Minors’ Personal Information Protection Rules and Instructions for Guardians
Update Date: Dec. 21.2021
Effective Date: Dec. 21.2021
Youdao (Hong Kong) Limited and its affiliates (collectively “Youdao” or “we”) have always been well aware of the importance of minors’ personal information and privacy. We hope to use the Minors’ Personal Information Protection Rules and Instructions for Guardians (hereinafter referred to as "this Policy") to explain the corresponding processing rules and other related matters when we collect and use personal information of minors. Before using our products and services (hereinafter collectively referred to as "Youdao Service"), minors and their parents or other guardians are required to carefully read and thoroughly understand this Policy, especially the terms marked in bold, and only after confirming that minor are fully understood and agreed to all the terms can minor start using it.
Special instructions from the guardian:
If we learn that minor’s child is under the age of 18, we will take special measures in accordance with this policy to protect the personal information we obtained from minor’s child. Please help us protect minor’s children's personal information and privacy security. They are required to read and accept this Policy together under minor’s supervision, and they should use Youdao Service and submit personal information under minor’s consent and guidance. If minor do not agree with the content of this policy, it may cause our products and services to fail to operate normally, or fail to achieve the service effects we intend to achieve, minor should ask minor’s children to stop accessing/using Youdao Services immediately. If minor click to agree to this Policy, or minor’s children uses/continues to use Youdao's service and submits personal information, it means that minor agree to our collection, use, storage and sharing of minor’s children's personal information in accordance with this Policy (including updated versions).
Special instructions for minors:
We suggest: Any minors participating in online activities should obtain the consent of the guardian in advance. If minor are a minor, please notify minor’s guardian to read this Policy together, and seek minor’s guardian's consent and guidance before minor use Youdao Services or submit any personal information. If minor click to agree to this Policy, or if minor use/continue to use Youdao services or submit minor’s personal information, it means that minor have obtained the permission of minor’s guardian, and minor’s guardian agrees that we collect, use, store and share minor’s personal information in accordance with this Policy (including updated version).
This Policy applies to our activities such as collecting, using, storing and sharing personal information of minors through the Internet within the territory of the People's Republic of China. When a minor uses any Youdao service, the guardian agrees to accept the protection of this Policy and the specific minor personal information protection rules and clauses (if any, hereinafter referred to as "specific clauses") issued by us in the individual service. In this case, the specific terms and the terms of this Policy will be effective for guardians and minors at the same time. If there is an inconsistency between a specific clause and the terms of this Policy, the specific clause shall prevail within the bounds of the specific clause. If an individual service we provide does not apply to this Policy, the service will expressly exclude the application of this Policy in an appropriate manner. Regarding the rules for the protection of personal information of minors, if this Policy is inconsistent with the content of the "Youdao Ads Privacy Policy", this Policy shall be applied in priority. If it is not mentioned in this Policy, the "Youdao Ads Privacy Policy" shall prevail.
After reading this Policy, if minor have any questions about this Policy or matters related to this Policy, please contact us through the feedback channels listed in the Section "How to Contact Us" of this Policy. We will answer them as soon as possible.
This Policy will help minors understand the following:
I. How Will We Share, Transfer or Disclose the Minor Information
II. How Will We Share, Transfer or Disclose the Minor Information
III. How Will We Keep, Save and Protect the Minor Information
IV. How to Manage Minor’s Information
V. Service Provided by Third Parties
VI. Notice and Amendment
VII. Application of Law and Jurisdiction
VIII. How to Contact Us
I. Personal Data that We may Collect
When minor use the Youdao services, we may collect and process information that may be directly or indirectly related to minor’s personal identity. In both instances, such information may constitute personal data subject to Privacy Policy.
(I) Information not directly related to minor’s personal identity:
When minor use Youdao Service, we may collect and process information such as the user’s source route, access sequence and so on, such as record the source route and browser software of each User who uses Youdao Service.
(II) Information related to minor’s personal identity:
When minor use Youdao Service , we may collect and process or request minor to provide information related to personal identity, such as personal identification; date of birth, place of birth, gender, personal phone number; online identification information (including system account, IP address, email address, and password and answers to password protection of the foregoing); personal property information (including dealing records, balances, and bank card information); communication information; personal online records and log information (including website browsing records, software usage records, click records, and operation logs); device information (including device model, device MAC address, operating system type and device settings); location information (including positioning information) ; personal tags; content tags; offer quotes, etc.
