Chapter I How to Collect Your Personal Information
Chapter II2 How to Use Your Personal Information
Chapter IV How to Share, Transfer and Publicly Disclose Your Personal Information
Chapter V How to Protect Your Personal Information
Chapter VI How to keep your personal information
Chapter VII Management, View or Delete Your Personal Information
Chapter VIII Protection of Minors’ Information
Chapter VIII How to update this policy
Chapter X Complaints and Suggestions
Chapter XI Others
Chapter 1 How to Collect Your Personal Information
According to Appendix A(Informative Appendix)-Examples of Personal Information-Table A.1 of GB/T35273 Personal Information Security Specification for Information Security Technology, personal information refers to all kinds of information recorded electronically or in other ways that can identify the identity of A specific natural person or reflect the activities of A specific natural person alone or in combination with other information. If name, date of birth, ID card number, individual biometric identification information, address, communication communication contact way, communication record and content, account number and password, property information, credit information, track of whereabouts, accommodation information, health physiological information, trade information, etc.
According to Appendix B(Informative Appendix)-Determination of Personal Sensitive Information in GB/T35273 Personal Information Security Code, Personal sensitive information refers to the personal information that may endanger the safety of personal and property and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment once disclosed, illegally provided or abused. Such as personal property information, personal health physiological information, personal biometric information, personal identity information, network identity identification information and other information.
1.1 Relevant personal informationprovided
1.1.1 In order to use our products or services, first of all, you need to register an account and log in. You may choose to create an account for our products or services through WeChat, Facebook, Instagram, Twitter, mobile number, etc., and log in (” Account Login “).
22.214.171.124 If you choose mobile number to login, you need to provide us with your mobile phone number. We collect this information to identify and verify your identity. This also helps us to bind your mobile phone number to our account, so that the data under the account can be synchronized between different devices. If you refuse to provide your phone number, you will not be able to log in with your phone number, nor will you be able to synchronize your data with your phone number. If you sign in with a third party account such as WeChat, Facebook, Instagram or Twitter, you do not need to provide us with your phone number. However, after you log in, you can choose to provide us with your mobile phone number to improve your account information, you do not provide the supplement may affect your use of some of our products or services.
126.96.36.199 When you choose to log in to our products or services through third party accounts such as WeChat, Facebook, Instagram or Twitter, you agree that we can obtain the information you are authorized to share from third parties such as WeChat, Facebook, Instagram or Twitter (WeChat login:Obtaining public information about users, including profile pictures, nicknames, regions and genders;Facebook, Instagram, Twitter login: access to public information), and agree to bind your third-party account with your account of our products or services, so that you can directly log in and use our products or services through the third-party account, and use the account to realize data synchronization between different devices. We will use the personal information you authorized to share in accordance with the agreement with the third party and in accordance with the relevant laws and regulations. If you refuse to allow us to obtain the information you are authorized to share from a third party, you will not be able to register and log in our account through such third party accounts as WeChat, Facebook, Instagram or Twitter, nor will you be able to realize data synchronization with such third party accounts.
188.8.131.52 You may need to provide us with your mobile phone number, WeChat ID, Facebook ID, Instagramid, Twitter ID when you purchase our fee-paying products and services, or to provide you with our course explanation, school supervision group operation and other services in order to implement the agreement you signed with us. In order to help you successfully complete the transaction, protect your transaction security and inquire the order information, we will collect your transaction commodity/service information, order number, transaction amount, payment method, contact phone number, bank account number and other information when you place an order or to complete the transaction. If your purchase is made through a third party, we may also collect your third-party payment account (Alipay account, WeChat account, PayPal account, Apple account).
1.1.2 When you use our products or services, you may contact our customer service for account management, product use and other issues. To that end, in order to verify your identity, You may need to provide us with your name, mobile phone number, mobile phone recharge record, purchase record, payment record, system operation record & photo, bank account number, account number of third-party payment platform (Alipay account number, WeChat account number, Paypal account number, Apple account number), communication records and content of contact with us and other information related to your use of our products or services, so that our customer service staff can contact you and help you solve relevant problems. If you refuse to provide relevant information, we may not be able to help you solve the relevant problem.
