Children's Privacy Policy

Last Updated: November 11, 2025

I. Age Restrictions

1.1 General Age Requirement

• Sublinur Life APP is intended for users aged 13 and above
• In the United States (COPPA): Users under 13 must have parental consent
• In the European Union (GDPR): Users under 16 must have parental consent

II. COPPA Compliance (United States)

2.1 COPPA Principles

We comply with the Children's Online Privacy Protection Act (COPPA) which protects children under 13 in the United States.

2.2 Information Collection from Children

For users under 13, we collect only:

• Contact information (email, name) for parental verification
• Age information to ensure compliance
• Minimal technical data for service operation

2.3 Parental Consent

• We obtain verifiable parental consent before collecting children's information
• Parents can review, update, or delete their child's information
• Parents can opt-out of data collection
• Contact: service@sublinur.com for parental inquiries

III. GDPR Compliance (European Union)

3.1 GDPR Protection

We comply with the General Data Protection Regulation (GDPR) which protects children under 16 in the European Union.

3.2 Parental Consent

• Users under 16 (or age of digital consent in their country) must have parental consent
• We verify parental consent before processing personal data
• Parents have the right to access, correct, and delete their child's data

IV. Data Limitations for Children

4.1 Prohibited Data Collection

We do NOT collect from children:

• Behavioral data or activity tracking
• Geolocation data (for under 13 in US; limited for EU)
• Device IDs or persistent identifiers
• Cookies or tracking technologies
• Third-party behavioral targeting
• Information for marketing purposes

4.2 Permitted Data Collection

We collect only what's necessary to provide the service:

• Account information (username, email)
• User-generated content (playlists, collections)
• Minimal technical data (device type, OS version)

V. No Behavioral Targeting

5.1 Advertising Restrictions

• No behavioral advertising for children under 13
• No third-party advertising networks tracking children
• Advertisements are contextual, not behavior-based

5.2 No Marketing

• We do not market to children based on their data
• No behavioral profiling or predictive marketing

VI. Data Security for Children

6.1 Enhanced Security Measures

• End-to-end encryption for children's data
• Secure password requirements
• Regular security audits and penetration testing
• Compliance with ISO 27001 information security standards

6.2 Data Retention

• Children's data retained only as long as needed
• Account deletion removes all associated data
• No data retention for marketing purposes

VII. Parental Rights

7.1 Parental Access and Control

Parents have the right to:

• Know what information we collect from their child
• Review and correct their child's information
• Delete their child's account and data
• Opt-out of data collection
• Request a copy of collected data

7.2 How to Exercise Parental Rights

To exercise any of the above rights, parents should:

1. Send a request to: service@sublinur.com
2. Include the child's username and parent's email
3. Verify your relationship to the child
4. We will respond within 30 days

VIII. Third-Party Links and Services

8.1 External Links

• We do not intentionally link to third-party services targeting children
• We are not responsible for third-party privacy policies
• Parents should review external site policies

IX. Contact Information

For questions about our Children's Privacy Policy:

DARKBEACON H.K LIMITED.

Email: service@sublinur.com

Website: www.sublinur.com

Address：DARKBEACON H.K LIMITED

9.1 US COPPA Inquiries

For COPPA compliance questions, you may also contact the Federal Trade Commission (FTC) at: www.ftc.gov/coppa

9.2 EU GDPR Inquiries

For GDPR-related concerns, contact your local Data Protection Authority or visit: www.edpb.eu