xanther · Children's Personal Information Protection Rules

Version: v1.0 Effective date: 2026-05-21

These rules are drafted in accordance with Article 31 of the Personal Information Protection Law of the People's Republic of China (PIPL) and the Regulations on Internet Protection of Children's Personal Information, and apply to children under 14 years of age.

These rules apply together with the Privacy Policy and the Terms of Service. Where these rules are inconsistent with those documents, these rules prevail.

Chapter 1 — Our Position on Child Protection

1.1 We do not offer services to children under 14

"xanther" (the "App") is an emotional-wellness product designed for adults. Its core features (health monitoring, emotion recognition and trend analysis, awareness diary) are not suitable for children.

We do not provide the App's services to children under 14 years of age ("children"). Specifically:

• We verify date of birth at registration; accounts whose date of birth indicates the user is under 14 cannot be registered
• The registration flow expressly states that "the App does not offer services to children under 14"
• No feature entry point, paid purchase, or content-creation surface within the App is targeted at children

1.2 We do not actively collect any personal information from children

Where we know that a user is a child, we will not:

• Collect the child's name, date of birth, gender, profile picture, voiceprint, face, or other personal information
• Collect the child's physiological health data
• Process the child's awareness diary or AI dialogue content
• Push any commercial content to the child

Chapter 2 — Discovery and Handling of Mistaken Child Registrations

2.1 When a guardian discovers a mistaken child registration

If you are a parent or other guardian of a child and discover that the child has registered the App in violation of these rules — using the guardian's identity information (or forged identity) — please contact us immediately through the channels below:

• Email: sznssj2021@163.com
• Customer-service email: sznssj2021@163.com

Please include in your email:

1. The phone number / WeChat account / Apple ID used by the child (any one is sufficient)
2. Proof of your guardianship (e.g., a scan of the household register, birth certificate, or other equivalent document)
3. The measures you would like us to take (such as deleting the account or deleting specific data)
4. Your contact information

2.2 Our handling process and timeline

• Acknowledgment: We will confirm receipt of the ticket within 24 hours
• Verification: We will complete verification of the guardianship within 7 business days
• Deletion: After verification, we will permanently delete the child's account and all related data, including backups (except for logs we are legally required to retain), within 7 business days
• Notification: We will notify the guardian by email after deletion is complete

2.3 Proactive detection mechanism

• If, in the course of day-to-day operations, customer-service feedback, or risk-control auditing, we reasonably suspect that an account belongs to a child, we will immediately request additional identity information from that account via SMS or in-app message
• If the requested information is not provided within a reasonable period, or verification confirms that the user is a child, the account will be frozen and handled in accordance with the process described in 2.2

Chapter 3 — Minors Between 14 and 18

3.1 Conditions of use

Minors who are 14 years of age or older but under 18 ("teenagers") may use the App only with the consent of their guardian.

3.2 Guardian consent

• When a teenager first registers, the App displays a "Teen-use notice" and requires confirmation that guardian consent has been obtained
• Guardians may contact us at any time at sznssj2021@163.com to withdraw consent, access, correct, or delete the teenager's personal information
• After consent is withdrawn, we will stop processing the teenager's personal information (except for statistical data that has already been irreversibly anonymized)

3.3 Purchase protection

• Any in-app purchase by a teenager must be expressly consented to in advance by a guardian
• If a guardian discovers an unauthorized purchase by a teenager, the guardian may request a refund by presenting proof of guardianship and the purchase record to sznssj2021@163.com

Chapter 4 — Security Safeguards

We apply the same — or stricter — protection to children's and teenagers' personal information (if it is collected by mistake) as to other personal information:

• The same field-level AES-256 encryption
• The same least-privilege access controls
• Once information is confirmed to belong to a child, it is placed in the deletion queue at the highest priority and may not be used for statistics, training, improvement, or any other purpose

Chapter 5 — Contact Us

• Children's personal information protection: sznssj2021@163.com
• Customer service: sznssj2021@163.com
• Operating entity: Shenzhen Nanshengshijia Network Co., Ltd.
• Shenzhen office address: 22/F, Financial Technology Tower, No. 11 Keyuan Road, Science and Technology Park Community, Yuehai Subdistrict, Nanshan District, Shenzhen, China
• Phone: +86 13524723215
• ICP filing number: 粤ICP备2025440292号 / 粤ICP备2025440292号-3

We commit to responding to child-related requests within 7 business days. If you are not satisfied with our response, you may report the matter to:

• The Cyberspace Administration of China or its local offices
• The relevant department of the State Council in charge of education
• Public-security or consumer-protection authorities
• A people's court with jurisdiction (the designated court for jurisdiction is the People's Court of Nanshan District, Shenzhen)

Change Log