Minors' Personal Information Protection Rules

👶1. Who These Rules Apply To

• 1.1 Children: minors under 14 years of age. All provisions of these Rules apply to the processing of their personal information.
• 1.2 Other minors: those aged 14 or over but under 18. We protect their personal information to the same standard by applying these Rules by analogy.
• 1.3 Guardian: a parent or other person legally responsible for the minor's guardianship.
• 1.4 Product positioning: Vita Keeper is designed for adults and is not offered to children as a standalone service. A child's health data can only be entered by their guardian, as a family member under "Member Management".

✅2. Guardian Consent

• 2.1 Separate consent: if you are a child, please read these Rules together with your guardian, and have your guardian decide on your behalf whether to consent. Do not use this app without your guardian's consent.
• 2.2 Consent by entry: if you are a guardian, creating a member profile for a child and entering their health data under "Profile → Member Management → Add Member" constitutes your acknowledgement of these Rules and your consent to our processing of that child's personal information accordingly.
• 2.3 Consequences of refusal: you may refuse. If you do, you can still use the app normally to record health data for yourself or other adult members; you simply cannot create a member profile for that child.
• 2.4 Withdrawal: a guardian may withdraw consent at any time — see Section 6.

📋3. Scope, Purpose and Means of Collection

We apply the principle of minimum necessity and collect only the children's personal information required to deliver the health-record function:

• 3.1 Member profile
  • What we collect: nickname or name, gender, date of birth, avatar (optional).
  • Why: to distinguish family members' health data and to apply the age-appropriate blood-pressure / blood-glucose reference ranges.
  • How: entered manually by the guardian on the member management page. We obtain it through no other channel.
• 3.2 Health data
  • What we collect: blood pressure, blood glucose, blood lipids, height/weight and BMI records, together with their timestamps and notes.
  • Why: to generate health trend charts and reminders.
  • How: entered manually by the guardian, or read via OCR from a photo of a blood-pressure monitor or glucose meter display.
• 3.3 What we explicitly do not collect: we do not collect a child's ID number, home address, school information, location, contacts, call logs or biometric data. This app has no account system at all — we create no accounts and collect no phone numbers, we do not build user profiles or perform targeted push based on children's personal information, and we do not show personalised advertising to children.
• 3.4 About avatars: avatars are stored only on your device. They are never used for facial recognition and never used to train any algorithm.

🛡️4. Storage, Security and Internal Controls

• 4.1 Location and retention: children's personal information is stored only on your device and is never uploaded to our servers; we hold no copy of it. It is deleted once the member is removed or the app is uninstalled.
• 4.2 Designated officer: we have designated a person responsible for children's personal information protection, reachable at 1558406139@qq.com.
• 4.3 Least privilege and audit trail: staff access to children's personal information requires approval from the designated officer, is logged, and is subject to technical controls preventing unauthorised copying or download.
• 4.4 Encryption: data is encrypted in transit and at rest, and we run periodic security audits and vulnerability scans.
• 4.5 Breach response: if children's personal information is or may be leaked, damaged or lost, we will immediately activate our incident response plan, take remedial action, notify guardians promptly by email or in-app notice, and report to the competent authorities as required.

🤝5. Entrusted Processing, Sharing, Transfer and Disclosure

• 5.1 Principle: we do not sell, share, transfer or publicly disclose children's personal information to any third party, except as required by law or with the guardian's separate consent.
• 5.2 Entrusted processing: children's personal information is never uploaded to a server, so no third-party processing arrangement exists.
• 5.3 Third-party SDKs: the analytics and push SDKs listed in the Vita Keeper Privacy Policy have no access to any child's health data or member profile.
• 5.4 Transfer: if a merger, division, dissolution or bankruptcy requires transferring children's personal information, we will notify guardians in advance. The recipient will remain bound by these Rules; if it changes the original purpose or means of processing, guardian consent will be obtained afresh.

⚖️6. Guardians' Rights and How to Exercise Them

Guardians (and minors aged 14 or over themselves) may exercise the following rights at any time, free of charge and without submitting ID documents, selfies holding ID, or any other extra material:

• 6.1 Access and copy: view the full profile under "Profile → Member Management → swipe the member row left → Edit"; export a copy of all health data under "Profile → Other → Export Data".
• 6.2 Correction: edit name, gender, date of birth and avatar under "Profile → Member Management → swipe the member row left → Edit"; tap any health record to open its detail page and amend the values.
• 6.3 Deletion
  • A single health record: tap the record → "Delete" in the top-right corner. Takes effect immediately.
  • All of a child's information: "Profile → Member Management → swipe the member row left → Delete". The profile and every health record under it are deleted together. Takes effect immediately.
  • Everything on the device: uninstall the app. Nothing is uploaded to our servers, so we hold no copy afterwards.
  • We will also delete the data on our own initiative, without any action from you, where: we collected or used the child's personal information in breach of the law or of our agreement; you withdraw consent; or the service is terminated.
• 6.4 Withdrawing consent: deleting the child's member profile constitutes withdrawal of consent to processing their personal information. You may also email 1558406139@qq.com to declare withdrawal. On withdrawal we stop processing and delete the child's personal information already collected.
• 6.5 About accounts: this app has no account system — no sign-up, no phone number collected — so there is nothing to close. Uninstalling the app deletes the information of every member on the device, children included.
• 6.6 Response time: requests you can carry out in the app take effect immediately. For requests requiring manual handling, we undertake to complete verification, action and reply within 15 working days of receipt.

💬7. Complaints, Reports and Contact

• 7.1 Contact us: children's personal information protection officer — 1558406139@qq.com; you may also submit a request under "Profile → Other → Feedback". We will reply within 15 working days.
• 7.2 External reporting: if you discover anyone unlawfully collecting, using, sharing, transferring or disclosing children's personal information through this app, or you are dissatisfied with our reply, you may report the matter to the competent authorities or bring proceedings before a court of competent jurisdiction.
• 7.3 Operator: the developer and operator is Hengshui Qingzhi Technology Co., Ltd.

🔄8. Updates to These Rules

• We will announce any update prominently within the app. Where an update expands the scope of children's personal information collected, or changes the purpose or means of processing, we will obtain guardian consent afresh.