Children's Privacy Protection Statement

Updated Date: October 21, 2021

Effective Date: October 21, 2021

Tencent PC Manager is a computer security software provided by Shenzhen Tencent Computer Systems Company Limited (hereinafter referred to as “we”, “us”, or “Tencent”), with its registered address at 35th Floor, Tencent Building, Kejizhongyi Avenue, Hi-tech Park, Nanshan District, Shenzhen. During the product operation process, we may also operate jointly with our affiliated companies, such as through channel cooperation, brand collaboration, etc. We will use the Tencent PC Manager Children’s Privacy Protection Statement to help you understand how we collect, use, store, and share personal information, as well as the relevant rights you enjoy.

Tencent is committed to protecting the personal information of children who use our products or services. The Tencent PC Manager Children’s Privacy Protection Statement (hereinafter referred to as “this Statement”), along with the Tencent Privacy Policy and the Tencent PC Manager Privacy Protection Guidelines, are designed to explain to guardians (hereinafter referred to as “you”) and children how we collect, use, store, and process children’s personal information, as well as the methods we provide for you and the child to access, correct, delete, and protect such information. Unless otherwise agreed, the terms and abbreviations used in this Statement shall have the same meanings as those in the Tencent PC Manager Software License and Service Agreement, the Tencent Privacy Policy, and the Tencent PC Manager Privacy Protection Guidelines.

Special Notice to Children’s Guardians: If you are the guardian of a child user, please read this Statement carefully and choose whether to agree to it. We hope you will join us in protecting children’s personal information, educating and guiding children to enhance their awareness and ability to protect personal information, and instructing, reminding, and requiring them not to provide any personal information to any network product and service providers without your consent.

Special Notice to Children: If you are a minor under the age of 14, you need to read this Statement carefully together with your guardian, and use our products, services, or provide information to us only after obtaining your guardian’s consent.

Please carefully read and fully understand the Tencent Privacy Policy, the Tencent PC Manager Privacy Protection Guidelines, the privacy protection guidelines of specific products (if any), and this Statement, and then choose whether to agree to the relevant privacy policies and whether to agree to let you and the child under your guardianship use our products or services. If you do not agree to the contents of the relevant privacy policies and this Statement, or do not agree to provide the information necessary for providing the services, it may result in our products or services failing to operate normally or failing to achieve our intended service results, and you and the child under your guardianship may be unable to normally use our products, services, or related specific business functions.

By clicking “Agree”, you indicate your consent for us to collect, use, and process the information of you and the child under your guardianship in accordance with the Tencent Privacy Policy, the Tencent PC Manager Privacy Protection Guidelines, the privacy protection guidelines of specific products (if any), and this Statement.

Please understand that this Statement only applies to our products or services specifically directed at children under 14 years of age, products or services with functional sections specifically directed at children under 14 years of age, or products or services that require users to input birthday, age information, etc., that can identify the user’s age. For products or services that cannot identify or do not actively identify the user’s age, the Tencent Privacy Policy, the Tencent PC Manager Privacy Protection Guidelines, and the privacy protection guidelines of specific products (if any) shall apply. The products and services we provide may include those provided by third parties, and you may also log in to and use third-party products and services through our products (such as QQ or WeChat). Please note that such third parties may collect, use, or process children’s relevant information, which requires your separate consent obtained by such third parties. We recommend that you require children to seek your consent before authorizing third parties to collect and process any of their personal information.

We remind you that important clauses in this Statement that are (or may be) closely related to the rights and interests of you and the child under your guardianship have been specially brought to your attention through bolded text; please review them carefully.

If you have any questions or rights requests regarding personal information while reading this Statement, we have provided dedicated feedback channels for you, specifically detailed in the “Contact Us” section of this Statement, and we will respond to you as soon as possible.

