Shanghai Finite Learning Technologies Co., Ltd. (registered address: Area A, 13th Floor, Building 3, No. 2875 Huqingping Highway, Zhaoxiang Town, Qingpu District, Shanghai; hereinafter “we” or “us”) values children's personal information and privacy. This policy specifically explains how Ciyouqi (iOS version) processes the personal information of minors under 14 (collectively, “children”).
This policy should be read together with the Ciyouqi Privacy Policy. If this policy differs from the Privacy Policy, the rule that provides greater protection for children's personal information prevails.
Language and Regional Statement
The App currently provides services only to users in Mainland China. The Simplified Chinese version is the formal version and has legal effect. The English and Japanese versions are reference translations provided only to help international users in Mainland China understand the App. If the language versions differ, the Simplified Chinese version prevails.
Children's Privacy Protection Summary
- A child is a minor under 14, and the child's personal information is protected as sensitive personal information;
- At present, the guardian reads and actively declares consent in the App;
- We mainly process children's account information, vocabulary-book and dictionary-search information, word progress, quiz answers, incorrect answers, learning sessions, statistics, settings, subscription information, and feedback information;
- A guardian may access, correct, copy, or delete children's information, withdraw consent to specific children's personal-information processing activities, or disable relevant system permissions. If Apple, Sign In with WeChat, or Sign In with QQ is used, the relevant sign-in authorization is handled by the corresponding platform under its rules. A guardian may also delete a child's account through “Me > About Ciyouqi > Delete Account”;
- A child or guardian who has a problem may contact support@finitelearning.com.
Important Information for Guardians
Children's personal information is sensitive personal information. Before a child uses the App, a guardian should:
- Read and understand this policy, the Privacy Policy, and the Terms of Service together with the child;
- Select “under 14” according to the child's actual age;
- Personally complete the express consent statement in the App as the guardian;
- Guide the child to provide only information necessary for the learning service;
- Manage the child's account, subscription purchases, notifications, and third-party sign-in authorization.
The guardian should read and complete the consent statement in the App. The system records the applicable legal-document version, language, age group, guardian statement, and consent time. If the guardian does not accept the applicable children's privacy rules or has not completed the in-App consent statement, please do not let the child register, sign in, or use any service provided by the App.
If a child provides personal information to us without guardian consent, the guardian should promptly contact us at support@finitelearning.com. After verification, we will stop the relevant processing and delete the corresponding information, except where otherwise required by law.
1. Principles for Processing Children's Personal Information
We follow the principles of priority of the child's interests, clear purpose, minimum necessity, informed consent, security, and accountability assigned to designated personnel:
- We do not deny a child's use of basic functions because the child refuses information unrelated to core learning functions;
- We process only the information necessary for clearly defined and necessary functions, and limit the scope of access and use;
- If the purpose, method, scope, or third-party recipient of processing materially changes, we obtain guardian consent again as required by law.
2. How We Obtain Guardian Consent
On first use, the App asks the user to select an age group. After the user selects “under 14,” the App displays instructions for children and a guardian statement. The guardian must personally read it and indicate consent through an active in-App action.
We retain:
- The age group;
- The version and language of this policy, the Privacy Policy, and the Terms of Service;
- The guardian's in-App consent statement;
- The consent time and record source.
This information is used to prove and manage authorization for processing children's personal information. The guardian must ensure that the statement is truthful and valid. If we have a reasonable basis to believe that the account is operated by a child without completed guardian consent, that age information is false, or guardian consent has been impersonated, we may suspend the relevant processing and take appropriate account-security and service-restriction measures in accordance with law. Where a valid contact method exists and the law requires it, we will use an actually practicable notification method, or delete the relevant information as required by law.
If a guardian withdraws consent to a specific children's personal-information processing activity, we will stop that processing. If it is necessary for the account, sign-in, cloud synchronization, or core learning service, the relevant service cannot continue to be provided. The guardian may contact us through the account-deletion process or the contact information in this policy to request handling of children's personal information.