Please note that if minor upload or post information in public areas that are visible to other users in Youdao Service and minor disclose minor’s personal information in response to information uploaded or posted by others, such information may be collected and used by others. When minor find that Youdao users improperly collect or use information from minor or others, please contact YDinfluencers@rd.netease.com.
II. How will We Collect and Use the Information
(I) We will collect and obtain minor’s information through the following ways:
1. Information provided by minor. For example:
(1) information provided by minor when minor register an account for Youdao Service or use Youdao Service;
(2) sharing information provided by minor to other parties through Youdao Service, and information saved when minor use Youdao Service.
2. Minor’s information shared by other parties. Also sharing information about minor provided by other parties when they use Youdao Service.
3. Minor’s information obtained by us. The information collected, summarized and recorded by us when minor use Youdao Service, such as log information, location information and device information.
(II) COOKIES, log archives and WEB BEACON
We or our third-party partners may obtain and use minor’s information through COOKIES and WEB BEACON and save this information as log information.
By using COOKIES, we provide users with a simple and easy-to-use personalized web experience. A COOKIES is a small amount of data that is sent from a web server to minor’s browser and stored on minor’s computer's hard drive. We use COOKIES to allow its users to benefit. For example, to make the login process of the Youdao virtual community faster, minor can choose to save the username in a COOKIES. This will make it easier and faster to login into Youdao Service next time. COOKIES can help us to determine the webpages and content minor are connected to, time minor spend on certain Youdao Service and the Youdao service minor have chosen.
COOKIES enables us to serve minor better and faster, and to make minor’s experience on Youdao Service more personal. However, minor should be able to control whether and how COOKIES is accepted by minor’s browser. Please check the documentation attached to minor’s browser for more information on this.
We or our third party partners may collect and use minor’s information through COOKIES and WEB BEACON, and store such information.
We use our own COOKIES and WEB BEACON for the following purposes:
(1) Remember minor’s identity. For example: COOKIES and WEB BEACON help us identify minor as our registered user, or save minor’s preferences or other information provided by minor to us.
(2) Analyze minor’s use of our services. We can use COOKIES and WEB BEACON to understand for which activities minor use Youdao Service, or which services or service is the most popular, We may request guardian and minor’s consent prior to using COOKIES and WEB BEACONS for these purpose.
(3) Advertising optimization. COOKIES and WEB BEACON help us to provide minor with advertisements related to minor based on minor’s information instead of general advertising, We may request guardian and minor’s consent prior to using COOKIES and WEB BEACONS for these purpose.
While we use COOKIES and WEB BEACON for the foregoing purposes, we may summarize and provide the information collected through COOKIES and WEB BEACON to advertisers and other partners to analyze how minor and other users use Youdao Service and for advertising services.
Minor can also reject or manage COOKIES or WEB BEACON through the browser (if minor access Youdao Services via a browser) or user selection mechanism. However, please note that if minor disable COOKIES or WEB BEACON, we may not be able to provide minor with the best service experience, and some services may not work properly. At the same time, minor will still receive ads, but the relevance of these ads to minor will decrease.
The following links provide instructions for managing cookie settings of commonly used browsers:
• Chrome
• Safari
In addition, if minor do not want Google Analytics to be used in minor’s browser, minor can
• disable the Google Analytics browser add-on at https://tools.google.com/dlpage/gaoptout; and/or
• opt-out through the Network Advertising initiative consumer opt-out system accessible at the following link: http://optout.networkadvertising.org/#!/.
In addition, minor may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.
Moreover, minor can use another online service enabling minor to manage the advertisement cookies placed on minor’s devices: http://www.minor’sonlinechoices.com/.
(III) After obtained guardian’s consent, we will collect and use minor’s information for the following purposes:
1. help minor to complete the registration
In order for us to provide services for minor and/or to perform contract, minor need to provide basic registration information, including email address, and create minor’s username and password. Minor’s personal data is therefore processed for these purposes in order to provide minor with and perform the services based on minor’s engagement with us. Without this personal data, we are not able to provide minor with our services.
2. provide goods or services to minor
The information we collect and use is necessary to provide minor with Youdao Service. In case lack of relevant information, we will not be able to provide minor with the core content of Youdao Service, such as:
(1) In relation to some service projects, in order to facilitate the delivery goods or services to minor, minor need to provide the consignee’s personal identification information, name, shipping address, postal code, consignee, contact telephone number, payment status and other information. If minor refuse to provide such information, we will not be able to complete the relevant delivery service. If minor order goods or services for others through Youdao Service, minor need to provide the aforementioned information of the actual orderer. Before providing us with the aforementioned information of the actual orderer, minor need to make sure that minor have obtained their authorized consent.
