Shenzhen Yuanqi Chuangxiang Artificial Intelligence Co., Ltd. (the "Company", "we", "us" or "our") takes the protection of children's personal information seriously in connection with the TocoTalk picture-book reading device (the "App" or "TocoTalk"). In addition to the Privacy Policy and the Terms of Service, we have created this Children's Privacy Policy (this "Policy") to explain how we collect and use children's personal information. For the purposes of this Policy, a "child" means a minor under the age of fourteen.
Before using the App or its services, children and their parents or other guardians (together, "guardians") must carefully read and fully understand this Policy, in particular the clauses highlighted in bold.
TocoTalk accounts may only be registered and operated by adults. Before you first add a child's profile (nickname, gender, birth month) or upload a sample containing a child's voice, we will, in a separate dialog, explain the purpose of processing, the types of information, the retention period and the consequences of refusing, and ask you to:
- confirm that you are the parent or other guardian of the child you are adding;
- give separate consent to the processing of the child's personal information;
- choose not to add the child's profile if you do not agree; not adding it does not affect features that do not rely on children's information, such as device setup and listening.
We record when that consent was given and which version of this Policy it relates to. You may withdraw consent at any time through the channels listed under "Contact Us"; after withdrawal we will stop the relevant processing and delete or anonymize the child's personal information already collected (unless the law requires otherwise).
Special note: The TocoTalk mobile app and mini program are intended for parents' use — to pair devices, connect Baidu Netdisk, and choose content for their children to listen to. Children do not sign in, do not authorize anything, and do not see other files in the Netdisk; they simply listen to the content a parent has chosen on the device at home. The clauses in this Policy concerning children's personal information apply to children listening to content and to the information processing necessary when a parent manages the account on their behalf.
1. How We Collect and Use Children's Personal Information
- When a child uses the App or its services, we collect only the personal information you have agreed we may collect, or that you or the child have voluntarily provided, and only to the extent needed to provide core functionality and to protect account and system security. The purposes, methods and scope of that processing are set out in the "Information Collection and Use" section of the Privacy Policy. The children's personal information we collect mainly includes:
- Basic information: the child's nickname, birth month (month-level only, e.g. 2019-06) and gender (optional). We do not require the exact date of birth.
- Learning data: reading records, listening duration and reading preferences.
- Device information: device identifier and firmware version (for device management and updates).
- Voice samples: only when you voluntarily upload one and give separate authorization, used for AI story synthesis; see the Privacy Policy for details.
- We do not collect children's personal information unrelated to providing the service, including: the child's exact date of birth, national ID number or similar sensitive identity information; precise location; contacts, SMS or similar communications; or biometric information such as facial features or fingerprints. Where the law requires us to process such information, we will obtain the guardian's explicit consent separately.
- Where law or regulation requires identity verification, we may process the necessary information (for example, name and valid identity-document details). If a user is identified as a child, we will process their personal information in accordance with applicable law and may contact a guardian to verify the guardianship relationship (for example, by phone number or email).
- To better protect children's rights, we may, where necessary, collect additional information from a guardian (for example, name, identity card, household register, birth certificate or other proof of guardianship), used solely to verify the guardianship relationship and to fulfil our protection obligations. If we need to process children's personal information beyond that scope, we will obtain the guardian's explicit consent again.
- To use the Baidu Netdisk listening feature, the Baidu Netdisk OAuth authorization must be completed by a parent, other guardian or family administrator who fully understands the scope of the authorization; a child may not complete it independently. We process only the information necessary to enable directory browsing, audio preview and home-device listening within the scope of that authorization. The specific rules are set out in the Baidu Netdisk provisions of the Privacy Policy.
- Guardians should confirm that the audio content to be played is suitable for children and ensure that they have lawful rights to use the relevant files. Baidu Netdisk is a third-party service; its account, file content and authorization status are managed by the guardian under Baidu Netdisk's own rules.
- Audio data: recognising picture-book content may require the camera and microphone. Captured images are used only for real-time recognition and are not stored; voice-interaction data is uploaded only where necessary and the original audio is deleted once processing is complete. If you voluntarily use the story feature and upload a voice sample, that sample is uploaded to object storage for voice synthesis as described in the Privacy Policy, and we process it only with your separate authorization.
