Xiaohongshu Personal Information Protection Rules for Children/Teenagers

Last Updated: September 21th, 2022
Effective Date: October 5th, 2022

Xiaohongshu takes seriously the protection of the personal information and privacy of teenagers (minors under the age of 18) and children (particularly, minors under the age of 13). In the Xiaohongshu Personal Information Protection Rules for Children/Teenagers (these “Rules”), we will, based on the Xiaohongshu User Privacy Policy (the “Privacy Policy”), explain the rules and relevant matters for the collection and use of the personal information of children and teenagers (collectively, “Minors”). Where there is any discrepancy between these Rules and the Privacy Policy, these Rules shall prevail. The Privacy Policy shall apply mutatis mutandis to the matters not covered herein. By clicking the “Agree” button on the online interface, you and/or your guardian agrees that we may collect, use, store, share, transfer, disclose or otherwise process the personal information of the Minors in accordance with these Rules.
Special notes to the guardians:
To safeguard the legitimate rights and interests of your child, we expect you to ensure that your child uses our products and submits personal information to us with your consent and under your direction. For the purposes of providing you with a notice of the rules for processing personal information of children and obtaining your consent, you agree that we may collect your contact information from your child. We will not use your contact information for any purpose other than as described in the preceding sentence and will delete your contact information promptly if your consent is not obtained within a reasonable time after our notice to you. We will take special measures to protect relevant information in accordance with these Rules. If you disagree with these Rules, please ask your child to immediately cease access to/use of our products and services.
Special notes to the children/teenagers:
If you are a minor under the age of 18, please ask your guardian to read these Rules together with you and obtain the consent of your guardian before you use our products and services or submit your personal information. If you are under the age of 13, please obtain verifiable parental consent before you use our products and/or services and submit your personal information.
1. Teen Mode
1.1 We have designed and developed a “Teen Mode”. The guardian may enabled the “Teen Mode” and set the password through “Settings -Teen Mode” if he/she does not agree with the Minor’s use of the normal mode.
1.2 Under the Teen Mode, the Minors are not allowed to use Xiaohongshu from 22: 00 PM to 6: 00 AM or for over 40 minutes per day by default. A password is required for the continuous use of Xiaohongshu if the duration of single-day usage exceeds the above designed time limit. The password is set and managed by the guardians for them to effectively guide the Minors to use Xiaohongshu.
1.3 Under the Teen Mode, no tipping, top-up and other operations are available, and some functions are disabled.
1.4 Under the Teen Mode, we will present some educational and intellectual contents on the home page.
2. Collection and Protection of Personal Information of Children/Teenagers We will, based on the principles of legitimacy and necessity, informed consent, clear purpose, security assurance and lawful use, strictly perform our obligations and duties with respect to the protection of personal information of children/teenagers under laws and regulations.
2.1 How do we collect and use personal information of children/teenagers?
Please note that no products or services provided by us are children/teenagers-oriented. Therefore, we will collect and process the personal information of users in accordance with the Privacy Policy if we are unable to automatically identify and determine whether the personal information collected and processed belongs to the personal information of children/teenagers. If, however, we become aware that any user is a child/teenager through real-name authentication or otherwise, we will make reasonable efforts to remind the user to use our services under the supervision and guidance of his/her guardian. In addition, we will take special measures to protect accounts involving personal information of children/teenagers in accordance with these Rules and laws and regulations.
We may collect and use the personal information of children/teenagers for providing our products and services to them. For the specific purposes of our use, scope of information collection, and consequences for refusal to provide the information, you and your guardian may refer to the Privacy Policy for more details. In addition, if you voluntarily provide any personal information of children to us during your use of our services (e.g., your guardian voluntarily provides the personal information of children/teenagers to us when using our community, posting and other posting functions ), you and your guardian agree that we may collect and use the personal information of the Minors in accordance with these Rules. The guardians should be aware of that and make a prudent choice.
Personal information of children may be collected automatically by Cookies and other similar technologies we use. For more details, please refer to the section of “How We Use Cookie and Other Similar Technologies” in the Privacy Policy. If we collect and use personal information of children beyond the above scope, we will seek consent from the guardians anew.
You understand and acknowledge that, subject to the relevant laws and regulations, personal information of children/teenagers may be collected without the prior consent of their guardians if:
(a) it is necessary for the conclusion or performance of a contract in which the relevant individual is a party, or for human resources management in accordance with the labor rules and regulations established or the collective contract signed in accordance with the law;
(b) it is necessary for the performance of statutory duties or obligations;
(c) it is necessary for the response to public health emergencies, or for the protection of life, health or property safety of individuals under emergent circumstances;
(d) the processing is within a reasonable scope to conduct news reporting, supervision of public opinions or other activities in the public interest;
(e) the personal information processed has been disclosed by the relevant individual or otherwise legally disclosed, and the processing is within a reasonable scope in accordance with the Personal Information Protection Law; or
(f) there are other circumstances as specified by laws and regulations.
2.2 How do we store personal information of children/teenagers?
The personal information of children/teenagers that is collected and generated during our operations in the territory of the PRC will be stored within the PRC and will not be transferred or stored overseas. For any cross-border transfer of information, we will separately notify you and your guardian of the purpose of cross-border transfer of personal information, recipients of such information and security measures through an in-site notice or email and obtain your and your guardian’s separate consent.
We will take reasonable and practical measures to avoid collecting and processing irrelevant personal information of children to the maximum extent possible. We will retain the personal information of children/teenagers only for the period necessary for achieving the purposes set forth in these Rules, unless otherwise required by laws. Please refer to the section of “How We Store and Protect Your Personal Information” in the Privacy Policy for details about how we determine the period for retaining the personal information of children/teenagers.
