Updated: July 20, 2022
Effective: July 20, 2022
Tuya Smart Inc. and its affiliates (collectively, "we", "us", "our", or "Tuya") are committed to protecting the privacy of children (i.e., minors under 13 years of age or such other age provided by applicable law in your country/region of residence) who use our products and services. This Children's Privacy Statement (including subsequent updates, collectively, this "Statement") and the Tuya Smart Privacy Policy (Privacy Policy) are intended to explain to children's parents or other guardians ("guardians" or "you") how we collect and use children's personal information in connection with our products and services, the rules applicable to processing such personal information, and the ways in which guardians may access, correct, delete, and protect such personal information. Special Instructions for a Guardian:
We protect the personal information and privacy of children in accordance with this Statement. You are expected to help us protect the personal information and privacy of children under your custody, to require them to read and accept this Statement together with you, and to ensure that they use our products and services with your consent and guidance. Please note that if you choose to agree to this Statement, or your children begin, or continue, to use our products or services, or submit their personal information, you acknowledge that you agree to our collection, use, storage, sharing, transfer, and disclosure of your children's personal information in accordance with this Statement.
Special Instructions for Children:
We recommend that any child use our products or services with the prior consent of his/her guardian. If you are a child, please be sure to carefully read this Statement with your guardian, and use our products or services or provide information to us with your guardian's consent.
We hereby remind you that you shall carefully read and fully understand this Statement and the Tuya Smart Privacy Policy (especially the terms in bold) before choosing whether to agree to the terms and whether to agree to your children's use of our products or services.If you do not agree to any of the terms of the Tuya Smart Privacy Policy and/or the content of this Statement, or to provide relevant necessary information in the use of a specific feature or scenario of our products and services, please understandthat you and your child may not be able to normally use our products or services or the specific feature or scenario.If there is any inconsistency between this Statement and the Tuya Smart Privacy Policy in terms of the protection of children's privacy, this Stabtement shall apply. Matters not covered herein shall be subject to the Tuya Smart Privacy Policy. This Statement applies to (1) our products or services that require a user to enter birth date, age, or any other information that can identify the user’s age, and (2) specific smart devices and their features and scenarios designed and developed for children that are controlled by our software (including mobile applications and applets/mini-programs). The products and services that we provide may include products or services provided by third parties, and you may log in and use such third-party products and services through our software or products (e.g., App). Such third parties may collect, use, or process information related to children.We recommend that you ask your children to seek your consent before authorizing a third party to collect or process any of their personal information.
If you have any questions about any term of this Statement, or you and your children have any requests related to personal information during the use of our products or services, please contact us through the special channels available to you, which are shown in the "Contact Us" section below. We will handle and respond to your questions or requests as soon as possible upon receipt thereof.
I. What Information Do We Collect?
We will, in strict accordance with the obligations and responsibilities for the protection of children's personal information prescribed by applicable laws and regulations, as well as the provisions of relevant privacy policies and this Statement, and based on the specific needs of relevant products and services, collect and use children's personal information after obtaining the consent of their guardians.
When providing certain child-oriented products or services to you and your children, we may require the user to fill in their birth date information for the purpose of providing such products or services to you so as to identify whether the user is a child and, in accordance with applicable laws and regulations, allow the child to use relevant products or services after obtaining the consent of his/her guardian.
When you and your children use a specific smart device controlled by our software, we may collect and use your children's personal information necessary for certain features or scenarios, including information on years/months of age, movement, and geographic location. Specific types and scope of information involved will depend on the features and intelligent scenarios of the smart device(s) used.
When a child uses our products or services, we may collect other relevant information from the child. Please refer to the "What Personal Information Do We Collect" section of the Tuya Smart Privacy Policy to learn more about other personal information we may collect.
If we need to collect personal information about you or your children beyond the above-mentioned scope of collection, we will notify you again and obtain your consent.
Please understand that you may choose whether to fill in or provide us with certain information of your children, but if you do not fill in or provide certain information, it may cause our products or services to fail to function properly or to achieve the desired service effect, and you and your children may not be able to normally use our products or services or related specific business functions.
II. How Do We Use the Information?
We will, in strict accordance with laws and regulations and the agreements concluded with users, use the information collected from you and your children for the following purposes:
a) To provide necessary products or services or the specific functions thereof; and
b) To optimize products or services, provide security assurance, or conduct service survey.
If we need to use personal information about you or your children beyond the above-mentioned purposes, we will notify you again and obtain your consent.