(2) In order to display the order information of minor’s account, we will collect the order information generated during minor’s use of Youdao Service to show minor and facilitate minor’s order management;
(3) When minor contact us, we may store information such as minor’s communication/call history and conversation or the contact information minor left behind in order to contact minor or help minor solve problems, or to document the solutions and results of the related issues.
(4) In order to confirm the transaction status and provide after-sales and dispute resolution services for minor, we will collect minor’s transactions, payment, and logistics information related to the progress of the transactions through minor’s transaction objects, payment agents, and logistics companies selected based on such transactions, or we will share minor’s transaction information with the above service providers.
(5) To protect minor’s identity, we may request minor to bind minor’s third-party platform account to prevent minor’s identity from being replaced, faked, etc. We may read and store minor’s profile picture, ID, fans profiles, etc. on the third-party platform that minor bound, so that advertisers who need relevant candidate are better able to find minor and collaborate.
(6) To help minor match more suitable orders, we may request minor to provide minor’s personal tags, content tags and minor’s expected order quotes for different types of collaborations.
Minor’s personal data is therefore processed for these purposes in order to provide minor with and perform the services based on minor’s engagement with us. This personal data may also be processed in order to safeguard minor’s legitimate interests of obtaining pertinent information and other related data regarding minor’s services and orders obtained from Youdao.
3. Push notifications to minor
(1) Show and push products or services for minor. We may use minor’s information, minor’s browsing and search records, device information, location information, order information to extract minor’s browsing, search preferences, behavioral habits and so on, and based on feature tags, use emails, text messages or other methods to send marketing information, provide or promote our or third parties’ following goods and services to minor:
Our goods and services, including: payment service, internet search service, applications software and service, data management software and service, e-commerce, information and communications software and services ("Internet services"); and
Third party goods and services, including: internet services, financial services, points and rewards programs, and other goods and services we believe may be related to minor.
(2) Send notices to minor. We may send minor notices related to the service when necessary (for example when we suspend a single service, change, or stop providing a single service due to system maintenance).
If minor do not wish to continue to receive messages we have pushed, minor may request us to stop the push. For example: According to the email unsubscribe guidelines, minor may request us stop sending promotional email messages. However, except when we send messages according to the provisions of the law or the service agreement of individual services.
4. Provide minor with security
To ensure the authenticity of minor’s identity and provide minor with better security, minor can provide us with sensitive personal information such as identification and other information to complete real-name authentication.
In addition to authentication, we may use minor’s information for customer service, security precautions, fraud monitoring, archiving and backup purposes to ensure the security of the services provided by us to minor; we may use or integrate minor’s information collected by us, and our partners obtain the information authorized by minor or legally shared information to comprehensively determine minor’s account and transaction risk, conduct identity verification, detect and prevent security incidents, and take necessary records, audits, analysis and disposal actions according to the law.
This personal data is therefore processed for these purposes in order to safeguard minor’s legitimate interests of ensuring the security of minor’s connection and minor’s personal data while minor are obtaining information and services from Youdao.
5. Improve our services
We may use the information collected through a certain Youdao Service for our other services. For example, minor’s information collected when minor use one of Youdao Service may be used in another Youdao Service to provide minor with specific content or to show minor information that is relevant to minor, but not universally pushed; we may ask minor to participate in surveys about Youdao Service to help us improve existing services or design new services; at the same time, we may use minor’s information for software updates.
This personal data is therefore processed for these purposes in order to safeguard our legitimate interests of improving our services in this way.
6. Other use of anonymous information
Guardian and minor understand and agree that, in certain instances, upon the collection of minor’s information, we will de-identify and fully anonymize the data through technical means, so that it no longer constitutes personal data directly or indirectly related to an individual, such as minor. The de-identified information will not identify minor or be related to minor. In such case, we have the right use such de-identified information to analyze and commercialize the user database.
If we use minor’s information for other purposes not specified in this Privacy Policy, we will ask for guardian and minor’s consent in advance.
7. Exceptions to get authorization
According to relevant laws and regulations, collecting minor’s information under the following circumstances does not need to get minor’s authorization:
(2) directly related to national security and national defense security;
(3) directly related to public security, public health or major public interests;
(4) directly related to criminal investigation, prosecution, trial and execution of judgment;
(5) in order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;
(6) the personal information involved is disclosed to the public by the subject of personal information;
(7) necessary for signing and performing the contract as required by the subject of personal information;
(9) necessary to maintain the safe and stable operation of the products or services provided, such as finding and disposing of faults of the products or services.