2. How We May Share, Transfer or Publicly Disclose Children's Personal Information
- [Sharing] We will not provide children's personal information to any third party without the guardian's consent, except in the following situations:
- where necessary for device network setup, account management, security auditing, customer support or legal requirements, and with the guardian's authorization;
- where necessary to engage entrusted service providers (such as cloud services or SMS channels), in which case we sign strict confidentiality and data-security agreements requiring them to process information only within the authorized scope;
- where the guardian voluntarily authorizes the Baidu Netdisk listening feature, we interact with the Baidu Netdisk open platform only to the extent necessary to provide that feature; children's personal information is not automatically submitted to Baidu Netdisk because a child uses the App.
- [Transfer] If a merger, acquisition, asset transfer, division, dissolution or bankruptcy requires the transfer of children's personal information, we will inform the guardian of the recipient and require the recipient to continue protecting the information under applicable law and standards no less protective than this Policy.
- [Public Disclosure] We will publicly disclose children's personal information only on lawful grounds and after taking industry-standard security measures (for example, cooperating with administrative or judicial authorities as required by law).
3. Storage and Protection of Children's Personal Information
- [Storage location] Children's personal information collected within the People's Republic of China is stored on servers within China and is in principle not transferred across borders; if cross-border transfer is genuinely necessary, we will fulfil obligations such as assessment, notification and re-obtaining guardian consent in accordance with law.
- [Security measures] We safeguard children's personal information through access controls, encryption, least privilege, log auditing and staff security training. If a security incident such as a leak, damage or loss occurs or may occur, we will activate our emergency plan in accordance with law and promptly notify guardians and regulators.
- [Retention period] We retain information only for the shortest period necessary to achieve the purpose. When the retention period expires, or a guardian requests deletion and the statutory conditions are met, we will delete or anonymize the information, unless otherwise required by law.
4. Guardians' Rights and How to Exercise Them
- Access: guardians may view the children's personal information we collect (such as learning records and usage data) through in-app entries such as "Parent Center" or "Profile", or make an access request through the channels listed under "Contact Us".
- Correction: if children's personal information is inaccurate, guardians may correct it directly in the App or contact us for assistance.
- Deletion: guardians may ask us to delete children's personal information where: we collected, used or shared it in violation of law or our agreement with you; the guardian withdraws consent; or you or the child stop using the products and services by deleting the account or otherwise.
- Withdrawal of consent: for processing based on consent, guardians may withdraw consent through system permission settings or by contacting us. Withdrawal does not affect the lawfulness of processing carried out before withdrawal; after withdrawal we will stop the relevant processing and delete or anonymise the children's personal information collected (unless otherwise required by law).
- Account deletion: to delete an account, submit a request via the email or support hotline listed under "Contact Us" and we will handle it in accordance with law after verification, deleting or anonymising the children's personal information within a reasonable period.
- Refusal and restriction: guardians may refuse further collection, use or disclosure of children's personal information. Refusal does not affect features that do not depend on that information (such as device setup or listening).
- We do not use children's personal information for commercial advertising, user-profiling or marketing unrelated to the service.
5. Miscellaneous
This Policy is a supplementary policy to the Privacy Policy and applies together with it to child users. If the two conflict, this Policy prevails.
Contact Us
- Company: Shenzhen Yuanqi Chuangxiang Artificial Intelligence Co., Ltd.
- Email: privacy@tocotalk.com
- Support hotline: 0755-23216256
- Address: 601-A05, Yousuowei Building, No. 2000 Jiaxian Road, Gangtou Community, Bantian Street, Longgang District, Shenzhen
- Website and general domain: https://www.mindax.cn
- Filing number: 粤ICP备2025456131号-3A
We have a dedicated person responsible for children's personal-information protection. If guardians have any question, comment or suggestion about this Policy, or wish to exercise rights relating to children's personal information, they may contact us through the channels above; we will respond within 15 business days.