3. What Children's Personal Information We Collect
3.1 Account Registration and Sign-In
Depending on the sign-in method selected by the guardian, we may process:
- Email address, securely stored password value, and verification status. Email verification information is processed through the verification process and cleared or replaced upon successful verification, resending, or account deletion; password-reset information is cleared after the reset is completed;
- Mobile number and verification status; SMS verification codes are processed through the verification process;
- Verification result and verified mobile number required for one-tap mobile-number sign-in. The Alibaba Cloud Number Verification SDK and relevant mobile operators may process device, network, and other technical information necessary for verification under their rules;
- When signing in with Apple, the Apple user identifier and the name or email authorized to be provided; authentication credentials are processed through the relevant authentication process;
- Sign In with WeChat OpenID, UnionID (if available), and nickname; authentication credentials are processed through the relevant authentication process;
- Sign In with QQ OpenID and nickname; authentication credentials are processed through the relevant authentication process;
- A nickname set by the child or guardian.
We do not require children to provide an avatar. Guardians should prevent children from using a child's real name, school, class, contact information, or similar content as a nickname.
3.2 Vocabulary Books, Dictionary Search, and Learning Content
When a child browses vocabulary books or units or searches the dictionary, we process the selected learning language, vocabulary-book or unit identifier, search term, and matching method to return results. Search terms are processed only to complete the query, and no separate long-term search history is created.
Guardians should guide children not to enter a real name, school, address, contact information, or other information unrelated to vocabulary searches in the search field.
3.3 Word Progress, Review, and Cloud Synchronization
To provide word learning, review, statistics, and cross-device synchronization, we process:
- Learning language, vocabulary books, learning goals, and learning settings;
- Whether a word is mastered, learning status, memory-algorithm stability, and difficulty;
- Learning and review count, forgetting count, score, review interval, previous and next review times;
- Words learned each day, learning budget, goal-completion status, and review plan.
This information is used only to provide children with personalized learning-progress management and synchronization.
3.4 Quizzes, Incorrect Answers, Learning Sessions, and Statistics
When a child uses quizzes, incorrect-answer practice, or learning statistics, we process:
- Quiz sessions, rounds, question types, difficulty, language, and word identifiers;
- Answers submitted by the child, correct answers, correctness, scores, and answer times;
- Incorrect words, forgetting count, challenge rounds, and incorrect-answer practice results;
- Learning sessions, active learning time, paused/idle time, word count, completion status, and accuracy;
- Daily progress, consecutive study days, accumulated time, memory retention, learning efficiency, difficult words, vocabulary milestones, and predictions.
Incorrect-answer records and statistics are used to arrange subsequent reviews and help children understand learning status. They are not used to evaluate a child's education, employment, credit, or other matters.
3.5 Settings, Voice, and Notifications
We retain the interface/learning language, daily new-word goal, review limit, quiz type/difficulty, definition/example language, system voice and speech speed, mastery standard, maximum interval, learning order, and other settings selected by the child or guardian.
The App uses iOS system text-to-speech to play word pronunciations and does not collect or record a child's voice; this function does not require microphone permission. Notifications are used for study reminders and, where applicable, subscription-benefit expiration reminders only after the guardian permits them, and may be disabled at any time in iOS Settings.
3.6 Recommending to a Friend and System Sharing
When a child or guardian actively taps “Recommend to a Friend,” “Share the App,” or copies related content, the App provides recommendation text, an App Store link, and a user-visible UID, or generates learning-statistics and vocabulary-milestone images. It then invokes the iOS system share sheet or writes the content to the system clipboard. The content is sent to a third party only after the user selects a specific recipient app; copied content is written only to the system clipboard. The App does not read existing clipboard content, record recipients or actual sending results, or save shared content on the server. This function is not a basic learning function and need not be used.
3.7 Subscription and Transaction Information
When a guardian purchases or restores a subscription for a child's account through the App Store, the App receives only product, transaction, and subscription-status information, together with the account-binding identifier, for transaction verification, benefit activation, and after-sales handling. Apple handles the payment account and payment process under its applicable rules.
A child must not make a purchase without the guardian's consent and operation. A guardian may use Apple's “Ask to Buy,” Family Sharing, or other parental-control features, and should check the product, price, period, and renewal rules before payment. The App does not interpret the age-group record as proof that Apple has completed payment authorization.
3.8 App Security and Offer-Abuse-Prevention Information
To confirm eligibility for limited subscription offers and prevent repeated claims, the App may, when necessary, use Apple's app-security verification mechanisms and process the corresponding security-verification information, verification results, and account-unlinked offer-claim status.
3.9 Feedback and Customer-Service Information
When a child or guardian submits in-App feedback, we process feedback content, category, App version, iOS version, interface language, account identifier, an existing verified reply email if any, and necessary submission and processing information.