III. How Will We Share, Transfer or Disclose the Information
(I) Share
Guardian and minor agree that we share minor’s personal information with our affiliates or related legal entities, and some business partners that we cooperate with (collectively referred to as "information recipients") in accordance with this Policy.
We will actively help minor understand the storage and use of personal information by the information recipient, as well as minor’s rights to access, correct, delete, and cancel minor’s account.
Except for the following circumstances, without guardian and minor’s consent, we will not share minor’s personal information with any third party other than the information recipient:
1. Provide minor with our services. We may share minor’s information with our partners and other third parties in order to achieve the core functions minor need or to provide the services minor need, such as to provide Advertiser and Influencer with corresponding order information;
2. Maintain and improve our services. We may share minor’s information with our partners and other third parties to help us provide minor with more targeted and improved services, such as communication service providers that send emails or push notifications on our behalf;
3. To achieve the purposes described in Section II “How will we collect and use the information” of this Privacy Policy;
4. perform our obligations under this Privacy Policy or other agreements entered into between minor and us and exercise our rights;
5. share with third parties including the partners who entrusts us to promote, but we will only provide such third parties with the information relating to the coverage and effectiveness of the promotion, not any information which will identify minor, such as name, telephone number or email address; or we will summarize these information so that it will not identify minor personally. For example, we may display minor’s personal tags and content tags to third parties so that minor can reach a more suitable collaboration; we can notify such third parties how many people viewed their promotional information or purchased their goods after viewing such information, or provide them with statistical information that could not identify personal identity and help them understand their audiences or customers.
6. To the extent permitted by laws and regulations, in order to comply with the law, protect us and our affiliates or partners, minor or other Youdao users or the public interest, property or safety from harm, such as to prevent fraud and other illegal activities and reduce credit risk, we may exchange information with other companies and organizations. However, this does not include information sold, rented, shared, or otherwise disclosed for profit making in violation of the commitments made in this Privacy Policy.
7. to help minor deal with minor’s disputes or controversy with others upon minor’s legitimate request;
8. provide minor’s information in response to the legitimate requests of minor’s guardian;
9. provide according to the service agreement signed with minor (including the online signed electronic agreement and the corresponding platform rules) or other legal documents;
10. provide based on academic research;
11. provide based on the social and public interests that are in conformity with laws and regulations.
We will only share minor’s information for legitimate, justifiable, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share the information, we will sign strict confidentiality agreements with them and ask them to process information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.
(II) Transfer
1. As with the continuous development of our business, we may conduct mergers, acquisitions, asset transfers or similar transactions, and minor’s information may be transferred as part of such transactions. We will ask new companies and organizations that hold minor’s information to continue to be bound by this Privacy Policy. Otherwise, we will ask the company and organization to ask guardian and minor for authorization again.
2. With guardian and minor’s explicit consent, we will transfer minor’s information to other parties.
(III) Disclosure
We will disclose minor’s information only under the following conditions and in compliance with industry-standard security measures:
1. disclose minor’s designated information in the manner to which guardian and minor explicitly agree according to minor’s needs;
2. Where it is necessary to provide minor’s information in accordance with the requirements of laws and regulations, mandatory administrative enforcement or judicial requirements, we may disclose minor’s information in accordance with the type of information requested and the manner of disclosure. In compliance with laws and regulations, when we receive the above request for disclosure of information, we will require the recipient to show corresponding legal documents, such as subpoenas or investigation letters. We firmly believe that the information required to be provided by us should be as transparent as possible to the extent permitted by law. We have carefully reviewed all requests to ensure that they are legally valid and are limited to the data that law enforcement agencies have obtained for their specific legal purposes.
(IV) Under the following circumstances, sharing, transferring, and disclosing minor’s personal information does not require guardian and minor’s prior authorization and consent:
(1) related to the fulfillment of the obligations prescribed by laws and regulations by the personal information controller;
(2) directly related to national security and national defense security;
(3) directly related to public security, public health or major public interests;
(4) directly related to criminal investigation, prosecution, trial and execution of judgment;
(5) in order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;
(6) the personal information involved is disclosed to the public by the subject of personal information;
(7) collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
According to laws and regulations, sharing and transferring personal information that has been de-identified, and ensuring that the information recipient cannot restore and re-identify the subject of personal information does not belong to the external sharing, transfer, and public disclosure of personal information. Storage and processing that information will not need to notify minor separately and obtain guardian and minor’s consent.