III. Sharing, Transfer, and Disclosure of Children's Personal Information
We strictly restrict the sharing, transfer, and disclosure of the personal information of children in accordance with laws and regulations. In general, we do not share children's personal information with any third party. We may share with third parties the personal information of a child only after obtaining the prior consent of their guardian.
a) Sharing with Guardians
We will share certain children's personal information (such as the children's user names, account numbers, and passwords, and transaction information for some of our products and services) with their guardians so that the guardians may access and manage relevant personal information.
b) Sharing with Third Parties
For the purpose of external processing only, we may share a child's personal information with third-party partners, including service providers, contractors, agents, and application developers (e.g., communications service providers that send emails or push notifications on our behalf, and map service providers that provide us with location services) (they may not be located in your jurisdiction) and have them process such information for us in accordance with our statements and privacy policies and relevant confidentiality and security policies.
If we entrust a third party with processing of children's personal information, we will conduct security assessment on the third party and the entrustment, and sign an entrustment agreement to require the third party to process such personal information within the scope of our authorization. The children's personal information is used by such third party mainly for the following purposes:
i. To provide our services to the children;
ii. To achieve the purposes as set forth in the "How Do We Use the Information" section hereof;
iii. To fulfill our obligations under the Tuya Smart Privacy Policy and this Statement and exercise our rights thereunder; and
iv. To understand, maintain, and improve our services.
If we share your and your child's information with the above-mentioned third parties, we will conduct security assessment and adopt encryption, anonymization, de-identification, and other measures to protect the security of your and your children's information.
With the continuous development of our business, we may engage in a merger, acquisition, asset transfer, or other transaction that results in the sharing of your and your children's personal information with a third party, in which case we will inform you by push notification, announcement, or other means, and continue to protect or require the new manager to continue to protect your and your children's personal information in accordance with applicable laws and regulations and the security standards no less stringent than those required in this Statement.
We may anonymize the collected information of children for the purpose of big data analysis, for example, generating a report for the services that you use.
c) Other Disclosures
In general, we prohibit the disclosure of children’s personal information, but we may disclose children's personal information for the following purposes:
i. To comply with applicable laws and regulations, legal proceedings, or requests from public institutions and government authorities;
ii. To perform our terms of use and other agreements, policies, or standards, including investigating any potential violations;
iii. To protect the rights, privacy, security, or property of us and/or other users, including you; and
iv. To seek available detection, prevention, or remedial measures, limit potential damages payable by us, or resolve security, fraud, or technical issues.
IV. Storage of Children's Personal Information
We will take encryption and other technical measures to store children's personal information to ensure information security. We will store children's personal information only for a period necessary to fulfill the purposes for which we collect and use such information. For more information about how we store and protect children's personal information, please refer to the "Storage Location and Period of Information" and "Information Security" sections of the Tuya Smart Privacy Policy.
If our products or services cease operating, or the storage period of your and your children's personal information expires as required by this Statement or the Tuya Smart Privacy Policy, we will notify you and your children by means such as push notification, announcement, and email, and delete or anonymize your and your children's personal information within a reasonable period of time.
V. Management of Children's Personal Information
To make it easier for you and your children to access, correct, or delete relevant personal information while using our products or services, we provide you with the corresponding operation settings in the product design, and you also may provide your feedback or inquiries through the contact information we provide. We will contact you in a timely manner upon verifying your feedback. Please understand that during the verification process, we may require you to provide the children's personal information such as account number, birth date, and contact information, so that we can continue to respond to your needs after completing authentication and verifying the issues.
a) Accessing Children's Personal Information
You and your children may view the personal information provided or generated by the child user in the use of our products or services, including but not limited to user name, nickname, gender (if applicable), and voluntarily posted contents.
b) Correcting Children's Personal Information
When you and your children find errors in the children's personal information that we collect, use, and process, you may correct such personal information by choosing Me > Personal Information > Nickname/Time Zone, or by contacting us. We will take measures in a timely manner to correct the errors after completing the authentication and verification.
c) Deleting Children's Personal Information
You and your children may request us to delete the children's personal information that we collect, use, and process, and we will take measures in a timely manner to delete such personal information after completing the authentication and verification if:
i. we collect, store, use, transfer, or disclose the child's personal information in violation of applicable laws and regulations or relevant agreement with you;
ii. we collect, store, use, transfer, or disclose the children's personal information beyond the intended scope or necessary period;
iii. you withdraw your consent; or
iv. you or your children terminates the use of our products or services by cancelling the user account.
For your request, we will perform authentication and verification, and take measures in a timely manner to delete relevant personal information after completing the authentication and verification. However, please note that if you and your child require us to delete the specific personal information of the child, it may cause the child user to be unable to continue to use our products and services or certain specific business functions thereof. If you find that any personal information of your children has been collected without your prior consent, please contact us immediately, and we will endeavor to delete relevant information as soon as possible.
Contact Us
If you have any questions about our practices or this Statement, please contact us in the following ways:
Tuya Smart Inc.
Correspondence Address: 160 Greentree Drive, Suite101, in the City of Dover, County of Kent, 19904.