Welmo Technology Minors Personal Information Protection Rules

This English version is a courtesy translation. In case of any discrepancy between the Chinese and English versions, the Chinese version shall prevail.

Important Notice

Welmo Technology fully understands the importance of protecting minors' personal information and physical and mental well-being. This rule is established under the PRC Law on the Protection of Minors (especially its Internet Protection chapter), Article 31 of the PIPL, and the Provisions on the Protection of Children's Personal Information Online.

Welmo Technology's services are primarily aimed at adults with full civil capacity. This rule informs minor users, guardians, and the public of our commitments and arrangements for the protection of minors' personal information.

1. Scope

1.1 Definition of "Minor"

For the purposes of this rule, a "minor" is a natural person under 18 years of age. Within this:

• "Child" means a minor under 14 years of age;
• "Teen" means a minor between 14 and 18 years of age.

1.2 Applicability

This rule applies to all products and services provided by Welmo Technology on *.welmotech.com and the WeChat Mini-Program "Welmo Perks" (未陌惠).

2. Our Basic Position

2.1 Target Audience

All Welmo Technology services are by default designed for adults with full civil capacity. Our products (black peppercorn refills, plant-based meal replacement trial, pet memorial storage, etc.) are not designed, produced, or marketed for minors.

2.2 No Active Collection

Welmo Technology does not actively collect the personal information of minors. We:

• Do not design promotional content targeting minors;
• Do not run ads targeting minors on external e-commerce channels (Douyin, Kuaishou, Xiaohongshu);
• Do not actively ask for age in product pages or registration flows;
• Do not run marketing campaigns specifically for minors.

2.3 Acknowledged Risks

We nevertheless recognize:

• Neither the WeChat Mini-Program nor the website has a mandatory age verification mechanism;
• Minors may access the Service through guardian devices, accounts, or other means;
• Minors may also register and activate benefits without informing their guardian.

We adopt this rule as a proactive measure to address such residual risks.

3. Rules for Minors Using the Service

3.1 Children Under 14

Children under 14 years of age may not register accounts or use the Service on their own.

If use is necessary:

• It must be conducted by their parent or other legal guardian, fully accompanied and on their behalf;
• Registration, activation, fulfillment information, and all other operations are completed by the guardian on behalf of the child;
• The guardian assumes full legal responsibility for such use.

3.2 Teens Between 14 and 18

Teens between 14 and 18 years of age using the Service shall:

• Obtain prior consent from their parent or other legal guardian;
• Register an account and activate benefits with the knowledge and consent of the guardian;
• Have the guardian decide on uploads of sensitive personal information such as photos and videos;
• The guardian may exercise all rights under this rule and the Privacy Policy (Document 02) on behalf of the minor.

3.3 Guardian Responsibilities

When permitting a minor to use the Service, parents or other guardians shall:

• Read and understand the Terms of Service (Document 01), the Privacy Policy (Document 02), and this rule;
• Supervise the minor's use to prevent uploading of inappropriate content or excessive disclosure of personal information;
• Safeguard account credentials and SMS verification codes;
• Promptly attend to Welmo's service changes and privacy policy updates.

4. Special Protections for Minors' Personal Information

4.1 Processing Principles

For personal information of minors that is identified or notified by guardians, Welmo Technology follows these principles:

4.2 Separate Consent Mechanism

For processing personal information of children under 14, Welmo Technology requires:

• Obtaining separate consent from the guardian (per Article 31 of the PIPL);
• The consent must be recorded in a verifiable manner (e.g., guardian's own mobile verification, email confirmation);
• The guardian may withdraw consent at any time.

4.3 Activities We Do Not Conduct

For minors, Welmo Technology will never:

• Conduct profiling or personalized recommendations;
• Use information for commercial advertising;
• Share with third parties (except recipients required by law and necessary fulfillment partners);
• Use information for AI model training;
• Use information for marketing purposes (even with guardian consent, the information will not be used for marketing).

4.4 Special Protection for Uploaded Content

• Photos and videos uploaded by minors or by guardians on their behalf will be processed by Welmo Technology in private display mode and will not be used for marketing;
• Even if the guardian has checked the video authorization box for The Greens, if we later identify a minor's image in the video, we will proactively contact the guardian for confirmation; if the guardian withdraws authorization, we will immediately take it down.

