ENGLISH TRANSLATION IS FOR REFERENCE PURPOSE ONLY. In the event of any conflict between this translation and the Chinese version, the Chinese version shall prevail.

Promulgation date: September 19, 2024

Effective date: October 21, 2024

INTRODUCTION

Tenpay Payment Technology Co., Ltd. (hereinafter referred as “We”), is committed to protecting the personal information of children that use our products and services. This “Tenpay Children Privacy Protection Statement” (hereinafter referred to as “Statement”) explains to the guardians (hereinafter referred to as “you”) and the children how we handle children’s personal information, and how we respond to the rights of you and the children in personal information processing activities. Unless otherwise stated, the terms and acronyms used in this Statement have the same meanings ascribed to them in the “Tenpay Service Agreement” and “Tenpay Privacy Policy”.

SPECIAL INSTRUCTIONS FOR GUARDIANS

You should carefully read and agree to this Statement if you are a guardian. We hope that you will work with us to protect the personal information of the children under guardianship, educate and guide the children to enhance their awareness and ability to protect personal information, and to guide, remind and require them not to provide any personal information to any network products and service provider without your consent.

SPECIAL INSTRUCTIONS FOR CHILDREN

If you are a minor under the age of 14, you need to read this Statement carefully together with your guardian and use our products and services or provide us with information after obtaining prior consent from your guardian.

After carefully reading and fully understanding the “Tenpay Privacy Policy” and this Statement, please choose whether to agree with the relevant privacy policies thereunder and whether to agree with the use of our products or services by you and the children under guardianship. If you do not agree with the content of the relevant privacy policies thereunder or this Statement, or you fail to provide the information necessary to our services, it may result in our products or services not operating properly or not achieving our intended service effects. You and the children under your guardianship hence may not be able to properly use our products and services or the related specific business functions.

By clicking “Agree”, you indicate that you agree with us to process the information of you and the children under guardianship in accordance with the “Tenpay Privacy Policy” and this Statement.

Please understand that this Statement only applies to the related products or services where the users’ age (under the age of 14) can be identified by us. For products or services that cannot or do not actively identify users’ age, the “Tenpay Privacy Policy” or related privacy policy of the specific products shall apply. Our products and services may include products or services provided by third parties. You may also log in and use third-party products and services through our products. Any third party that may process children's related information will need to obtain your consent separately. We recommend you to remind the children to confirm with you before granting third parties’ access to any of their personal information.

In this Statement, any provisions that may have a significant impact on the rights of you and the children are in bold font. Please pay special attention to these provisions.

If you have any doubt or other related matters regarding this Statement, you can contact us via a special feedback channel. For details, please refer to “Contact Us” section of this Statement. We will respond to you as soon as possible.

1. HOW WE COLLECT CHILDREN'S PERSONAL INFORMATION

We will strictly comply with the legal and regulatory requirements and agreements with users and abide by the user’s choice of any specific products or services to collect the following personal information of you and the children under guardianship.

We will identify whether the user is a minor under the age of 14 through the ID number provided by the user. If the user is identified as a minor under the age of 14, we will obtain your consent before allowing the minor to continue to use relevant products or services or collecting his/her personal information (details will be subject to the page displayed at that time) in accordance with the legal and regulatory requirements.

When a user is identified as a minor under the age of 14, we may collect the guardian’s name, relationship with the user, ID number, contact information (such as mobile phone number, email address, Weixin account, QQ account number) and other personal information to contact you to verify the guardianship between you and the child under guardianship and obtain your consent for processing the  information of the child under guardianship. We may also associate your account with the child’s account in order to protect the personal information rights of you and the child under your guardianship. For any product or service that involves uploading profile pictures and other similar functions, we strongly advise that you guide the child not to upload any real personal portrait photo or other information when using our products and services.

During any child’s usage of our products or services, we will continue to collect relevant information. For details, please refer to the section of “How We Collect Your Personal Information” under the “Tenpay Privacy Policy” to learn more about the other personal information of children that we may collect.

If our handling of the personal information of you or the children under guardianship is beyond your agreed scope, we will notify you and obtain your consent again.

Please understand that you and the children under guardianship can choose whether to fill in or provide us with specific information. However, if the guardian and the children do not fill in or provide the specific information, it may result in certain functions not being able to be used properly.

2. HOW WE STORE AND PROTECT CHILDREN’S PERSONAL INFORMATION

We will use encryption and other technical measures to store children’s personal information in order to ensure information security. We will keep children's personal information within the time limit stipulated by the laws and regulations, or regulatory requirements. For details, please refer to the section of “How We Store and Protect Your Personal Information” under the “Tenpay Privacy Policy” to learn more about how we store and protect children's personal information.

