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. We do not create standalone accounts for children (accounts can only be registered by an adult guardian with their own mobile number), 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, or in encrypted cloud storage if you have actively enabled Cloud Backup. 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 by default. It is uploaded over an HTTPS-encrypted channel to our servers located within mainland China only when the guardian actively enables Cloud Backup. We do not transfer children's personal information outside mainland China. Retention is limited to the shortest period necessary; the data is deleted once the member is removed or the account is closed.
• 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: health data is stored on cloud servers we lease within mainland China (Alibaba Cloud) only when the guardian enables Cloud Backup. That entrusted processing is governed by a written agreement; the processor may not process the data beyond the agreed purpose and may not sub-delegate. We assessed the processor's security capabilities before entrusting the data.
• 5.3 Third-party SDKs: the analytics, push and advertising 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 → tap the member"; export a copy of all health data under "Profile → Account → Data Management → Export Data".
• 6.2 Correction: edit name, gender, date of birth and avatar under "Profile → Member Management → tap the member"; 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 → Delete Member". The profile and every health record under it are deleted together. Takes effect immediately.
  • Cloud copies: "Profile → Account → Data Management → Cloud Backup → Delete Cloud Data".
  • 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; you close your account; 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 Closing the account: "Profile → tap the account card at the top → Account → Delete Account". After SMS verification on the bound mobile number the account is closed immediately, and the information of every member under it (children included) is deleted or anonymised on our servers.
• 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.