Children’s Privacy Policy

Update Date: June 5, 2025

Effective Date: June 5, 2025

Thank you for your trust in Xi'an Fuhuan Network Technology Co., Ltd. (hereinafter referred to as "AI TripTalk " or "we"). We fully understand the importance of processing the personal information of children (minors under the age of 14) in accordance with the principles of legality, legitimacy, necessity, and good faith. This platform complies with the laws of the People's Republic of China to protect personal privacy.

Building upon our **Privacy Statement**, we outline the rules and related matters regarding the collection and use of children's personal information in this Children's Personal Information Protection Policy (hereinafter referred to as "this Policy"). In case of any inconsistency between this Policy and the main body of AI TripTalk 's **Privacy Statement**, this Policy shall take precedence. For matters not covered herein, please refer to our **Privacy Statement**. Specifically, this Policy includes:

Introduction

1. Definitions

2. How We Collect and Use Children's Personal Information

3. How We Entrust Processing, Share, Transfer, and Publicly Disclose Children's Personal Information

4. How We Store Children's Personal Information

5. How We Protect Children's Personal Information

6. How to Manage Children's Personal Information

7. How This Policy Is Updated

8. How to Contact Us

Special Note for Guardians:

Your understanding and cooperation are essential for us to protect your child's personal information and privacy. To safeguard your child's legitimate rights and interests, we kindly ask for your assistance in ensuring that your child uses our products and services and provides personal information only under your consent and guidance. We will take special measures in accordance with this Policy to protect the personal information of your child that we obtain. If you do not agree with the content of this Policy, please instruct your child to immediately stop accessing and using our products and services.

Special Note for Children:

If you are a child, please be sure to read this Policy together with your guardian and seek their consent and guidance before using our products and services or submitting personal information. If you are under the age of 14, please obtain explicit consent from your guardian before using our products and services or providing personal information.

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1. Definitions

The following terms in this Policy shall have the meanings specified below:

"Personal Information": Any information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding anonymized information.

"Sensitive Personal Information": Personal information that, if leaked or unlawfully used, may easily infringe upon the dignity of a natural person or endanger their personal or property safety, including biometric data, religious beliefs, specific identity details, medical health information, financial accounts, location tracking, and the personal information of children.

"Child": A minor under the age of 14.

"Processing": Includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc., of personal information.

"Anonymization": The process by which personal information is rendered incapable of identifying a specific natural person and cannot be restored.

For any undefined terms in this Policy, unless otherwise specified, their meanings shall align with the relevant laws and regulations of the People's Republic of China on personal information protection.

2. How We Collect and Use Children's Personal Information

We strictly adhere to the legal obligations and responsibilities for protecting children's personal information, following the principles of legitimacy, necessity, informed consent, purpose limitation, security assurance, and lawful utilization. We collect and use children's personal information only after obtaining the guardian's consent. By voluntarily providing your child's personal information while using our products or services, you indicate your consent to our collection and use of such information in accordance with this Policy.

Additionally, we may automatically collect personal information from you or your child through technologies such as cookies. For details, please refer to the "How We Use Cookies and Related Technologies" section in AI TripTalk 's **Privacy Statement**. If we need to collect and use children's personal information beyond the scope described above, we will seek the guardian's consent again.

Please note that when you provide information such as your child's birthday, enabling us to identify that the collected and processed personal information pertains to a child, we will handle such information in accordance with this Policy. In other cases where we cannot identify or determine whether the collected and processed personal information belongs to a child, we will handle it in accordance with AI TripTalk 's **Privacy Statement**.

Under relevant laws and regulations, the following scenarios do not require the guardian's prior consent for the collection and use of children's personal information:

Necessary to fulfill our legal obligations;

Necessary for the performance of a contract to which the child is a party;

Necessary to respond to public health emergencies or to protect the life, health, or property safety of the child in emergencies;

Processing of children's personal information that the child or guardian has voluntarily made public, within a reasonable scope;

Processing of children's personal information collected from legally disclosed sources (e.g., lawful news reports, government information disclosure channels) within a reasonable scope;

Other circumstances stipulated by laws and administrative regulations.