3. HOW WE USE CHILDREN'S PERSONAL INFORMATION

We strictly comply with the legal and regulatory requirements and the agreement with you, and will use the collected children’s information for the following purposes:

3.1 Verification of the identity of the child and the guardian

3.2 Provision of necessary products, services or specific business functions

3.3 Identity verification, customer service, security protection, fraud monitoring, transaction monitoring, prevention or prohibition of illegal activities, archiving and backup purposes, in order to ensure the security of our products and services to children.

If we need to use the personal information of you or the children under your guardianship beyond the above-mentioned purposes, we will inform you in accordance with the requirements of the legal and regulatory regulations and obtain your consent again.

4. HOW WE SHARE, TRANSFER, AND DISCLOSE CHILDREN'S PERSONAL INFORMATION

We strictly restrict the sharing, transfer, and disclosure of children's personal information in accordance with the legal and regulatory requirements.

4.1 Generally, we do not share children's personal information with any third parties. We may only share children’s personal information with third parties with the prior consent of their guardians.

4.2 Sharing with the guardians

Certain children's personal information (such as the children's username, account number, password, and transaction details in some of our products and services) will be shared with the guardian, who can access and manage the relevant personal information.

4.3 With the development of our business, in the case of merger, division, dissolution, acquisition, asset transfer, declared bankruptcy or other transaction or matter that leads to the provision of the personal information about you and the children to any third party, we will inform you of the relevant circumstance and the recipient’s name and contact information through push notifications, announcements, etc.. We will continue, or cause the recipient, to protect your and the children’s personal information in accordance with the laws and regulations and standards not lower than those required by this Statement.

4.4 In order to improve the quality and efficiency of information processing, we may, within the scope permitted by the laws and regulations, entrust any competent cooperative institutions to process children’s information. The aforementioned competent cooperative institutions include but not limited to third-party service providers, contractors, agents and application developers. For example, communication service providers who send emails or push notifications on our behalf and map service providers who provide us with location services (they may not be located in your jurisdiction).

We undertake that we will comply with the relevant requirements under the laws and regulations in relation to the entrusted processing. We will fully review and evaluate the capability of such cooperative institutions in terms of personal information protection. We will, through written agreement, audit and other means, require the cooperative institutions to strictly comply with the confidentiality obligations and adopt technical measures to desensitize the entrusted information and prohibit them from using these information for any purposes without your authorization. When the entrusted relationship is terminated, we will require the cooperative institutions not to retain any relevant information.

4.5 We may use the collected children's information for big data analysis after anonymization, such as forming heat maps and insight reports that do not contain any personal information.

We may publicize and share with our partners any statistically processed information that is without identification content for the purpose of understanding how the users use our services or letting the public understand the overall usage trends of our services.

4.6 In general, we will prohibit the public disclosure of children's personal information, unless we have obtained your separate consent or otherwise provided by laws and regulations.

5. HOW YOU MANAGE CHILDREN'S PERSONAL INFORMATION

During the use of our products and services by the children, in order to facilitate you and children to review, copy, correct, supplement, delete, etc.,  children’s information, you can find the details in the section of “Your Rights with respect to Your Personal Information” under the “Tenpay Privacy Policy” to learn more about how to manage children's personal information.

You can also use the contact information provided by us to submit requests and applications for the exercise of rights or to provide feedback or consult on relevant information. We will contact you in time after verifying the feedback. Please understand that, during the verification process, we may need you to provide personal information such as the child's account number, date of birth, contact information so as to continue to respond to your requirements after completing the preconditions such as verifying your guardianship of the child.

Children under guardianship will have the right to manage their own accounts after reaching the age of 14. If a child elects to manage his/her Tenpay account by himself/herself, you will no longer be able to access to or control his/her account.

6. THE STATEMENT APPLICATION

This Statement only applies to products and services or some functional sections of products and services for children under the age of 14, or products or services that require users to enter birthdays, age information, and other products or services that can identify the user's age. For users of other ages, the “Tenpay Privacy Policy” shall apply. Please note that the “Tenpay Privacy Policy” applies to any of our products or services not specified in this Statement.

In cases where this Statement applies, if there is any inconsistency between this Statement and the provisions of the “Tenpay Privacy Policy” and the privacy protection guidelines of specific products (if any), this Statement shall prevail.

7. CONTACT US

If you have any questions or feedback about this Statement, please contact us through customer service. You can also follow the personal information consultation guidelines provided by us, fill in the relevant information and send your questions to Tenpay_privacy_kids@tencent.com or mail to the following address:

Address: Financial Legal and Compliance Department, Tencent Binhai Building, No.33 Haitian Second Road, Nanshan District, Shenzhen, Guangdong, the PRC

Post code: 518064

We will review your questions as soon as possible and respond within fifteen days after verifying your identity. If you are the guardian of the child user, please remark “Children's Personal Information Consultation” in the subject of the email or letter and we will handle as soon as possible.

Tenpay Payment Technology Co., Ltd.