Children’s Privacy Protection Rules

Orient Speech Therapy Center (China) Co., Ltd. and/or its affiliates (hereinafter referred to as “we”) place great importance on protecting the personal information and privacy of children (referring to minors under the age of fourteen, hereinafter the same). We understand the importance of safeguarding the personal information and privacy of children. To ensure the security of children’s personal information and privacy, we have specifically formulated this ‘Children’s Online Privacy Protection Rules’ (hereinafter referred to as ‘this policy’) to explain the relevant rules for handling children’s personal information when we collect and use it. As a parent or other guardian (hereinafter collectively referred to as ‘Guardian’) of your child, the scope of this policy applies to but is not limited to the client applications we legally own, manage, and operate under the registered name ‘Allied Health School Services’ (including but not limited to mobile apps, mini-programs, WeChat public accounts, and all other terminal clients), websites (Allied Health School Services – Join Our Village to Foster Children’s Well-being and Academic Success (ahprogram.com), and web pages, software development kits (SDKs), and application programming interfaces (APIs) used by third-party client applications and/or official websites, and any other product forms that may emerge (hereinafter collectively referred to as ‘our products and services’).

Before you and your child use our products and services, please carefully read and fully understand this policy, especially the terms marked in bold/bold underline. As your child’s Guardian, you agree that we may process your child’s relevant personal information in accordance with this Privacy Policy for the purpose of complying with legal and regulatory requirements and/or completing the necessary functions of Allied Health School Services. In certain functional scenarios, you or your child may refuse to provide us with relevant personal information, but this may result in your child being unable to use specific functions. We will provide related explanations in this policy to help you better understand.

※Special Statement for Children’s Guardians: If you are a legal guardian of a child, please carefully read this policy and confirm whether you agree with the relevant rules for processing children’s personal information and whether you agree for your child to use our products/services. You should ensure that your child uses our products/services with your consent and guidance and provides us with personal information. We will take special measures to protect your child’s personal information obtained by us in accordance with this policy. If you do not agree with the contents of this policy, please stop providing your child’s personal information to us, or ask your child to immediately stop accessing or using our products and services.

※Special Statement for Children: If you are a minor under the age of 14, please be sure to inform your Guardian to read this policy together with you and seek your Guardian’s consent and guidance before using our products and services and submitting personal information.

This Policy Will Help You Understand the Following:

1. How We Collect and Use Children’s Personal Information
2. How We Share, Delegate, Transfer, and Publicly Disclose Children’s Personal Information
3. How We Store Children’s Personal Information
4. How We Protect Children’s Personal Information
5. How to Manage Children’s Personal Information
6. Revisions to This Policy
7. How to Contact Us

1. How We Collect and Use Children’s Personal Information
2. We will strictly fulfill our legal obligations and responsibilities regarding the protection of children’s personal information, adhering to principles of legality, legitimacy, necessity, and transparency. We will collect and use children’s personal information with the consent of their guardians. When you use our products or services, you may voluntarily provide us with your child’s personal information, including the child’s voice information uploaded during training tests, basic health information submitted during customer service interactions, appointments for evaluations, the child’s nickname, age range, birth date, gender, first language, and health information and assessment reports reflected in self-assessment questionnaires. By doing so, you agree that we can collect and use your child’s personal information. If you refuse to provide such information in certain scenarios, you will not be able to use the corresponding functions, but this will not affect your or your child’s use of other products and services we offer.
3. During your and your child’s use of our products and services, we may collect and use other children’s personal information for the purpose of providing our products and services (e.g., ensuring account security). For details on the specific purposes, the scope of personal information collected, and other related content, please refer to Section 3, “What Information We Collect and Use,” of the “Online Privacy Policy.” Please note that we may not be able to identify and will not judge whether the personal information collected and processed belongs to children if it is automatically retained by computer systems. If we cannot identify whether the retained and processed information belongs to children, we will collect and process user information in accordance with the “Online Privacy Policy.”
4. Exceptions to Authorized Consent: According to relevant laws and regulations, the following situations do not require the guardian’s authorized consent to collect and use children’s personal information:
   1. When the collection and use are related to the fulfillment of our legal obligations;
   2. When it is directly related to national security or national defense security;
   3. When it is directly related to public safety, public health, or significant public interest. For example, when necessary to respond to public health emergencies or to protect the life, health, and property safety of individuals in emergencies;
   4. When it is related to criminal investigations, prosecutions, trials, and enforcement of judgments;
   5. When it is difficult to obtain the guardian’s consent to protect the major legal interests of the child or other individuals, such as life and property;
   6. When the information is publicly disclosed by the child or guardian themselves;
   7. When it is necessary for signing and performing contracts at the request of the child or guardian;
   8. When the personal information is collected from legally disclosed information, such as legitimate news reports, government information disclosure, etc.;
   9. When it is necessary to maintain the safe and stable operation of our products and services, such as detecting and handling product or service malfunctions;
   10. Other circumstances stipulated by laws, regulations, or national standards.