IV. How Will We Keep, Save and Protect the Information
(I) We retain minor’s information only during the period required by the purposes described in this Privacy Policy and within the time limits required by laws and regulations. Youdao’s criteria for judging the aforementioned period include:
1. Completing the transaction objectives related to minor, maintaining the corresponding transaction and business records, and responding to minor’s possible inquiries or complaints;
2. Ensuring the safety and quality of the services provided by the Platform;
3. If guardian and minor agree to a longer retention period;
4. If there are other special provisions on the retention period.
After minor’s personal information exceeds the retention period, Youdao will delete minor’s personal data or anonymize it as required by applicable laws (if minor are under 18, Youdao will process minor’s personal information in accordance with relevant laws and regulations after minor’s personal information exceeds the retention period). If it is impossible to delete it according to relevant requirements due to special circumstances, Youdao will explain this part to minor.
If we terminate our services or operations, we will stop collecting minor’s personal information in a timely manner, notify minor in advance in accordance with relevant laws and regulations, and delete or anonymize minor’s personal data after we terminate our services or operations, unless otherwise provided by laws, regulations or regulatory authorities.
(II) The information we collect and generate through our Services may be stored and processed within the territory of PRC or in any other country/region where Youdao (Hong Kong) Limited, its affiliates and/or service provider maintains facilitates. If minors are located in the EU or any jurisdiction where the laws governing data collection and use may differ from those in PRC, please note that we may transfer information, including personal information, to countries, regions and jurisdictions where there is no same data protection as minor’s jurisdiction. Nevertheless, we will take all steps reasonably necessary to ensure the secure processing of any personal data in accordance with this Privacy Policy. Such transfers are carried out in accordance with appropriate safeguards. In these cases, we will ensure that minor’s personal information is adequately protected in accordance with this Policy as well as laws and regulations.
We will take the following measures to protect minor’s information:
1.Data Security Technology Measures
We will adopt industry-standard security protection measures, including the establishment of reasonable system specifications and security technologies to prevent unauthorized access and modification to minor’s information, avoid the damage or loss of data. Web services use a variety of encryption technologies. For example, in some services, we will use encryption technology (such as SSL) to protect minor’s information, adopt encryption technology to encrypted storing minor’s information, and isolate via isolation technology. In the use of information, such as information display, information-related computing, we will use a variety of data desensitization technologies to enhance the security of information in use, and use strict data access control and multiple identity authentication technologies to protect the date from being used illegally.
2. Other Security Measures Adopted by Us to Protect the Information
We manage and regulate the storage and use of information by establishing a data classification hierarchy, data security management rules, and data security development regulations.
We conduct comprehensive data security control through information access confidentiality agreements, monitoring and auditing mechanisms.
Strengthen security awareness. We also hold security and privacy protection training courses to strengthen employees’ awareness of the importance of protecting information.
3.We only allow Youdao employees and partners who need to know the information to access to minor’s information, and set strict access control and monitoring mechanisms for this purpose. We also require that all personnel who may have access to minor’s information perform the corresponding confidentiality obligations. Failure to perform these obligations may result in legal liability or suspension of cooperation with Youdao.
4.We will take all reasonably practicable steps to ensure that no unrelated information is collected.
5.The internet is not an absolutely secure environment, and the methods used to communicate with other users, such as e-mail, instant messaging, social software or other service software, cannot be determined to be fully encrypted. We recommend that minor use complicated passwords when using such kinds of tools and carefully protect minor’s Information security.
6. The internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information minor send to us. If our physical, technical, or management protective facilities are destroyed, resulting in unauthorized access to information, public disclosure, alteration, or destruction, and minor’s legitimate rights and interests are damaged, we will assume corresponding legal liabilities.
7. Dealing with Security Incidents
When communicating with third parties or purchasing goods and services through Youdao Service, minor will inevitably disclose minor’s information to the counterparty or potential counterparties, such as contact information or postal address. Please protect minor’s information and provide it to others only when necessary.
In order to cope with possible risks such as information disclosure, damage and loss, we have formulated a number of systems to clarify the classification and grading standards for security incidents and security vulnerabilities and the corresponding processing procedures. We also set up a specific emergency response team for security incidents. According to the requirements of the security incident handling regulations, we will initiate security preplans for different security incidents, conduct stop loss, analysis, positioning, formulate remedial measures, and trace and crack with relevant departments jointly.