What Information We Collect

Tencent strictly complies with the provisions of laws and regulations and its agreements with users. Depending on the specific circumstances of the products or services chosen by users, we collect the following personal information of you and the child under your guardianship:

For our products and services specifically directed at children under 14 years of age, or certain functional sections of products and services, or products or services requiring users to input birthday, age information, etc., that can identify the user’s age, if such products or services are registered for or used, we will ask the user to provide personal birthday information to identify whether the user is a child under 14 years of age. In accordance with legal and regulatory requirements, we will allow the child to continue using the relevant products or services only after obtaining guardian consent.
When we identify a user as a child under 14 years of age based on the aforementioned information provided by the user, we will collect your contact information, including your mobile phone number and email address, and use this information to contact you to verify the guardianship relationship between you and the child under your guardianship. Depending on the specific plan for verifying the guardianship relationship and obtaining your consent for the product or service, we may also link your account with the child’s account so that you can be aware of and manage the child’s personal information rights. In certain products or services involving transactions, we may request the collection and linking of your bank card-related information so that you can be aware of and manage the transaction behaviors of the child user. If the product or service involves features such as uploading an avatar, we strongly recommend that you guide the child not to upload real portrait photos and similar personal information while using our products or services.
During the process of a child using products or services, we will collect relevant information. For details, please refer to the “Information We Collect” section in the Tencent PC Manager Privacy Protection Guidelines to learn more about the other children’s personal information we collect.
If we need to collect the personal information of you or the child under your guardianship beyond the aforementioned scope, we will inform you again and obtain your consent.

Please understand that you may choose whether to fill in or provide us with specific information. However, if you do not fill in or provide certain specific information, it may cause our products or services to fail to operate normally, or fail to achieve the service results we intend to reach, and you and the child under your guardianship may be unable to normally use our products, services, or related specific business functions.

How We Use This Information

We strictly comply with the provisions of laws and regulations and our agreements with users. We will use the collected information of you and the child under your guardianship for the following purposes:

Verifying the identity of the child and the guardian;
Providing necessary products or services, as well as specific functions of the products or services;
For the purposes of optimizing products or services, ensuring security, and conducting service surveys.

If we need to use the personal information of you or the child under your guardianship beyond the aforementioned purposes, we will inform you again and obtain your consent.

Circumstances of Sharing, Transferring, and Disclosing Children’s Personal Information

We strictly limit the circumstances under which we share, transfer, and disclose children’s personal information in compliance with legal and regulatory requirements:

Generally, Tencent will not share children’s personal information with third parties. We may only share children’s personal information with third parties with the prior consent of the guardian.
Sharing with Guardians: We will share some of the child’s personal information (such as the child user’s username, account, password, as well as the transaction contents of the child user in certain of our products and services) with the guardian, and the guardian may access and manage the relevant personal information.
Solely for the purpose of external processing, we may share children’s personal information with third-party partners (third-party service providers, contractors, agents, application developers, etc. For example, communications service providers who send emails or push notifications on our behalf, or map service providers who provide location services to us), who may not be located in your jurisdiction, allowing them to process such information for us in accordance with our instructions, privacy policy, and relevant confidentiality and security policies.

If we entrust third parties to process children’s personal information, we will conduct security assessments of the entrusted parties and the entrusting actions, sign entrustment agreements, and require that the entrusted parties’ processing actions do not exceed our scope of authorization. Our entrustment of third parties to process children’s personal information is primarily for the following purposes:

Providing our services to children;
Fulfilling the purposes described in the “How We Use This Information” section;
Performing our obligations and exercising our rights under the Tencent Privacy Policy, the Tencent PC Manager Privacy Protection Guidelines, and this Statement;
Understanding, maintaining, and improving our services.

If we share the information of you and the child with the aforementioned third parties, we will conduct a security assessment and adopt measures such as encryption, anonymization, and de-identification processing to ensure the information security of you and the child.

With the continuous development of our business, when transactions such as mergers, acquisitions, or asset transfers result in the sharing of the personal information of you and the child with third parties, we will inform you of the relevant circumstances through push notifications, announcements, or other forms. We will continue to protect or require the new manager to continue to protect the personal information of you and the child in accordance with laws and regulations and standards no lower than those required by this Statement.
We may use the collected children’s information for big data analysis after anonymization processing, such as forming heat maps or insight reports that do not contain any personal information.

We may publicly disclose and share with our partners statistically processed information that does not contain personally identifiable content, to understand how users use our services or to let the public understand the overall usage trends of our services.

