all applicable to the users of Pathea Games and Service. The Children's Guidelines are privacy protection guidelines designed for children, which include special protection of children's personal information. If there is any inconsistency or contradiction between the Children's Guidelines and "Pathea Games Privacy Policy", the Children's Guidelines shall prevail.
9.2 We will generally notify all users of any material changes to this Children's Guidelines, through a notice provided via the Game or Service provided by Pathea and providing any other notice required by applicable law. We will also update the "Last Updated" date at the top of this Children's Guidelines, which reflects the effective date of such policy. In such event, by continuing to use our Services, you agree to be bound by this Children's Guidelines, as amended.
10. Contact Us
When you and your child have any questions to the Children's Guidelines, or any relevant complaints, suggestions, or requests, you and your child are encouraged to contact us via admin@pathea.net. We will review the issues involved as soon as possible, and handle them promptly after verifying your identity, and reply within a maximum of fifteen days or within the period prescribed by laws and regulations.
Pathea Co., Ltd.
In addition to "Pathea Games Privacy Policy", through this Pathea Games Privacy Protection Guidelines for Children ("Children's Guidelines"), we will further help you and your child ("child" or "Children" shall be under the age stipulated by the applicable laws and deemed as child under such laws) understand how we collect, use, store and share your child's personal information, as well as the relevant rights you and your child are entitled to. We will explain to you the collection of children's personal information through prompts, interaction processes, website announcements and other ways and obtain your consent. Please carefully read and fully understand "Pathea Games Privacy Policy" and the Children's Guidelines, before choosing to agree the afore-mentioned privacy policies.
1. Children's Personal Information We Collect
While your child is using Pathea Games and Service, we will only collect your child's information upon your consent or by you and your child's voluntary provision, in order to provide and optimize our services to your child and to ensure your child's account in safe security. We may collect you and your child's personal information through third party service providers, as detailed in the Pathea Games Privacy Policy. We will collect information such as your login time, length of playing games, etc., and guide the minors to play games rationally through ways such as automatically intervening and limiting the game duration of the minors in our system, enabling the function of mandatorily exiting the game, etc. Besides, we may also collect the game behavior data generated during the game (for example, the data such as the click pressure and radius, the relative position of the click, the acceleration direction, and the direction of gravity formed when you operate the game on the terminal device, and the voice data generated when you interact with other players through online voice in the game) to preliminarily determine whether the user is a minor.
Also, in order to verify your custody relationship with your child, we might collect your contact information (including phone number, email address) and other information to help us judge the existence of custody relationship. When the consumption is conducted by a person suspected to be a minor, we will then try to contact his or her guardian for reminders, confirmations and deposition, so as to help the minors have a healthy access to the Internet.
At present, aside from collecting game research information from third-party research organizations to help us upgrade our game products and provide personalized services, we do not take the initiative to obtain your child's personal information from any third party outside of Pathea. In the future, if Pathea needs to obtain your child's personal information indirectly from a third party outside of Pathea, we will strictly comply with the relevant laws and regulations and require the said third party to guarantee the legality of the information it provides.
2. How We Use Children's Personal Information
We will strictly obey the laws, regulations and the agreement with our users, and we will make use of the collected information in accordance with the Children's Guidelines, and Pathea Games Privacy Policy to provide your child with better service.
We use children's personal information as mentioned above in Section 1. We will protect the legitimate rights and interests of minors by initiating anti-addiction system in accordance with national regulations on online game anti-addiction policies. We will make a judgment on whether the real name information of an account belongs to a minor via the identification result of information such as real-name identity, based on which we decide whether the account shall be included in the anti-addiction system. If we use your child's personal information beyond the scope, or a direct or reasonably relevant scope, of the purpose we claimed when collecting that information, we will inform you once again and seek your express consent before using your child's personal information.
