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GSK Child Privacy Notice

GSK Child Privacy Notice

China (Mainland)

 

Last Updated: June 20, 2023

This Privacy Notice applies only to our products or services that are intended for children under the age of 14 or that require the user to enter age information such as date of birth or age. For products or services that do not identify the user's age, please refer to the GSK General Privacy Notice and the Privacy Notice(if any) for the specific product or service.

Please understand that where not covered by this notice, please refer to the applicable GSK General Privacy Notice or the Privacy Notice (if any) for specific product or service.

We are committed to protecting the personal information of children who use our products or services. This Privacy Notice is《GSK一般隐私声明》intended to inform guardians (hereinafter referred to as "you") and children about how we collect, use, store and process children's personal information and the ways we provide you and your child with access to, correct, delete and protect of such information.

Notes for children's guardians:

If you are the guardian of a child user, please read carefully and choose whether to agree with this notice. We hope that you will work with us to protect children's personal information, educate and guide children to enhance their awareness and ability to protect personal information, and instruct, remind and require them not to provide any personal information to any network product and service provider without your consent.

Notes for children:

If you are a minor under the age of 14, you need to read this notice carefully with your guardian and use our products, services or provide information to us with your guardian's consent.

After carefully reading and fully understanding the GSK General Privacy Notice, Privacy Notice (if any) for specific product or service and this notice, please choose whether you agree to the relevant privacy policies and whether you and your children under your guardianship agree to use our products or services. If you do not agree with the relevant privacy policies and the contents of this notice or do not agree with the information necessary to provide services, it may cause our products or services to operate normally, or we will not be able to achieve the service effect we intend to achieve, you and your child may not be able to use our services or related specific business functions normally.

GlaxoSmithKline values your privacy and that of your children .When we say "GSK","we","us" or "our", we mean local GSK company, GlaxoSmithKline LLC (at Navy Square, 5 Crescent Avenue, Philadelphia, PA 19112, USA) and GSK Services Unlimited (at 980 Great West Road, Middlesex County, Brentford, United Kingdom).

Personal information means various information related to identified or identifiable natural persons recorded electronically or in other ways, excluding anonymized information; “process(ing)” personal information refers to collection, storage, use, processing, transmission, provision, disclosure and deletion, etc. of personal information. If any content in this Privacy Notice conflicts with China laws and regulations, Chinese laws and regulations shall prevail.

In this Privacy Notice, we explain:

Contact Information and Your Privacy Point of Contact

If you have any questions about this notice, want to exercise your and your children's rights, need more information or would like to raise a concern, you can find details of each local privacy point of contact here.

In the meantime, you can contact GSK China Privacy Office at cn.pharma-privacy@gsk.com and we will answer you as soon as possible. 

What personal information do we collect about you and your child?

We strictly abide by the provisions of laws and regulations and the agreement with users, and collect the following personal information of you and your children under your guardianship according to the specific conditions of the products or services selected by users.

  • Information to identify the age of children-We provide products and services for children under the age of 14, or products and services which requires users to provide birthday or age information that identifies user’s age, If you register or use such products or services, we will require users to fill in personal birthday information to identify whether the user is a child under the age of 14.
  • Contact information of the guardian-When we identify that the user is a child under the age of 14 based on the above information provided by the user, we will collect your contact information, including telephone number and email address, and use this information to contact you to verify the guardianship relationship between you and your child.

In addition to the categories of personal information described above, we collect relevant information in relation to a child's use of a product or service, as described in the chapter "What personal information we collect about you" in the GSK General Privacy Notice. We recommend that you do not provide the child's real name, portrait, contact information and other information without necessity, and do not easily share the child's personal information with others through our products and services or publish it publicly in our products and services.

If we need to collect personal information of you or your children beyond the above collection scope, we will inform you again and obtain your consent.

Please understand that you can choose whether to fill in or provide specific information to us, but if you do not fill in or provide certain specific information, it may cause our products or services to fail to operate normally, or fail to achieve the service effect we intend to achieve, and you and your children may not be able to use our products, services or related specific business functions normally.

 

How do we collect children's personal information?

We will follow the principle of minimum necessity to collect personal information of your child directly from you with your explicit consent, based on the necessity to achieve the purpose of processing.

How do we use or process children's personal information in other ways?

We strictly abide by the provisions of laws and regulations and agreements with users, and use the information collected from you and your children for the following purposes:

  • Verify the identity of children and guardians;
  • Provide the necessary product or service, the specific function of the product or service;
  • For product or service optimization, security assurance, service investigation purposes.

If we need to use your personal information or that of a child under your guardianship for purposes other than those described above, we will inform you again and obtain your consent.


Why are we allowed to collect and process children's personal information?

