1. Introduction

This Children’s Privacy Policy (hereinafter referred to as the “Policy”) constitutes an integral part of the STOQ Privacy Policy and establishes special rules for the processing of data of persons who have not attained the age of majority when using the STOQ platform, provided by STOQ FZ-LLC (FDRK5298, Compass Building, Al Shohada Road, AL Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates) (hereinafter referred to as “STOQ” or “we”).

This Policy is applied in conjunction with the STOQ Platform Terms of Use, the Privacy Policy, the Cookie Policy, and the Refund Policy. In the event of a conflict between this Policy and the Privacy Policy with respect to the processing of minors’ data, the provisions of this Policy shall prevail as the special instrument.

2. Who Is STOQ Intended For

STOQ is a digital platform for storing, managing, and organising objects, collections, records, and other user data. The Service is intended for use by individuals of any age, subject to compliance with the conditions established by this Policy and the Terms of Use.

STOQ is not a service specifically designed for or directed at children. The platform does not contain features intended exclusively to attract minor users.

Nevertheless, since the Service permits use by persons of any age, STOQ implements special measures to protect the personal data of minors in accordance with the requirements of applicable legislation, including COPPA (USA), GDPR (EU/EEA), and UAE PDPL (UAE).

3. Age Restrictions and Conditions for Use by Minors

3.1. General Rule

Use of STOQ by persons under the age of 18 is permitted exclusively with the express prior consent of a parent or legal guardian, who shall bear full responsibility for the minor’s use of the Service.

3.2. Age Thresholds by Jurisdiction

For users under the age of 13 (USA) and under the age of 16 (EU/EEA), verified parental or legal guardian consent is required. For users aged 13 to 18 (USA) and 16 to 18 (EU/EEA), parental consent without special verification is sufficient. In the UAE and other jurisdictions, the requirements of local legislation shall apply.

3.3. Prohibition of Independent Registration Without Consent

Persons who have not attained the applicable minimum age may not independently create an account, take out a Subscription, or enter personal data into the Service without the consent and participation of a parent or legal guardian. If STOQ determines that an account has been created by a minor without such consent, access to the account shall be suspended, and the data shall be deleted in accordance with Section 10 of this Policy.

4. What Data May Be Collected About Minors

STOQ does not collect data of minors beyond the minimum necessary for the provision of the Service. The principle of data minimisation applies to all users, and is applied with particular rigour with respect to minors.

If a minor uses STOQ with the consent of a parent or legal guardian (including through an additional profile within a family Subscription), the following categories of data may be processed:

• additional profile registration data (username, settings), without requiring the provision of date of birth or other identifying information beyond the necessary minimum

• Service usage data: actions in the interface, features used, technical logs — in the same scope as for adult users

• technical device data: IP address, device type, operating system, application version — automatically upon access to the Service

• data entered by the user within the Service functionality (objects, collections, records) — exclusively those entered by the user independently

• support data — if a parent or legal guardian contacts customer support on behalf of a minor user.

STOQ does not request or process special categories of personal data of minors (health data, biometric data, data concerning racial or ethnic origin, etc.).

STOQ does not request precise location data of minor users.

5. Sources of Data

Data of minor users may be obtained from the following sources:

• directly from the parent or legal guardian — upon registration of an additional profile, account management, or contacting support

• automatically — during the use of the Service by the minor user (technical logs, session data, device data)

• from the minor user — with respect to data that they independently enter into the Service functionality (accounting objects, collections, etc.).

STOQ does not obtain data of minors from third-party sources, social networks, advertising platforms, or data brokers.

6. Purposes of Data Use

Data of minor users is used by STOQ exclusively for the following purposes:

• provision of Service functionality — providing access to paid features, data display, synchronisation

• ensuring security — protection of the account, prevention of unauthorised access, anomaly detection

• technical diagnostics and error resolution — crash analysis, ensuring platform stability

• fulfilment of legal obligations — compliance with applicable legislation requirements, responses to lawful requests of public authorities

• processing requests from the parent or legal guardian — including requests for access to data, rectification, or deletion.