In the event that we cease our service provision or business operation, we will promptly cease our collection of personal information of children/teenagers, notify the guardians in advance in accordance with the relevant laws and regulations, and, unless otherwise specified by laws and regulations or required by regulatory authorities, delete or anonymize the personal information of children/teenagers.
2.3 How do we share, transfer and publicly disclose personal information of children/teenagers?
We undertake to keep personal information of children/teenagers strictly confidential and share children’s personal information only in compliance with these Rules and with your express authorized consent. Please refer to the section of “How We Share, Transfer and Publicly Disclose Your Information” in the Privacy Policy for details.
In order to ensure the security of personal information of children/teenagers, we will not entrust any third party sub-processor to process their personal information under normal circumstances. If it is necessary to do so, we will conduct a security assessment of such sub-processor in terms of its qualifications, capacity and processing, and will enter into a sub-processing agreement with the sub-processor, specifying the responsibilities of the parties, specific processing activities, and term, nature and purposes of the processing to ensure that the entrusted processing does not go beyond the scope of authorization.
To be specific:
(1) Before sharing any personal information of children/teenagers with any third-party sub-processor or entrusting a sub-processor to process the same, we will take compliance measures in accordance with laws and administrative regulations, including but not limited to independently or through a third party agency, conducting a security assessment on the legality, legitimacy and necessity of sharing personal information of children/teenagers with the sub-processor and its capability to protect such information; and
(2) We will expressly specify in the agreement with the third-party sub-processor that the sub-processor shall take measures to protect the personal information of children/teenagers in strict compliance with relevant laws, regulations and regulatory requirements. We will require such sub-processor to comply with strict confidentiality obligations and to take effective confidentiality measures not less strict than those specified in these Rules during its processing of the personal information of children/teenagers, and not to use such information for any purposes other than those authorized by the children/teenagers and their guardians. In addition, we will require such sub-processor to:
(a) process the personal information of children/teenagers in accordance with laws, administrative regulations and our requirements;
(b) assist us in responding to requests made by the guardians of children/teenagers;
(c) take measures to ensure information security, and promptly report to us upon any breach of personal information of children/teenagers;
(d) delete the personal information of children/teenagers promptly upon termination of the entrusted sub-processing;
(e) refrain from transferring its obligations under the entrusted information processing agreement to any third party; and
(f) perform other obligations of protecting personal information of children/teenagers as required by laws.
2.4 How do we protect personal information of children/teenagers?
We attach great importance to the protection of privacy of children/teenagers. We have appointed designated personnel for children’s information protection and will take all reasonably practical measures to protect the personal information of children. We have a dedicated security department and data security process to ensure the security of the Minors’ information. We adopt a strict policy for data use and access to ensure that only authorized personnel have access to relevant information, and timely conduct security audits on data and technology. Meanwhile, we will take encryption measures and other technical measures to store the personal information of children/teenagers to ensure information security. Please refer to the section of “How We Store and Protect Your Personal Information” in the Privacy Policy for details about how we protect the personal information of children/teenagers.
2.5 How do we manage personal information of children/teenagers?
To make it easier for you or children/teenagers to access and manage the relevant personal information during the use of our products and services, we have provided you and children/teenagers with the appropriate operating settings in our products. You and children/teenagers may operate following the instructions set out in the section of “How You Manage Your Personal Information” in the Privacy Policy. In particular, you may access, change or delete the child’s personal information collected by us through the above methods.
You or children/teenagers may contact us through the means listed in the section of “How to Contact Us” in the Privacy Policy to request the deletion of the relevant personal information of the child/teenager in any of the following circumstances:
(a) We collect, store, use or disclose the personal information of the child/teenager in violation of laws, administrative regulations or the agreements between you and us;
(b) We collect, store, use or disclose the personal information of the child/teenager beyond the purpose and scope as described or the necessary term;
(c) You have withdrawn your consent; or
(d) You or the child/teenager has terminated his/her use of our products or services by way of account closure or otherwise.
2.6 We will seek to delete the relevant information as soon as possible if we are aware that we have collected the personal information of children without obtaining the prior verifiable parental consent.
3. Ensuring the Healthy Use of Xiaohongshu by Children/Teenagers
3.1 We are building a teenager-specific content pool by providing such contents as selected courses, calligraphy and painting, parenting, humanities and history, traditional culture, handicraft, natural science and other educational contents.
3.2 We are trying to optimize the algorithm for recommending contents to the Minors, with a view to expanding the horizons of the Minors by showing positive contents.
4. Miscellaneous
4.1 Under normal circumstances where a user does not expressly state the nature of the personal information, we will collect and process the personal information of the user in strict accordance with the Privacy Policy if we are unable to identify and determine whether the personal information collected and processed belongs to the personal information of children/teenagers.
4.2 When the guardian opts out of the “Teen Mode”, all the functions of Xiaohongshu will be available for use, and the category of information collected and the purpose of use will be governed by the Privacy Policy.
4.3 If you have any questions about these Rules, or any complaints or suggestions regarding the processing of children’s personal information, please contact us via the following contact details. We will respond to your request in accordance with laws and regulations after verifying your identity.
Email: shuduizhang@xiaohongshu.com
Company name: Xingin Information Technology (Shanghai) Co., Ltd.
Address: Room 4D67, No.1611 Cao’an Highway, Jiading District, Shanghai
Contact Number: +86-95218999