This Privacy Statement was last updated on August 9, 2022
Welcome to visit our products. The arpha Kids App (hereinafter referred to as "applications, products") is a service that can help parents monitor and improve their children's brushing habits, and provide brushing record services to children based on their brushing data (below referred to as "services") . The personal data used by this application is collected or processed by the application by the X3 children's toothbrush handle (hereinafter referred to as "device") connected to Bluetooth. The controller of the personal data in this Privacy Statement is Shenzhen Ganyan Technology Co., Ltd. at Rm. 1812, Jinhua Bldg., Minzhi community, Minzhi St., Longhua Dist., Shenzhen city, Guangdong Prov., China (hereinafter referred to as "arpha", "our" or "us").
The aforementioned applications, services and devices are developed and operated by arpha. To ensure that user data security and privacy protection are our top priorities, this Privacy Policy sets out the data collected when you visit and use our products and services and how they are handled.
Please read carefully and confirm that you fully understand all the rules and points of this Privacy Policy before continuing to use our products. Once you choose to use it, it is deemed that you agree to the entire content of this Privacy Policy and that we collect and use you according to it. related information. If you have any questions about this policy during the reading process, you can contact our customer service for consultation, please contact us at aaa1556517141@dingtalk.com or the feedback method in the product. If you do not agree with the relevant agreement or any of its terms, you should immediately stop using our products and services.
This Privacy Policy helps you understand the following:
1. How we collect and use your personal information;
2. How we store and protect your personal information;
3. How we share, transfer and publicly disclose your personal information;
4. How we use cookies and other tracking technologies;
5. How we collect and use personal information of minors
6. How we handle the personal information of minors;
7.Personal and minor information and account closure
8. Rating and review data;
9. Customer support data;
10. Relevant usage rights;
1. How we collect and use your personal information
Personal information refers to all kinds of information recorded electronically or in other ways that, alone or in combination with other information, can identify the identity of a specific natural person or reflect the activities of a specific natural person. In accordance with the requirements of the "Network Security Law of the People's Republic of China" and "Information Security Technology Personal Information Security Specification" (GB/T 35273-2017) and other relevant laws and regulations, and strictly follow the principles of legitimacy, legality and necessity, for your Collect and use your personal information, including but not limited to phone numbers, email addresses, preferences and interests, in the course of using the services and/or products we provide.
In order to receive our comprehensive product services, you should first register a user account through which we will record relevant data. All the information you provide comes from the data you provided yourself during registration. The account name, password, and your own contact information you plan to use, we may verify whether your identity is valid by sending text messages or emails.
With your consent, we will collect analytics data on your child's brushing habits and app usage, including toothbrush head type, toothbrush handle data (model, serial number, firmware version), duration of brushing, start time and intensity of brushing (below called "brushing data"). We use and/or aggregate brushing data for analytical purposes to improve the Apps and Services, including improving your child's general app experience, the app's gameplay and graphics, and device performance. arpha always ensures that brushing data is properly protected when processing it. Additionally, arpha associates brushing data with a random identifier and replaces any IP addresses associated with brushing data with generic IP addresses prior to storage.
If you do not agree, arpha will not process brushing data in any way. In this case, brushing data will always be saved in this app on your mobile device and arpha has no access to this data. You will have control over this data. If you delete your child's profile and/or the app, your brushing data will also be deleted from your mobile device.
The personal information you provide will continue to be authorized to be used by us during your use of the Service. When you cancel your account, we will stop using and delete the above information.
2. How we store and protect your personal information
As a general rule, we only retain your personal information for as long as is necessary to fulfill the purpose for which it was collected. We retain your personal information for as long as is strictly necessary to manage our relationship with you (for example, when you open an account, obtain services from our products). We ensure that your personal information is completely deleted or anonymised when it is no longer necessary for our statutory obligations or statutory statutes of limitations for purposes or files.
We protect the personal information you provide using industry-standard security safeguards and encrypt critical data within it from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable steps to protect your personal information. We use encryption technology to ensure the confidentiality of data; we use trusted protection mechanisms to prevent data from malicious attacks.
It is worth mentioning that in order to strengthen the protection of private data, we have desensitized it when we collect it. Even in our own database, no associated private data in plaintext will be stored.
3. How do we share, transfer and publicly disclose your personal information
We will use your personal information compliantly and appropriately in pursuit of our legitimate interests to better serve our customers as required to manage our day-to-day business activities. For the comprehensive consideration of business and all aspects, we will share this data with third-party partners, which will also comply with their privacy policies and will not be disposed of arbitrarily.
We may share your personal information externally in accordance with laws and regulations or the mandatory requirements of government authorities. Under the premise of compliance with laws and regulations, when we receive the above-mentioned request for information disclosure, we will require the issuance of corresponding legal documents, such as subpoenas or investigation letters. We strongly believe in being as transparent as possible about the information we are asked to provide, to the extent permitted by law.