1.2 Relevant equipment and network information we collect
When you use our products or service, we will collect the related information of your equipment, in order to provide you with a steady service support (such as data real-time synchronization, etc.), at the same time helps us to continually improve their products or services, enabling you in the process of using our product or service to obtain the optimal experience. The relevant device information we collect from you includes device name, device model, hardware serial number, operating system and application version and type, language Settings, resolution, mobile terminal random storage memory, login IP address, network access method, network quality data, mobile network information (including operator name), log information (such as operation log, service log), and so on.
1.3 We collect information from you by invoking permissions
1.3.1 In order to improve the use experience and convenience of our products or services, we may collect the following personal information from you by invoking the rights of the device. If you do not agree to provide such personal information, you may not be able to use the functions related to improving the user experience, or you may need to manually re-fill in some information during the use of our products or services.
1.3.2 If you want to upload picture information to us, you can choose to authorize us to invoke album permissions on the device you are using.
1.3.3 If you wish to make payment through a third-party mobile operator quickly and conveniently, you may choose to authorize the call of mobile operation-related permissions (such as SMS) in the device you are using if your device supports it, so that you can make payment quickly and conveniently.
1.3.4 If you wish to upload your recordings to us, you may choose to authorize us to invoke the microphone rights of the device you are using.
1.3.5 If you wish to implement or experience the above functions, you may need to enable your appropriate access rights to us on your device. You can also choose to close the corresponding access rights at any time to cancel the corresponding authorization. Permission display mode and closing mode may be different in different devices. For details, please refer to the instructions or guidelines of the device and system developer.
1.3.6 If you wish to use certain of our products or services, you may need to choose to authorize us to include your audio recordings and other audio materials in these courses. After obtaining your authorization, we may display your personal information (such as gender, profile picture, nickname, voice information such as recordings formed in us, etc.) in relevant products or services (such as leaderboard, participating in discussions, leaving messages) for other users to view.
1.3.7 In order to make statistical analysis of the data and better optimize the product design, we promise to de-identify and anonymize the data and information provided by you, such as date of birth, gender, region, personal introduction, recording formed in us, and so on, before conducting statistical and analysis.
1.3.8 In order to recommend appropriate products or services to you and to perform the agreements signed between the parties, we will collect your personal Internet records, including: browsing records, usage records, click records, learning data, etc. generated during your use of our products or services.
1.4 Information collected from you by a third party
1.4.1 The third party collects the relevant personal information from the third party payment service provider
1.4.2 Service providers such as third-party AD providers collect relevant personal information
We may work with third party service providers to incorporate third party services (such as advertising, links or other forms of promotional content) into our products or services.
184.108.40.206 Advertising push and delivery
We may share with the partners for promotion and advertising information, but we will not share what is used to identify your personal identification information (e.g., phone number, nickname, head). We only provide these partners with indirect portrait tag can’t identify your personal identity and to identify the device information or anonymous of equipment, network, channel information, helping them increase the effective touch rate of their ads without identifying you personally.
220.127.116.11 Advertising statistics
We may share analytical de-identified device information or statistics with service providers, suppliers and other partners of our business that are difficult or cannot be associated with your real identity. This information will help us analyze and measure the effectiveness of advertising and related services.
1.5 You should fully understand that we do not need to obtain your authorization to collect and use personal information under the following circumstances:
1.5.1 Related to our performance of obligations under laws and regulations
1.5.2 Related to the fulfillment of our obligations under laws and regulations and directly related to national security and national defense security
1.5.3 Those directly related to public security, public health or major public interests
1.5.4 Directly related to criminal investigation, prosecution, trial and execution of judgment, etc
1.5.5 For the purpose of safeguarding the life, property and other important legitimate rights and interests of the subject of personal information or other individuals, but it is difficult to obtain consent from the individual;
1.5.6 The collected personal information is disclosed to the public by the subject of personal information
1.5.7 It is necessary to sign and perform the contract according to the requirements of the subject of personal information
1.5.8 Collect your personal information from lawful public disclosure, such as lawful news reports, government information disclosure and other channels;
1.5.9 To maintain the safe and stable operation of the products or services provided, such as finding and dealing with the fault of the products or services;
1.6 By according to law, to a third party to provide the processing of personal information, and ensure the data receiver cannot recover and identify personal information main body, does not belong to the foreign share, transfer and disclosure of personal information, the preservation and processing of such data will be without prior notice to you and ask for your consent.