We may collect and process children’s personal information under your guardianship when one of the following applies:

  • Where your consent is obtained;
  • Where it is necessary for the conclusion or performance of a contract to which the individual concerned is a party, or for the implementation of human resources management in accordance with the labour rules and regulations formulated in accordance with the law (including but not limited to this Privacy Notice) and the collective contract concluded in accordance with the law;
  • Where it is necessary for the performance of statutory duties or statutory obligations, such as providing your personal information to the social insurance authorities for the purpose of making social insurance contributions;
  • Where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person;
  • Where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of personal information is within a reasonable scope;
  • Where it is necessary to process the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the law; and
  • Other circumstances prescribed by laws and administrative regulations.

How do we protect children's personal information?

The safeguards for the security of personal information we disclose in the GSK General Privacy Notice apply to children's personal information. At the same time, we have included children's personal information in the category of sensitive personal information and strictly abide by national laws and regulations to ensure the security of children's personal information.

  • Take encryption or other necessary technical measures for the storage, transmission and transfer of children's personal information;
  • Conduct security impact assessment when entrusting a third party to process personal information or transferring personal information to a third party;
  • We strictly limit the scope of personnel who can access children's personal information, require them to abide by confidentiality obligations, and shall not access and use children's personal information at will. In addition to keeping access records, we shall take technical measures to avoid illegal copying and downloading of children's personal information.

 

What are your rights regarding children's personal information?

You have rights we need to make you and your child aware of. The rights available to you depend on our reason for processing your personal information and your children’s personal information and the laws and regulations in China. Please refer to the chapter "What are your rights regarding your personal information" in the GSK General Privacy Notice.

You can find out how to contact us to exercise your rights in the chapter “Contact Information and Privacy Contact Point ”.


How long do we keep children's personal information?

We will keep children’s personal information only for as long as we have to, so we can complete the activities we have explained in this Privacy Notice (Please refer to “How do we use or process children’s personal information in other ways”). After the activity is completed, we will retain children’s personal information in accordance with relevant laws and regulations and GSK's global records retention schedule.

We will always keep children’s personal information for the period required by law and where we need to do so in connection with legal action or an investigation involving GSK. After the storage period of children’s personal information expires, we will delete or anonymize your personal information to make it not accessible and keep relevant deletion or anonymization record, except for the personal information that must continue to be stored for a longer period of time according to laws and regulations.

 

Will children's personal information be shared, transferred or disclosed?

We only share children's personal information on a necessary basis and strictly restrict the sharing, transfer and disclosure of children's personal information in accordance with laws and regulations. Please refer to the chapter "Will your personal information will be shared, transferred or disclosed" in the GSK General Privacy Notice for details of the sharing and transfer of children's personal information. If we need to entrust a third party to process children's personal information, we will conduct a security assessment of the entrusted party and the entrusted behavior, sign an entrustment agreement, clarify the responsibilities of both parties, the handling items, the processing period, the nature and purpose of the processing, etc. The entrusted processing will not exceed the scope of the children's information you authorize us to process. We will be responsible for the protection of children's personal information in the case of entrusted processing, and supervise and require the entrusted party to perform the following obligations:

  • Process children's personal information in accordance with the provisions of laws, administrative regulations and our requirements;
  • Assist us in responding to requests from guardians of children;
  • Take measures to ensure information security, and in the event of a child's personal information security incident, timely give feedback to us;
  • Delete the children's personal information in a timely manner when the entrustment relationship is terminated;
  • No transfer of entrustment; and
  • Other obligations to protect children's personal information that shall be fulfilled according to the law.

In general, we do not provide children's personal information to third parties. We may only provide children's personal information to third parties with the prior consent of the guardian.

We will conduct security assessments on our own or entrust a third-party agency when entrusting the processing or transfer of children's personal information, and take encryption and other technical measures to ensure the security of children's information.

The products and services we provide may include products or services provided by third parties, and you may also use third-party products and services through us. Please note that this third party may collect, use or process information about children, which requires the third party to obtain your consent separately. We recommend that you ask your child to seek your consent before authorizing the collection and processing of any of their personal information by a third party.

We prohibit the disclosure of children's personal information without your prior consent, unless we have a legal right or obligation to do so.

How we update this Privacy Notice?

We will update this Privacy Notice from time to time. Any changes will be effective when we post a revised Privacy Notice on the Privacy Center. This Privacy Notice was last updated as of the “Last Updated” date shown above. If changes are significant, we will provide a more prominent notice to let you know what the changes are. If such updates involve the rights of personal information subjects and matters that may cause you to change your consent or need to obtain your consent again (for example, the purpose of processing, the type of information collected, etc.), we will re-seek your consent to the updated privacy policy in accordance with the provisions of laws and regulations. 

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