Upon the occurrence of unfortunate information security incidents, we will promptly inform minor in accordance with the requirements of laws and regulations: the basic information and possible impact of security incidents, the measures we have taken or will take, and recommendations on minor’s own precautions and risk reduction, remedial measures for minor and so on. At the same time, we will promptly inform minor of the incident-related situation by email, letter, telephone, push notification, etc. When it is difficult to notify the information subject one by one, we will issue a notice in a reasonable and effective manner. Meanwhile, we will also voluntarily report the disposal of information security incidents in accordance with regulatory requirements.
Please understand that due to technical limitations and risk prevention limits, even if we have strengthened our security measures as much as possible, we cannot always guarantee 100% security of the information. Minor need to understand that the system and communication network used by minor to access to Youdao Service may have problems due to circumstances beyond our control.
V. How to Manage Minor’s Information
We encourage minor to access, correct or delete minor’s information to make it correct, more accurate and effective. Minor can access minor’s information through Youdao Service, and complete by minor’sself or request us to modify, supplement or delete with the instructions below. We will use appropriate technical methods to ensure minor can access, update, correct and delete minor’s own information or other information provided when using Youdao Service as much as possible. Please understand that minor’s decision to correct, delete, withdraw authorization or discontinue the use of Youdao Services does not affect the processing of personal information that we have previously conducted based on minor’s authorization.
For minor’s information collected through COOKIES and WEB BEACON, we also explain the selection mechanism provided to minor in Section II “COOKIES, log archives and WEB BEACON”of this Privacy Policy.
In case minor have any question or request to access, correct, and delete minor’s data, minor can contact us pursuant to the means explained in Section X below.
(I) Access minor’s personal information
- Account personal information: If minor want to access the basic personal information in minor’s account (including profile picture, nickname, brief introduction, contact information, bank information), minor can log in to the web account to access it through "Personal Information".
- Order personal information: Minor can check the status of all minor’s orders through "My Orders".
(II) Correct minor’s personal information
If minor want to correct the basic personal information in minor’s account (including profile picture, nickname, brief introduction, contact information, bank information), minor can log in to the web account to modify it through "Personal Information-Basic Information."
(III) Delete minor’s personal information
Minor can delete some parts of minor’s personal information through the methods listed in "(I) Access minor’s personal information". When minor delete minor’s personal information, we may require minor to verify minor’s identity to protect the security of minor’s personal information.
In the following situations, minor can request us to delete personal information:
(1) If our handling of personal information violates laws and regulations;
(2) If we collect and use minor’s personal information without guardian and minor’s authorization;
(3) If our handling of personal information seriously violates the agreement with minor;
(4) If we no longer provide minor with Youdao services.
(IV) Publish and Share
Many of our service allow minor to share minor’s information not only with minor’s social network, but also with all users who use such service, such as information uploaded or posted by minor on Youdao Service, minor’s response to the information uploaded or posted by others, minor’s personal information uploaded or published via email or in the public area which is available to non-specific users in Youdao Service, and also the location data and log information related to such information. As long as minor do not delete the information minor published or shared, such information may remain in the public domain; even if minor delete the shared information, such information still may be cached, copied or saved independently by other users or third parties who are not under our control, or be kept in the public domain by other users or such third parties. If minor publish or share information through the above channels, which results in the disclosure of minor’s information, we will not be liable for the same. Therefore, we remind minor and ask minor to carefully consider whether to publish or share minor’s information through the above channels.
(V) Cancellation
If minor no longer use Youdao Service, in accordance with this Service Agreement and relevant laws and regulations, minor can log in to the web account to cancel account through the "Personal Information - Cancel Account" or contact us pursuant to the means explained in Section X “How to Contact Us”. Normally, we will cancel minor’s account within 15 working days, at which time we will stop providing Youdao Service for minor. After minor’s account is cancelled or deleted, all service information and data related to Youdao Service will be deleted or anonymized, except minors haven’t fulfilled contractual obligations or as otherwise provided by laws and regulations.
(VI) Change the Scope of minor’s Consent
Some information is required to use Youdao Service, but the provision of most other information is on guardian and minor’s decision or consent. Where the processing of personal data is based on guardian and minor’s consent, minor can always select whether or not to disclose the information. Guardian and minor may withdraw guardian and minor’s consent by contacting us pursuant to the means explained in Section X below. Normally, we will respond within 15 working days.