In the following cases, the sharing, transfer and public disclosure of your personal information does not require your prior authorization and consent:
1、Those directly related to national security and national defense security;
2、Those directly related to criminal investigation, prosecution, trial and execution of judgments;
3、In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain my consent;
4、Your personal information disclosed to the public by yourself;
5、Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
6、Necessary to sign and perform a contract according to the personal information subject's request;
7、Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and disposing of faults in the products or services;
8、Other circumstances stipulated by laws and regulations.
4. How we use cookies and other tracking technologies
To ensure the proper functioning of our products, we store small data files called cookies on your mobile device. Cookies usually contain identifiers, product names, and some numbers and characters. With the help of cookies, we can store data such as your preferences or products, and use them to determine whether registered users have logged in, improve service and product quality, and optimize user experience.
We use various cookies for different purposes, including: strictly necessary cookies, performance cookies, marketing cookies and functional cookies. Certain cookies may be provided by external third parties to provide additional functionality to our products. We will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer or on your phone. Most web browsers have a function to block or disable cookies, and you can configure your browser. After blocking or disabling the cookie function, it may affect your use or not be able to fully use our products and services.
5. How we collect and use personal information of minors
Personal information refers to all kinds of information recorded in electronic or other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information. Personal information includes:
1. Personal data (personal name, gender, date of birth);
2. Personal location information (such as whereabouts, precise positioning information, etc.);
3. Other operation records;
In order to optimize the interactive experience by analyzing user information, we may collect and use children's operation records in arpha kids and some necessary equipment information, and use children's user information to improve the design and optimization of arpha kids. Product and/or service usage statistics to understand the overall usage trends of our products and/or services. However, when we use children's personal information, we will desensitize children's information through anonymization and de-identification processing to protect children's information security.
The personal information of the above minor provided by you will continue to be authorized to be used by us during your use of the Service. When you cancel your account, we will stop using and delete the above information.
6. How we handle the personal information of minors
When creating your child's profile, you can fill in the child's name and upload/take a profile picture. However, arpha does not process such data in any way. These data will always be saved in this app on your mobile device, arpha has no access to them. You will have control over this data. If you delete your child's profile and/or the app, this data will also be deleted from your mobile device.
For the collection of children's personal information with parental consent, we will only use or publicly disclose this information as permitted by law, expressly consented by a parent or guardian, or necessary to protect the child. If we become aware that a child has collected personal information from a child without prior verifiable parental consent, we will seek to delete the relevant data as soon as possible. If you are the guardian of a minor, please contact us in time when you have any questions about the use of our services by the minor under your guardianship or the user information provided to us. We will protect the confidentiality and security of minor user information in accordance with relevant national laws and regulations and the provisions of this policy.
We retain children's personal information for the shortest period necessary to provide children with products and services to meet the purpose, and will take reasonable and practicable measures to protect children's personal information. We have a professional technical team responsible for handling data protection related matters. At the same time, we also set up specific processes and security procedures for specific user data collection and processing to ensure that the storage and use of data meet our expectations and the requirements of laws and regulations. In addition, we regularly conduct risk assessments of security policies and data protection measures to ensure that our products are not exposed to risks such as data breaches or privacy violations.
7. Rating and review data
If you write a review or rate an app on the App Store, we will process this information, respond to your comments and questions, understand your experience with the app, familiarize yourself with the app and our brand in general, and Improve the application based on this information. We can only see your App Store username, ratings, reviews, and any other details you decide to share or make public with us. We will not associate this information with your account credentials or any other information we hold about you unless you ask us to do so. We will use your data to follow up on your case when you need customer support and guide you through our customer support process according to the "Customer Support Data" section below. We consider the activities of processing your rating and review data to be conducted in accordance with the requirements of the "People's Republic of China Cybersecurity Law" and "Information Security Technology Personal Information Security Specification" (GB/T 35273-2017) and other relevant laws and regulations.
8. Customer Support Data
If you request customer support, we may ask you to provide information about your use of our services, including your interactions with aprha and how we can contact you to provide the support you need. We operate and provide services, including providing customer support, as well as improvement, repair and customization services. We also use your information to respond to you when you contact us.
9. Relevant use rights
The app may ask for your permission to access your mobile device's storage features, sensors, or other features (such as photos, camera, Wi-Fi, geolocation, or Bluetooth). We require access when necessary to provide the services detailed below.
Time of publication, entry into force and update of this Privacy Policy
Release time of this privacy policy: January 8, 2022
Effective date of this privacy policy: January 8, 2022
Update time of this privacy policy: August 9, 2022