Chapter 2 How to Use Your Personal Information
After collecting your personal information, we will use your personal information according to the following rules:
2.2 Please note that you will continue to authorize us to use all personal information provided by you when using our products or services, unless you delete or reject our collection through relevant Settings, during the use of our products or services and until you cancel your account. However, when you cancel your account, we will stop using it and delete your personal information.
2.3 We maintain statistics on usage of our products or services and may share such statistics with the public or third parties to show overall usage trends of our products or services.
But these statistics do not contain any identifying information about you.
2.4 When we want to use your Personal Information for other purposes not specified in this Policy, or to use the information collected for a specific purpose for other purposes, we will actively seek your express consent in advance.
3.1 In order to better provide you with products or services, we use a number of automated data collection tools, currently including Flash Cookies and embedded Web links. With these technologies, we can track your learning progress in real time and learn about your preferences to provide you with a better and more personalized user experience. We will not use the above technology for any purpose other than the purpose stated in this policy. Please understand that some of our services can only be implemented using the techniques described above. If permitted by your device or related programs, you may turn off or remove the above technologies by changing the Settings or by visiting the provider’s web page or other appropriate means. However, this action may affect your use of our products or services.
Chapter IV How to Share, Transfer and Publicly Disclose Your Personal Information
4.1 We will strictly abide by relevant laws and regulations and keep your personal information confidential. We will not share your personal information with others except in the following circumstances:
4.1.1 Obtain your express consent or authorization in advance
4.1.2 To provide your information at the legal request of your guardian
4.1.3 Upon the legal request of your guardian, your information is provided in accordance with the relevant agreement signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents;
4.2 For companies, organizations and individuals with whom we share personal information, we will make reasonable efforts to require them to comply with relevant laws and regulations when processing your personal information, and make every effort to require them to take relevant confidentiality and security measures to ensure the security of your personal information.
4.3 We will not transfer your personal information to any company, organization or individual, except under the following circumstances;
4.3.1 Obtain your express consent or authorization in advance；
4.3.2 Provided in accordance with the relevant agreement signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents；
4.4 We will only publicly disclose your personal information under the following circumstances and under the conditions that we have adopted industry-standard security measures：
4.4.1 Disclosure of your designated personal information in a manner that you expressly agree to, as required by you；
4.4.2 We may publicly disclose your Personal Information as required by laws, regulations or mandatory requirements of administrative or judicial authorities. When we receive a request for such disclosure, we will legally require the requestor to produce relevant legal documents, such as a subpoena or a letter of assistance to the investigation. We carefully review each disclosure request to ensure that it complies with the relevant legal requirements. Where permitted by laws and regulations, we will encrypt and protect the files containing the disclosed information。
4.5 You should fully understand that we do not need your authorization to share, transfer or publicly disclose your personal information under the following circumstances：
4.5.1 Related to our performance of obligations under laws and regulations；
4.5.2 Directly related to national security and national defense security；
4.5.3 Those directly related to public security, public health or major public interests；
4.5.4 Directly related to criminal investigation, prosecution, trial and execution of judgment, etc；
4.5.5 For the purpose of safeguarding the life, property and other important legal rights and interests of the subject of personal information or other individuals, but it is difficult to get consent from the person；
4.5.6 The individual information subject discloses to the public on its own initiative；
4.5.7 Collection of your personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
Chapter 5 How to Protect Your Personal Information
5.1 We take the security of your personal information very seriously and will take all reasonably practicable measures to continuously protect your personal information to prevent others from accessing, tampering with or disclosing your personal information we have collected without authorization：
5.1.1 We have adopted industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable steps to protect your personal information. For example, SSL encryption is used to protect data exchanged between your mobile device and our products or services; We use trusted protection mechanisms to protect our data from malicious attacks.