5. Handling Process After Discovery

5.1 How We Identify Minors

Welmo Technology identifies potential minor users through:

• User self-disclosure (e.g., mention of age in customer service communications);
• Guardian complaints;
• Detection during content review of student IDs, ID cards, schools, or other age indicators;
• Notice from third parties (schools, educational institutions, relevant authorities).

5.2 Measures After Identification

Once identified as a minor user (especially a child under 14), we will:

5.3 Special Situations

• If we discover that a minor has uploaded inappropriate content, we will immediately delete it and contact the guardian;
• If we discover that a minor faces cyberbullying, fraud, or other dangerous situations, we will report to relevant authorities according to law;
• If we discover that a minor has made payments (in the external e-commerce stage), we will help the guardian communicate with the external e-commerce platform regarding refunds.

6. Guardian Rights

Guardians have the following rights regarding the minor's personal information and may exercise them at any time via legal@welmotech.com:

6.1 Right of Access

Access all personal information processed by Welmo Technology about the minor.

6.2 Right of Correction and Supplementation

Correct erroneous or incomplete personal information.

6.3 Right of Deletion

Request deletion of all personal information of the minor. Welmo Technology will complete processing within 15 business days.

6.4 Right to Restrict Processing

Request that Welmo Technology limit the scope of processing the minor's personal information.

6.5 Right to Withdraw Consent

Withdraw consent previously given. Withdrawal does not affect the validity of processing carried out before withdrawal.

6.6 Right to Complain

If you believe Welmo Technology's processing of a minor's personal information is non-compliant, you may:

• Complain via legal@welmotech.com;
• Complain to local cybersecurity authorities (12377) or the consumer association (12315);
• File suit with a competent People's Court.

6.7 Guardian Identity Verification

When exercising the foregoing rights, guardians may need to provide:

• A copy of the guardian's own identity document;
• Proof of relationship with the minor (household register, birth certificate, etc.);
• The minor's account information or purchase order number.

Welmo Technology will keep these materials strictly confidential and use them only to verify guardian identity.

7. Content Management and Anti-Addiction

7.1 Content Suitability

Welmo Technology's products themselves (black peppercorns, meal replacement, pet memorial) are not in categories unsuitable for minors. Nevertheless, we commit:

• Not to display ads or links unsuitable for minors on any product or activation pages;
• To require partner external e-commerce platforms to comply with equivalent minor protection standards.

7.2 Anti-Addiction

The nature of Welmo's services (one claim per month, one trial cashback) is inherently non-addictive. We:

• Do not set any mechanism that encourages frequent logins, daily check-ins, or forced daily active use;
• Do not send push notifications that interfere with minors' normal life and study.

8. Contact Us

If you are a guardian or a minor user wishing to communicate about personal information processing, please contact us via:

• Personal Information Protection Officer Email: legal@welmotech.com
• Customer Service Phone: +86 158 3825 5257 (Daily except Wednesdays, 09:00–18:00 CST)
• Company Name: Henan Welmo Technology Co., Ltd.
• Registered Address: Room 2501, 25/F, Unit 1, Building 5, Yard 66 Zhengtong Road, Erqi District, Zhengzhou City, Henan Province, China

We commit to providing an initial response to minor-protection-related requests within 5 business days and completing processing within 15 business days.

9. Honest Disclosure of Engineering Status

This section is a technical-status statement to users and regulators, ensuring the authenticity of Welmo Technology's commitment to minor protection.

Welmo Technology's current technical systems do not have a built-in automatic age verification mechanism:

• Registration does not require date of birth or ID number;
• No facial recognition, liveness detection, or other age-determination tools;
• Reliance is mainly on post-discovery + manual handling (the process described in Section 5).

We have included "supplementing automated age recognition" in our future product improvement plan. Before such capability launches, we compensate as follows:

• Prominently inform in the Privacy Policy and this rule that minors should not register on their own;
• On first activation of a benefit, require the user to confirm they are at least 18 years of age;
• Accept and prioritize fast deletion requests submitted by guardians via legal@welmotech.com;
• Pay attention during content review for the presence of minors and actively verify.

Revision History

All rights of final interpretation reserved by Henan Welmo Technology Co., Ltd.

Document ID: WELMO-LEGAL-07 · Version v1.0 · April 7, 2026