After minor withdraw guardian and minor’s authorization, we are unable to continue to provide minor with the service corresponding to the withdrawal of the consent, and will not process minor’s corresponding information. However, guardian and minor’s decision to withdraw guardian and minor’s consent will not affect the information processing previously based on minor’s consent.
(VII) Tips for Sensitive Information
Certain information may be considered being sensitive information because of its particularity, such as minor’s bank information, withdrawal record, virtual property information, system account, email address and related password, telephone number, web browsing history, location information, information of minors, etc.
Please note the content and information provided, uploaded or posted by minor on Youdao Service (such as personal information or third-party account information) may reveal minor’s sensitive information. Minor need to carefully consider whether to use Youdao Service to disclose minor’s sensitive information. When minor do so, we will understand that minor give guardian and minor’s explicit consent to Youdao to process such sensitive information.
Please be cautious and pay attention to minor’s personal sensitive information, guardian and minor agree that minor’s sensitive information will be treated in accordance with the purposes and manner described in this Privacy Policy.
(VIII) Respond to minor’s above requests
To ensure safety, minor may need to provide a written request or prove minor’s identity in other ways. We may ask minor to verify minor’s identity before processing minor’s request. For minor’s reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the circumstances. We may reject requests which are unreasonably repeated, requiring too many technical means (for example, the need to develop new systems or fundamentally change existing practices), bringing risks to the legitimate rights and interests of others or are very impractical (for example, involving information stored on backup tapes).
In the following situations, we may not be able to respond to minor’s request:
(1) related to our fulfillment of the obligations provided by laws and regulations;
(2) directly related to national security or national defense security;
(3) directly related to public safety, public health, and major public interests;
(4) directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
(5) we have sufficient evidence to show that minor have subjective malice or abuse of rights;
(6) to protect minor’s or other individuals’ life, property and other major legal rights and interests but is difficult to obtain the consent of the person;
(7) responding to minor’s request will cause serious damage to the legitimate rights and interests of minor or other individuals or organizations;
(8) involving trade secrets.
* If minor is located in the European Union, pursuant to applicable data privacy laws in EU, minor and minor’s guardian have the following rights with respect to minor’s personal data:
1. The right to know. Minor and guardian have the right to understand how we will collect and process minor’s personal data and how minor and guardian can manage minor’s personal data by reading this Policy and related rules.
2. The right to request a copy of minor’s personal data. Minor and guardian have the right to request a copy of minor’s personal data from us and we will provide minor’s requested personal data no more than one month (or two months in complex cases) after receipt of the request. If we fail to meet such requirements, we will notify minor and/or guardian why we failed to provide minor’s personal data within one month from the date of receipt of the request.
3. The right to access. Minor and guardian have the right to access minor’s personal data and confirm whether minor’s personal data is being processed.
4. The right to correct. Minor and guardian have the right to correct minor’s personal data if minor and/or guardian believe that it is incorrect or incomplete.
5. The right to delete. Minor and guardian have the right to request us to delete minor’s personal information we previously stored and/or data provided by third parties under certain conditions, such as when that personal information is no longer needed for the purpose for which it was collected or processed.
6. The right to restrict processing. Under certain conditions, minor and guardian have the right to request us to restrict processing minor’s personal data for a period of time so that we can verify the accuracy of such personal data, such as when minor and guardian question the accuracy of minor’s personal data.
7. The right to data portability. The right to data portability allows minor to move, copy, or transfer minor’s personal data from one entity to another, under certain conditions.
8. The right to object to processing. Minor and guardian have the right to object to our processing of minor’s personal data, including data processing, data portraits. etc. for legitimate interests and direct marketing purposes. Minor and guardian may choose whether to provide us with minor’s personal information and bind minor’s social media platform or not.
If minor and/or guardian wish to exercise one of these rights, minor and/or guardian may contact us in accordance with the procedures set out in this Policy or the contact information described in Section X “How to Contact Us”. Minor and guardian also have the right to file a complaint with minor’s local data protection authority if they believe that our processing of minor’s personal information violates applicable laws.
VI. Service Provided by Third Parties
Youdao Service may link to the social media or other services provided by third parties (including websites or other forms of services), including:
(1) Minor may use “share” button to share some content with Youdao Service, or minor can use a third-party service to log into Youdao Service. These features may collect minor’s information (including minor’s log information), and may put COOKIES on minor’s computer to properly operate the above features;
(2) we provide minor with links through advertisements or other means of our service to enable minor access to the services or websites of third parties; and
(3) other circumstances of accessing to the services of third parties.