Guardians should submit feedback involving children on their behalf and remove unrelated real names, schools, addresses, identification documents, photographs, and similar information.
3.10 Operation Logs and Troubleshooting
Logs generated by the server for security and troubleshooting may include source IP, request time, request result, client version, and error summary, and are processed according to the actual log category and necessary period.
A guardian may request a copy of personal information that must be provided by law by contacting support@finitelearning.com.
For complete information, see the Ciyouqi Personal Information Collection List and the Ciyouqi Third-Party SDK Directory.
4. How We Use Children's Personal Information
We use children's personal information only to:
- Create, sign in to, protect, and manage a child's account;
- Provide vocabulary-book browsing and dictionary searches actively initiated by the child;
- Save word progress, quiz answers, incorrect answers, and learning sessions, arrange reviews, generate statistics, and synchronize across devices;
- Save learning, voice, quiz, and notification settings;
- Verify App Store transactions and activate and restore subscription benefits;
- When the child or guardian actively uses the relevant function, provide recommendation text, an App Store link, a user-visible UID, or learning-statistics and vocabulary-milestone images, and invoke the system share sheet or write to the system clipboard;
- Provide feedback and customer service actively requested by a child or guardian;
- Prevent fraud, attacks, account theft, and offer abuse;
- After the guardian has accepted the applicable legal documents, process necessary operation logs, crash, and performance-diagnostic information to maintain service stability, troubleshoot, and improve necessary functions;
- Perform legal obligations and protect the life, health, and property of children or others.
Without additional guardian consent, we will not change the purposes described above.
5. Entrusted Processing, Sharing, Transfer, and Public Disclosure
To provide functions actively selected by a child or guardian, the following service providers may process necessary information:
- Apple: Sign in with Apple, App Store purchases and subscriptions, and app-security verification services;
- Shenzhen Tencent Computer Systems Co., Ltd. and its related service providers: Sign In with WeChat and Sign In with QQ;
- Alibaba Cloud Computing Co., Ltd.: SMS services, number verification required for one-tap mobile-number sign-in, cloud infrastructure, and service-notification email;
- Relevant mobile operators: necessary device and network technical information only during one-tap mobile-number authentication.
Specific recipients, information types, purposes, and retention periods are described in the Ciyouqi Personal Information Collection List; client-side SDK names, purposes, and privacy rules are described in the Ciyouqi Third-Party SDK Directory.
We conduct necessary security assessments of providers entrusted to process children's personal information, use contracts to define their processing purposes, periods, methods, scope, and security responsibilities, and supervise their processing. Independent processors such as Apple process information required for platform services under their own rules. WeChat and QQ jointly help implement login functions actively selected by the user, and each party is responsible within its own processing scope. Alibaba Cloud Computing Co., Ltd. and its corresponding service providers process necessary information under the entrusted relationship. We do not make commitments on behalf of third parties regarding rights requests within their platforms.
If the App adds a third-party recipient, changes the scope of entrusted processing, or changes the App's processing purpose, we will update the relevant description as required by law and obtain consent where necessary. For information independently processed by a third party under its own rules, the relevant third party is responsible for its own notice and rights handling.
In principle, we do not transfer or publicly disclose children's personal information. If the personal information processor changes, we will notify the guardian of the recipient's information. Public disclosure requires separate consent or another lawful basis.
6. Storage Location and Retention Period
Production databases for children's accounts and learning data are stored in Mainland China. Local device data is stored on the iOS device of the child or guardian.
The retention periods are:
- Age group, guardian-consent records, account profile, learning data, subscription benefits, subscription transaction records associated with the account, App Store notification events, and legal-consent records: during the account lifetime and as needed to provide services; deleted according to the account-deletion process after account deletion;
- Authentication credentials for Apple, WeChat, QQ, and one-tap authentication: processed through the relevant authentication process and not retained as long-term children's account profile information;
- Email verification information: cleared or replaced upon successful verification, resending, or account deletion; password-reset information is cleared after the reset is completed;
- SMS verification codes: processed through the verification process and cleared after verification is completed;
- In-app feedback: usually 24 months and deleted early upon account deletion;
- Server operation logs: processed for the period required by the actual log category, security protection, troubleshooting, and necessary auditing;
- Account-unlinked device offer-claim status: retained only during the offer's validity period or the shortest period needed to prevent abuse, and not used to identify or restore a deleted account;
- Data held by third parties: processed for the shortest necessary period under the third party's policy and our agreement with it.