STOQ does not use data of minor users for marketing purposes, behavioural analytics, profiling, targeted advertising, or transfer to advertising platforms.

STOQ does not train AI models on personal or identifiable data of minor users. Aggregated anonymised data that does not permit the identification of a specific user may be used for the technical improvement of the Service.

7. Parental / Legal Guardian Consent and Age Verification

7.1. Consent Requirement

Registration and use of the Service by a minor user is carried out by the primary account holder — the parent or legal guardian. By granting the minor access to the Service within an additional profile, the account holder confirms their express consent to the processing of the minor’s data in accordance with this Policy and the STOQ Privacy Policy.

7.2. Verification Mechanism

STOQ implements the following measures to ensure compliance with age requirements:

• upon creation of an additional profile, the parent or legal guardian expressly confirms that they are granting access to a minor and assumes responsibility for their use of the Service

• upon receipt of information regarding possible use of the Service by a minor without proper consent, STOQ may request supporting documents from the account holder

• upon receipt of substantiated information that an account has been created by a minor independently, STOQ shall suspend access and notify the registered user accordingly.

7.3. Verification Limitations

STOQ does not perform automatic age verification of all users upon registration. Responsibility for ensuring that the minor uses the Service exclusively with the consent and under the supervision of a parent or legal guardian rests with the person who created and manages the primary account.

8. Cookies, Analytics, and Similar Technologies in the Context of Minors

With respect to minor users, the same cookie technologies and similar technologies as for adult users are applied, subject to the following restrictions:

• strictly necessary cookies (session management, security, Service operation) are applied regardless of the user’s age, as the use of the Service is technically impossible without them

• analytics cookies and SDKs are applied only with consent obtained through the consent banner in jurisdictions where such consent is required; responsibility for managing consent with respect to minors rests with the parent or legal guardian managing the primary account

• STOQ does not set advertising or marketing cookies with respect to minor users and does not transfer data on their behaviour to advertising platforms

• STOQ does not use profiling or behavioural targeting technologies with respect to minors.

A detailed description of the cookies used and the mechanisms for managing them is contained in the STOQ Cookie Policy.

9. Subscriptions, Billing, Cancellation, and Refunds in the Context of Minors

Subscriptions to the STOQ Service may be taken out exclusively by adults or legal guardians of minors. Minor users may not independently take out, modify, or cancel a Subscription or make payments in the Service.

If a Subscription has been taken out by a minor without the consent of a parent or legal guardian, such Subscription shall be subject to a refund in accordance with Section 3.2 of the STOQ Refund Policy, subject to the provision of supporting documents within 14 (fourteen) days from the date of discovery of such fact.

Upon deletion of a minor user’s data, STOQ shall retain payment and accounting records related to Subscription payments for the periods established by applicable tax legislation (generally 5 to 7 years). This retention obligation does not affect the minor’s operational data, which shall be deleted in accordance with Section 10 of this Policy.

10. Data Retention and Deletion

10.1. Retention Periods

Data of minor users is retained for the period of activity of the corresponding additional profile or primary account. Upon deletion of the profile or closure of the account:

• operational data of the minor (content, accounting objects, profile settings) is retained for the period provided for the corresponding subscription plan (up to 30, 60, or 90 days), after which it is permanently deleted

• security logs and technical logs — no more than 12 months

• payment and accounting data — for the periods established by applicable tax legislation.

10.2. Data Deletion Upon Request

A parent or legal guardian may at any time request the immediate deletion of a minor user’s data by sending a request to privacy@stoq.global. STOQ shall process such requests on a priority basis and shall fulfil them within 30 (thirty) days, except for data the retention of which is required by law.