For the purposes stated in this Policy, we may access SDKs or other similar applications provided by third-party service providers and share some of minor’s information collected by us in accordance with this Policy with such third-party service providers, in order to provide better customer service and user experience. At present, the third-party service providers we access mainly include the following types:
- Used for payment related services, including order payment, transaction behavior verification, income settlement, payment information summary and statistics, etc.;
- Used for third-party authorization services, including third-party account login, sharing relevant content to third-party products, etc.;
Some third-party SDKs or similar applications accessed by us may collect minor’s personal information. If minor use such services provided by third parties in our services, guardian and minor agree that minor’s information may be directly collected and processed by them. We will evaluate the legality, legitimacy and necessity of collecting personal information by such third-party services, and require such third parties to take measures to protect minor’s personal information and strictly abide by relevant laws, regulations and regulatory requirements. Minor can click on <Third-party Information Sharing Checklist>, understand the basic situation of our main access third-party, each individual service may have different access to third-party. If minor want to know the details of the specific individual service access to the third-party, please go to the corresponding service page and check the specific terms and related pages of our individual services. Guardian and minor may also withdraw guardian and minor’s authorization by contacting us pursuant to the means explained in Section X below. Normally, we will respond within 15 business days.
The services described above are operated by the relevant third parties. Minor’s use of such third party services (including any information minor provide to such third parties) must comply with the third party's own Terms of Service and personal Information Protection Statement (not this Policy), which minor must read carefully. We will only share minor’s information for legitimate, necessary and specific purposes. We will require them to fulfill their confidentiality obligations and take appropriate security measures.
VII. Protection of Minors
We recommend that any minor who participates in online activity should obtain prior consent from parents or his/her legal guardian (“Guardian”). We will protect information about minors in accordance with relevant national laws and regulations.
We encourage parents or Guardians guide the minors to use Youdao Service. We recommend minors encourage their parents or Guardians to read this Privacy Policy and advise minors to seek parental or Guardian’s consent and guidance before submitting information.
Where the processing of personal data of an under-18 minor is based on the legal basis of “consent”, an under-18 minor must not use Youdao Service for any purpose without first obtaining Guardian’s consent to this Privacy Policy. We do not knowingly process personal data from any under-18 minor without such consent. If minor believe we have any personal data from any under-18 minor under minor’s guardianship, please contact us via the contact information set forth in Section X, we will promptly investigate (and remove, if applicable) such Personal Information.
VIII. Notice and Amendment
We may revise the terms of this Privacy Policy in due course, and such modifications form part of this Privacy Policy. For major changes, we will provide more noticeable notices, If guardian and minor do not agree to these changes, guardian and minor may choose to stop using Youdao Service. In such case, if minor continue to use Youdao Service, guardian and minor agree to be bound by this Privacy Policy as revised.
We encourage guardian and minor to review our Privacy Policy each time minor use Youdao Service.
We may publish service-related announcements when necessary (for example, when we suspend certain service due to system maintenance). Minor may not be able to cancel these announcements that are related to the service and that are not in the nature of promotion.
Finally, guardian and minor must be obligated to keep minor’s account and password confidential. In any case, please take care of such information safely.
IX. Application of Law and Jurisdiction
The terms of this Policy shall be governed by the laws of the People’s Republic of China, without regard to principles of conflict of laws. Any dispute arising from or in connection with this Policy, if no agreement could be reached by the Parties through friendly negotiation, it shall be submitted to China International Economic and Trade Arbitration Commission (“CIETAC”) for arbitration in accordance with its rules for the time being in force. The seat shall be Beijing and the tribunal shall consist of three arbitrators. The arbitral award shall be final and binding on the parties.
X. How to Contact Us
Our contact address is: NetEase Building, No.7, West Zone of Zhongguancun Software Park, No. 10 XibeiWangdong Road, Haidian District, Beijing, China.
We will protect minor’s personal information in accordance with this Policy. We have established a dedicated department for personal information protection, if guardian and minor have any complaints or reports about the security of online information, or if guardian and minor have any questions, comments or suggestions about this Privacy Policy and matters regarding minor’s information, and any questions regarding this statement or Youdao's privacy practices, please contact us. The phone number is: 4006789163. The email address is YDinfluencers@rd.netease.com.
Under normal circumstances, we will reply within 15 days after receiving minor’s questions, comments or suggestions and verifying the identity of the guardian and/or the minor.