3. How We Entrust Processing, Share, Transfer, and Publicly Disclose Children's Personal Information

We are committed to maintaining strict confidentiality of children's personal information and will only disclose it in compliance with this Policy and with your explicit authorization.

In addition to the provisions outlined in the "How We Entrust Processing, Share, Transfer, and Publicly Disclose Your Personal Information" section of AI TripTalk 's **Privacy Statement**, we will take the following measures to ensure the security of children's personal information during entrusted processing, sharing, transfer, and public disclosure:

When sharing children's personal information with entrusted partners to achieve the functions described in the **Privacy Statement**, we will additionally require such partners not to subcontract.

Before sharing children's personal information with third parties to achieve the functions described in the **Privacy Statement**, we will assess the legality, legitimacy, and necessity of the third party's collection of such information.

If children's personal information needs to be transferred due to mergers, divisions, dissolution, bankruptcy, etc., we will conduct a security assessment either independently or through a third-party agency.

We will not publicly disclose children's personal information unless required by law or agreed upon with the guardian.

4. How We Store Children's Personal Information

In principle, the personal information we collect and generate within the territory of the People's Republic of China ("China") is stored domestically. However, as we may use resources and servers worldwide to provide insurance-related services, if such services involve cross-border transfers of children's personal information, we will:

Obtain separate consent from the guardian;

Require overseas recipients to take prudent and necessary measures to ensure that the transferred personal information receives protection equivalent to that under the **Personal Information Protection Law**;

Strictly comply with laws and regulations on cross-border data transfers and meet their stipulated requirements and conditions.

If we terminate our services or operations, we will promptly cease the collection of children's personal information, notify guardians in advance as required by law, and delete or anonymize such information after termination. If deletion is technically unfeasible, we will stop all processing activities except for storage and necessary security measures.

5. How We Protect Children's Personal Information

We place great importance on children's privacy and security and take all reasonably feasible measures to protect their personal information. For example:

Strictly controlling access to children's personal information;

Applying the principle of least privilege to staff who may handle such information;

Implementing technical measures to record and regulate staff actions regarding children's personal information to prevent unlawful copying or downloading;

Conducting periodic security audits on data and technology;

Employing encryption and other technical methods to securely store children's personal information.

6. How to Manage Children's Personal Information

(1) Access and Account Deletion

To facilitate access to and management of your child's personal information during the use of our products and services, as well as to exercise the right to delete an account, you or your child may follow the instructions in the "How to Manage Your Personal Information" section of AI TripTalk 's **Privacy Statement**.

(2) Deletion Requests

Under the following circumstances, you or your child may contact us through the channels listed in the "How to Contact Us" section of the Privacy Statement to request deletion of the relevant children's personal information:

The purpose of processing has been achieved, cannot be achieved, or is no longer necessary;

We cease providing the product or service, or the retention period has expired;

You withdraw consent;

We violate laws, regulations, or agreements in processing personal information;

Other circumstances stipulated by laws and regulations.

7. Updates to This Policy

We may update this Policy from time to time based on changes to our products and services or legal requirements. Such modifications will form part of this Policy, and the latest version will be displayed on a dedicated page. For significant changes, we will provide more prominent notice (e.g., via SMS, special prompts on browsing pages, pop-up notifications, etc.), as detailed in the "How This Privacy Statement Is Updated" section of AI TripTalk 's **Privacy Statement**.

8. How to Contact Us

If you have any questions, comments, suggestions, or requests regarding this Policy or our personal information processing activities, you may contact us via:

Email: developer2@happynet.tech

Generally, we will respond within 15 working days after verifying the identity of the guardian and/or child.