3. Storage of Children's Personal Information
3.1 In accordance with laws and regulations, we will store your child's personal information within the information collection territory and strictly keep that information confidential. If we need to transmit personal information collected within the information collection territory to overseas institutions for the sake of cross-border business, we will protect your child's personal information pursuant to domestic laws, administrative regulations and competent authorities' specifications.
3.2 In general, we will only store your child's information for a necessary period for achieving the purpose of providing our services or as required by laws and regulations. After the period specified by laws or competent authorities has expired, we will delete or anonymize your child's personal information in accordance with the requirements of laws and regulations.
4. Security of Children's Personal Information
4.1 In order to ensure the safety of your child's personal information, we will take reasonable and necessary measures under the current level of technology to protect children's information, and adopt measures of physical protection, security technology, management systems and so forth to reduce the risk of information loss, improper usage, unauthorized access, disclosure and alteration, including but not limited to, encrypted data transmission, firewalls and encrypted storage, physical access control, and information access authorization control.
4.2 We have established special management regulations, procedures and organizations to safeguard the security of your child's personal information. For example, we will strictly limit the scope of people that are authorized to access the information, requiring them to comply with confidential obligations and conducting audits.
4.3 If any security incident such as the leak of children's personal information occurs, we will initiate the emergency plan to prevent it from expanding and inform you the basic situation of the security incident, the treatment measures and remedies we will take or have taken as well as our advice for you via announcements, push notifications or emails, etc. in a timely manner. If it is difficult to inform every user, we will issue the warning through public announcements and other methods.
5. Rectification of Children's Personal Information
If you and your child find there is any mistake regarding the child's personal information, you may contact us for rectification.
6. Deletion of Children's Personal Information
6.1 If you and your child find we process children's personal information against the requirements of laws, administrative regulations or our agreement, or beyond the purpose scope or the necessary period, you may contact us to delete relevant personal information.
6.2 If you withdraw your consent, you may contact us and we will deal with it pursuant to relevant laws and regulations.
6.3 If you and your child take the initiative to terminate the use of Pathea Games and Service, we will stop using relevant child's personal information, except as otherwise required by laws, regulations or competent authorities. If we plan to cease any operation of products or services, we will notify you in accordance with relevant laws and regulations.; in the meantime, we will stop using children's personal information in a timely manner and delete or anonymize the stored information.
7. Transfer and Delegation of Children's Personal Information
Generally, we will not transfer to or delegate any third party to process children's personal information. In the case where we have to do so, we will take compliance measures according to laws and regulations, including but not limited to conduct a security assessment on the third party.
8. Disclosure of Children's Personal Information
Unless otherwise required by laws, administrative regulations or pursuant to our agreement, or protect you, your child and other users personal property security, we will not disclose children's personal information.
9. Others
9.1 "Pathea Games Privacy Policy" is general privacy policy uniformly applied in Pathea Games and Service, and is made under and shall be governed by and construed in all respects in accordance with the laws of the People's Republic of China. The contents specified therein, including but not limited to user rights and information security protection measures, etc., are all applicable to the users of Pathea Games and Service. The Children's Guidelines are privacy protection guidelines designed for children, which include special protection of children's personal information. If there is any inconsistency or contradiction between the Children's Guidelines and "Pathea Games Privacy Policy", the Children's Guidelines shall prevail.
9.2 We will generally notify all users of any material changes to this Children's Guidelines, through a notice provided via the Game or Service provided by Pathea and providing any other notice required by applicable law. We will also update the "Last Updated" date at the top of this Children's Guidelines, which reflects the effective date of such policy. In such event, by continuing to use our Services, you agree to be bound by this Children's Guidelines, as amended.
10. Contact Us
When you and your child have any questions to the Children's Guidelines, or any relevant complaints, suggestions, or requests, you and your child are encouraged to contact us via admin@pathea.net. We will review the issues involved as soon as possible, and handle them promptly after verifying your identity, and reply within a maximum of fifteen days or within the period prescribed by laws and regulations.
Pathea Co., Ltd.