After the necessary period expires, we delete or anonymize the information. Where the law requires continued retention, it is retained only within the statutory scope and other uses are restricted.
If legal or policy requirements, commercial arrangements, or technical conditions require us to stop all or major services, we will stop collecting children's personal information and handle information already held in accordance with applicable law. Notice of the discontinuation will be published through an in-App announcement or another actually available prominent method. After statutory retention periods expire, we will delete or anonymize the relevant information; where the law requires timely deletion, we follow that requirement.
7. Security of Children's Personal Information
We use encrypted transmission, storage encryption or de-identification, access controls, least privilege, authentication, log auditing, security updates, and other measures appropriate to the risks to protect children's personal information and limit access by unrelated personnel. Passwords are not stored in plaintext, and necessary sign-in credentials are stored in secure local storage on the device. Service backups or controlled copies of personal information provided as required by law should also be protected by appropriate access controls and encryption.
We maintain a personal-information protection contact channel for children's personal-information matters and implement necessary access and confidentiality management for personnel who may access children's personal information.
If children's personal information is or may be leaked, altered, damaged, or lost, we immediately activate emergency handling and take remedial measures. For incidents that cause or may cause serious consequences, we report to the relevant authorities responsible for personal-information protection and notify affected children and their guardians as required by law. Where individual notification is difficult, we publish warnings through reasonable and effective means as required by law. Where laws and regulations provide otherwise, those provisions apply.
8. Rights of Guardians and Children
A guardian may legally access, copy, correct, supplement, or delete children's personal information; withdraw consent to specific children's personal-information processing activities; delete the account; restrict or refuse processing; and request an explanation of the processing rules.
8.1 Access and Correction
The guardian can view the child's account, learning data, and subscription status in the App and change the nickname. For information that cannot be changed independently, contact support@finitelearning.com.
8.2 Withdraw Specific Processing Authorization and Disable Relevant Permissions
“Withdrawal of guardian consent” in this section means only withdrawal of the guardian's consent to a specific children's personal-information processing activity. It does not mean withdrawal of the guardian's reading, acknowledgment, or acceptance of this policy or the Terms of Service. If the guardian no longer accepts this policy or the Terms of Service, the child should stop registering, signing in, and using the App, and the account-deletion process should be followed.
A guardian may disable notification permission in iOS Settings. If Apple, Sign In with WeChat, or Sign In with QQ is used, the relevant sign-in authorization should be managed through the method provided by the corresponding platform. Management and revocation of authorization held by those platforms is handled by those platforms under their own rules. To withdraw consent to a specific children's personal-information processing activity, contact us using the information in this policy. Withdrawal does not affect the validity of prior processing. After a guardian requests that processing necessary for the account, cloud synchronization, or core learning stop, the child may no longer be able to use the corresponding service.
8.3 Delete Information and Delete the Account
In the App, go to “Me > About Ciyouqi > Delete Account” and confirm. After necessary identity confirmation and deletion processing are completed, the App starts the account-deletion process. Account and database-associated data are handled through that process; some files or backups may continue to be cleared by background tasks. Children's account, learning records, feedback, sign-in credentials, and subscription-benefit mappings are generally not recoverable. Subscription transaction records, App Store notification events, and legal-consent records associated with the account are handled through the deletion process. Account-unlinked device offer-claim status is handled as described in this policy.
Deleting a Ciyouqi account does not automatically cancel the auto-renewing subscription managed by Apple. A guardian must separately go to iPhone “Settings > their name > Subscriptions” to cancel it.
8.4 Contact Us
If you suspect that a child provided information without consent or need to exercise the rights above, email support@finitelearning.com and include “Children's Personal Information” in the subject. To protect children, we may request information necessary to verify account ownership and the guardian relationship, but we will not use this to collect information unrelated to the request. We generally respond within 15 business days.
9. Policy Updates
We update this policy according to functions, SDKs, laws, or children's-protection requirements. When the processing purpose, method, information type, retention period, or recipient materially changes, we will provide prominent notice and obtain guardian consent again as required by law. Without renewed consent, we will not process children's personal information previously collected under the changed rules.
10. Contact Us
Operator: Shanghai Finite Learning Technologies Co., Ltd. Children's personal information protection and customer-service email: support@finitelearning.com