1. How We Share, Delegate, Transfer, and Publicly Disclose Children’s Personal Information We are committed to maintaining strict confidentiality of children’s personal information and will only share children’s personal information with third parties when it aligns with this policy and with your explicit authorization and consent. To better provide services to you and your child, we may share children’s personal information with our affiliated companies or delegate our partners to process children’s personal information on our behalf. For details, please refer to Section 5, “Information We Share, Transfer, and Publicly Disclose,” of the “Online Privacy Policy.” In addition to the content described in that section, we will also take the following measures to protect children’s personal information during sharing, delegation, transfer, and public disclosure:

1. If it is necessary to share children’s personal information with third parties for the purposes described in this policy, we will assess the legality, legitimacy, and necessity of the third party’s collection of children’s personal information.
2. We will require the third party to take protective measures for children’s personal information and strictly comply with relevant laws, regulations, and regulatory requirements. We will require the recipient of children’s personal information to adhere to strict confidentiality obligations and take effective confidentiality measures, prohibiting the use of this information for unauthorized purposes and requiring the entrusted company to fulfill the following obligations:
   1. Handle children’s personal information in accordance with laws, administrative regulations, and our requirements;
   2. Assist us in responding to requests from children’s guardians;
   3. Take reasonable measures to ensure information security and promptly notify us in case of any children’s personal information security breaches;
   4. Delete children’s personal information after the termination of the entrustment relationship;
   5. Prohibit further delegation;
   6. Fulfill other legal obligations related to the protection of children’s personal information.
3. Additionally, we will obtain your consent as required by laws and regulations or confirm that the third party has obtained your consent. Please note that, according to legal provisions, the sharing, transfer, and disclosure of anonymized personal information, ensuring that the data recipient cannot restore and re-identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. Therefore, no additional notification to or consent from the guardian is required for the retention and processing of such data.

III. How We Store Children’s Personal Information Children’s personal information collected and generated during our operations within the People’s Republic of China will be stored within China. Only in the following circumstances, and after meeting the relevant legal and regulatory requirements, may we provide your personal information to overseas entities, and we will strictly require the recipient to handle your personal information in accordance with relevant laws, regulations, and this policy:

1. When explicitly required by laws and regulations;
2. When separately obtaining your individual consent;
3. When the products and/or services you use involve cross-border activities, and you voluntarily provide personal information to overseas entities. We will only retain your personal information for the period necessary to achieve the purposes described in this policy unless there are mandatory retention requirements under the law. For the retention period of children’s personal information, please refer to Section 7, “Storage and Protection of Your Personal Information,” of the “Online Privacy Policy.” If we cease operations of the Qiyin Online products or services, we will promptly stop collecting children’s personal information and comply with relevant legal requirements to notify guardians in advance. After service or operation termination, we will delete or anonymize children’s personal information, except as otherwise required by laws, regulations, or regulatory authorities.

1. How We Protect Children’s Personal Information We attach great importance to the privacy and security of children and take all reasonable and feasible measures to protect children’s personal information:
2. We strictly control access to children’s personal information, adhering to the principle of minimal necessary authorization for staff who may access children’s personal information. We also implement technical measures to record and monitor staff handling of children’s personal information to prevent unauthorized copying or downloading of such information.
3. We have developed an emergency response plan for children’s personal information security incidents. We regularly organize internal training and emergency drills for relevant personnel to ensure they understand their responsibilities and emergency response strategies and procedures.
4. We have established data classification standards. All children’s personal information is stored on secure servers and protected in controlled facilities. We classify your data according to its importance and sensitivity, ensuring that children’s personal information is afforded the highest level of security.
5. If you would like to learn more, please refer to Section 7, “Protection of Personal Information,” of the “Online Privacy Policy” to gain a detailed understanding of the technical and management security measures we take to protect children’s personal information. Despite the reasonable and effective measures and compliance with relevant legal standards, please understand that due to technical limitations and possible malicious means, it is impossible to guarantee 100% security of information at all times. Therefore, we will do our utmost to ensure the security of the children’s personal information you provide to us, but we strongly recommend that you take proactive measures to protect the security of children’s personal information, including but not limited to using complex passwords, regularly changing passwords, and not disclosing your account password or other children’s personal information to others.

1. How to Manage Children’s Personal Information To facilitate better access and management of your child’s personal information during the use of our products and services, you and your child have the following legal rights:
2. Inquire, correct, modify, or delete children’s personal information, except in cases provided by laws and regulations;
3. Change the scope of authorization or withdraw authorization;
4. Cancel the account;
5. Obtain a copy of personal information. We have provided detailed instructions on how to exercise the above rights in the “Online Privacy Policy.” You and your child can follow the steps outlined in Section 6, “How to Manage Your Information,” of the “Online Privacy Policy” to manage your child’s personal information. For example, if you wish to correct or delete your child’s personal information, you can send an email to ahss@ostspeech.com to contact customer service.

1. Revisions to This Policy To provide you and your child with better services, our business may change from time to time, and this privacy policy will be adjusted accordingly. We will not limit the rights you and your child are entitled to under this privacy policy without your explicit consent. We will notify you and your child of relevant updates through updates on our website, mobile terminals, or other means, and we ask you to accompany and guide your child to visit us to stay informed of the latest privacy policy. In such cases, if you and your child continue to use our services, it will be deemed that you agree to accept and be bound by the revised policy. For details, please refer to Section 9, “Revisions to This Policy,” of the “Online Privacy Policy.”

VII. How to Contact Us If you or your child have any questions about this policy, or any concerns, opinions, suggestions, or complaints regarding the handling of children’s personal information, please send an email to ahss@ostspeech.com to contact us. We will review the issues involved as soon as possible and respond within 15 working days after verifying your identity as a guardian or your child’s identity.