Generally, we prohibit the external disclosure of children’s personal information, but we may disclose children’s personal information for the following purposes:
Complying with applicable laws, regulations, and other relevant provisions;
Complying with court judgments, rulings, or other legal procedural requirements;
Complying with the requirements of relevant government agencies or other legally authorized organizations;
When we reasonably believe it is necessary to comply with laws, regulations, and other relevant provisions;
For purposes that are reasonable and necessary to execute relevant service agreements or this Statement, safeguard public social interests, and protect the personal and property safety or other lawful rights and interests of our clients, us or our affiliated companies, other users, or employees.

Storing Children’s Personal Information

Tencent will adopt technical measures such as encryption to store children’s personal information and ensure information security. The storage of children’s personal information by Tencent will not exceed the necessary period for achieving its collection and usage purposes. Please refer to the chapters “Location and Duration of Stored Information” and “Information Security” in the Tencent PC Manager Privacy Protection Guidelines to learn in detail how we store and protect children’s personal information.

When our products or services cease operations or when the storage period for the personal information of you and the child expires, we will notify you and the child through forms such as push notifications or announcements, and will delete or anonymize the personal information of you and the child within a reasonable timeframe.

Managing Children’s Personal Information

During the period when a child user uses Tencent’s products or services, to enable you and the child to more conveniently access, correct, and delete relevant personal information, we have provided corresponding operational settings for you within the product design. You may also provide feedback and consult on relevant information through the contact methods we provide. We will contact you promptly after verifying the issues you provide feedback on. Please understand that during the verification process, we may need you to provide personal information such as the child’s account, the child’s date of birth, and contact information, so as to continue responding to your request after identity authentication and issue verification are completed.

Accessing Children’s Personal Information

You and the child under your guardianship can view the personal information provided or generated by the child user while using our products or services, including but not limited to username, password, avatar, nickname, gender, and actively published content.

Correcting Children’s Personal Information

When you and the child under your guardianship find errors in the children’s personal information we have collected, used, and processed, you can contact us to make corrections. We will take timely measures to make corrections after completing identity authentication and issue verification.

Deleting Children’s Personal Information

If the following circumstances exist, you and the child under your guardianship may request us to delete the collected, used, and processed children’s personal information. We will take timely measures to delete it after completing identity authentication and issue verification.

If we have collected, stored, used, transferred, or disclosed children’s personal information in violation of laws, administrative regulations, or the agreement between both parties;
If we have collected, stored, used, transferred, or disclosed children’s personal information beyond the scope of the purpose or the necessary period;
If you withdraw your consent;
If you or the child under your guardianship terminate the use of the products or services through account cancellation or other means.

Please note, however, that if you and the child under guardianship request us to delete specific children’s personal information, it may result in the child user being unable to continue using our products and services or certain specific business functions within the 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 try to delete the relevant data as quickly as possible.

When Children Can Manage Their Own Accounts

After a child under guardianship reaches the age of 14, they have the right to manage their account independently. If the child user chooses to manage their Tencent account independently, you will no longer be able to access or control their account. When the child under guardianship obtains the right to manage their Tencent account independently, we will notify you and the child under guardianship.

Applicability of this Statement

This Statement only applies to our products or services specifically directed at children under 14 years of age, products or services with functional sections specifically directed at children under 14 years of age, or products or services that require users to input birthday, age information, etc., that can identify the user’s age. For products or services that cannot identify or do not actively identify the user’s age, only the Tencent Privacy Policy and the Tencent PC Manager Privacy Protection Guidelines apply.

Please understand that for matters not specified in this Statement, refer to the Tencent Privacy Policy or the Tencent PC Manager Privacy Protection Guidelines. In cases where this Statement applies, if there is any inconsistency between this Statement and the terms of the Tencent Privacy Policy and the Tencent PC Manager Privacy Protection Guidelines, this Statement shall prevail.

Contact Us

If you have any questions and feedback regarding this Statement, please contact us at https://kf.qq.com/.

You may also follow the personal information consultation guidelines we provide, fill in the relevant materials, and send your questions to dataprivacy-kids@tencent.com.

Or mail to the following address:

Address: Data Privacy Protection Department (Recipient), Tencent Building, Kejizhongyi Avenue, Hi-tech Park, Nanshan District, Shenzhen, Guangdong Province, China
Postal Code: 518057

We will review the issues involved as soon as possible and reply within fifteen days after verifying your identity.