Children's Privacy Policy

Last Updated: June 26, 2026

This Children's Privacy Policy supplements our main Privacy Policy and describes how HO Smart Ring ("we", "us", "our") handles the personal data of minors. Capitalized terms not defined here have the meaning given in our Privacy Policy.

1. Age of Digital Consent

In the EU/EEA, the age at which a child may consent to the processing of their personal data varies by member state (between 13 and 16) under GDPR Art. 8. We apply a unified 16-year threshold across all regions: users under 16 may not create an account or use the Services, and verifiable parental or guardian consent is required where local law lowers this threshold.

2. Account Creation

Account registration requires an email address and date of birth. If we learn that we have collected personal data from a user under 16 without verifiable parental consent, we will delete that data promptly. If you believe a minor has registered without consent, please contact service@ho-ring.com.

3. Health Data Sharing for Minors (Couple / Family Features)

Our Couple Space and Family Care features allow users to share certain health data (heart rate, sleep, blood oxygen, stress, steps) with an authorized partner, friend, or family member.

• Under 16: Couple Space and Family Care features are not available. Health data cannot be shared with other users.
• Ages 16–18: These features are available, but sharing health data with a partner or family member may require parental or guardian consent where mandated by local law. We encourage parents and guardians to discuss these features with teens in their care.

4. Data We May Collect From Minors (16–18)

If a user aged 16–18 uses the Services, we collect the same categories of data described in our main Privacy Policy §3 (account information, health data from the ring device, device information). We do not conduct targeted advertising or profiling of minors, and we do not sell personal data.

5. Rights of Parents and Guardians

Parents or legal guardians may, on behalf of a minor, exercise any of the rights described in our main Privacy Policy §13, including:

• Access the minor's personal data
• Correct inaccurate data
• Delete the minor's data and account
• Withdraw consent for any processing based on consent

To exercise these rights, contact us at service@ho-ring.com. See our main Privacy Policy §12 for full contact details, including the interim contact for EU/EEA users while our EU Representative (Art. 27 GDPR) is being appointed.

6. Data Retention

Data belonging to minors is retained according to the same schedule as adult data (main Privacy Policy §7). Accounts belonging to users who are later found to be under 16 are deleted promptly upon discovery.

7. Contact Us

For any questions about this Children's Privacy Policy or to make a request regarding a minor's data:

• Privacy: service@ho-ring.com
• Data Protection Contact (EU): service@ho-ring.com

8. Changes to This Policy

We may update this Children's Privacy Policy from time to time. Material changes will be reflected by updating the "Last Updated" date above and, where appropriate, via in-app notification.