10.3. Data Collected Without Proper Basis

If STOQ determines or receives credible information that data of a minor user has been collected without proper consent of the parent or legal guardian, STOQ shall immediately:

• suspend the processing of such data

• notify the registered user (account holder)

• delete such data at the earliest possible time if there are no legal grounds for their further retention

• if necessary, notify the competent supervisory authority in accordance with the requirements of applicable legislation.

11. Third-Party Providers and International Data Transfers

STOQ transfers user data, including data of minors, to service providers ensuring the technical functioning of the Service: cloud infrastructure, error monitoring tools, technical support systems, and payment providers. All such providers act on the basis of contractual data protection obligations and are entitled to process data only to the extent necessary for the performance of their functions.

STOQ does not transfer data of minors to advertising platforms, marketing agencies, data brokers, or other third parties for commercial purposes.

As STOQ is registered in the UAE and uses cloud infrastructure, data may be transferred and processed outside the user’s country of residence. For the transfer of data of users from the EU/EEA, the EU Standard Contractual Clauses (EU Standard Contractual Clauses 2021) are applied. For more details, see Section 8 of the STOQ Privacy Policy.

12. Rights of Parents and Legal Guardians

A parent or legal guardian of a minor user may at any time:

• request confirmation of the fact of processing of the minor’s data and obtain access thereto

• request the rectification of inaccurate or incomplete data of the minor

• request the deletion of the minor’s data (right to be forgotten)

• withdraw previously given consent to the processing of the minor’s data — from the moment of withdrawal, further processing shall cease; processing previously carried out shall remain lawful

• request the restriction of processing of the minor’s data

• receive the minor’s data in a structured, machine-readable format (right to data portability)

• file a complaint with the competent data protection supervisory authority (for users from the EU/EEA — with the national DPA; list of authorities: edpb.europa.eu; for users in the UAE — with the UAE Data Office).

All requests shall be sent to: privacy@stoq.global with the subject line «Children’s Privacy Request». For data protection purposes, STOQ may request verification of the applicant’s identity and their relationship to the minor user prior to processing the request. Response time — no more than 30 (thirty) days.

13. Security Measures

STOQ implements technical and organisational security measures with respect to all user data, including data of minors:

• encryption of data in transit and at rest

• access control based on the principle of least privilege

• monitoring and detection of anomalous activity

• regular vulnerability assessment and remediation

• obligations of service providers to comply with security standards.

In the event of a security incident affecting the data of minors, STOQ shall notify the competent supervisory authority within 72 hours and the affected users (parents or legal guardians) — without undue delay.

14. Relationship with the Terms of Use, Privacy Policy, Cookie Policy, and Refund Policy

This Policy is a special instrument and is applied in conjunction with the following STOQ documents:

• STOQ Platform Terms of Use — Section 7 (age restrictions, verified consent), Section 9a (additional profiles and minor users), Section 15 (suspension and termination of access)

• STOQ Privacy Policy — Sections 3–6 (data categories, purposes, legal bases), Section 9 (retention periods: 30/60/90 days after account closure), Section 12 (data subject rights), Section 15 (age restrictions)

• STOQ Cookie Policy — Sections 3.1–3.4 (strictly necessary cookies, functional, analytics, security), Section 7 (cookie management and consent banner), Section 8 (legal bases)

• STOQ Refund Policy — Section 3.2 (refund for purchase by a minor without parental consent).

15. Policy Updates

STOQ reserves the right to periodically update this Policy in connection with changes in legislation, Service functionality, or internal data processing procedures.

We shall notify of material changes affecting the rights of parents or minor users no less than 14 (fourteen) days prior to the effective date of such changes — through the Service interface and/or by email registered in the primary account. The date of the last update is indicated at the top of the document.

16. Contact Information

For all enquiries relating to the processing of minors’ data, the exercise of rights of parents or legal guardians, and any other matters under this Policy, please contact:

Children’s Privacy enquiries: privacy@stoq.global (subject: “Children’s Privacy Request”)

Legal Enquiries: legal@stoq.global

Technical Support: support@stoq.global