5.1.2 We have adopted industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We only allow people who need to know to access the relevant personal information, and we have set up strict access control and monitoring mechanisms. We also require all persons who may have access to your personal information to fulfill the corresponding confidentiality obligations. Failure to comply with these obligations may result in legal liability or termination of the legal relationship with us.
We will take all reasonably practicable steps to protect your personal information. For example, SSL encryption is used to protect data exchanged between your mobile device and our products or services; We use trusted protection mechanisms to protect our data from malicious attacks
5.2 We will take all reasonably practicable steps to ensure that no irrelevant information is collected.
5.3 Please understand that due to technical limitations and possible malicious means, in the Internet industry, even if we do our best to strengthen security measures, it is not always possible to guarantee the absolute security of information 100%. You need to understand and be aware that the system and communication network used by you to access our products or services may have problems due to other factors beyond our control, and in such cases, we will do our best to assist in solving such problems according to law.
5.4 In the event of an information security accident, we will, in accordance with the requirements of laws and regulations, inform you in a timely manner: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and the suggestions for you to prevent and reduce risks independently. At the same time, we will timely inform you of the relevant situation of the event by email, letter, phone, push notification and other appropriate ways; When it is difficult to inform the information subject one by one, we will take a reasonable and effective way to release the announcement. At the same time, we will also in accordance with the requirements of regulatory authorities, the initiative to report the disposal of information security incidents.
Chapter 6 How to keep your personal information
6.1 We will continue to save users’ personal information during their use of our products or services
6.2 We promise to store your personal information within a reasonable and necessary period in accordance with the provisions of the law. For log information, record backup and other information, we will cancel your account for 60 days (however, if there is a minimum retention period required by law, we will keep the minimum period required by law); the transaction information is three years from the completion date of the transaction or 180 days after you cancel your account, whichever is the longer. After exceeding the above time limit, we will delete or anonymize your relevant information.
6.3 All your personal information will be stored in the People’s Republic of China
6.4 At present, we do not have a situation where we provide personal information overseas
Chapter 7 Management, View or Delete Your Personal Information
We strongly respect your rights to your personal information. We protect your rights to access, correct, delete and manage your personal information.
Access and correct your personal information
7.1 Unless otherwise provided by laws and regulations, you have the right to exercise data access.
You have the right to request us or make corrections by yourself when you find that we have made mistakes in handling your personal information or you have other modification or supplement requirements. The ways in which you may exercise your data access and correction rights include but are not limited to：
7.1.1 If you wish to access or modify your account information in our products or services, you can do so by accessing our products or services (you can do so by clicking “I” to enter the personal home page and clicking “Edit” function).。
7.1.2 As our products or services provided in the post, participate in discussions, messages, and other functions and you can have the chance to work through these made public or provide personal information, then we in the provision of the service will provide the corresponding function to ensure that you can access or delete you again in public during the process of the service or the provision of personal information
7.2 You have the right to know the identity or type of third parties who obtain your Personal Information through us. You can learn the identity or type of the third party through Chapters 1 and 4 of this Policy
Delete your personal information and revoke your agreed authorization
7.3 Delete Your Personal Information and Withdraw Authorization You may request us to delete your personal information under the following circumstances：
7.3.1 If we deal with personal information in violation of relevant laws and regulations；
7.3.2 If we collect and use your personal information without your consent；
7.3.3 If we deal with personal information in violation of your agreement or the provisions of the law；
7.3.4 If you no longer use our products or services, or you cancel the relevant account；
7.3.5 If we no longer provide you with products or services。
7.4 You have the right to withdraw your prior authorization to collect and use your personal information from us. When you withdraw your consent, we will no longer process your personal information. However, your decision to withdraw your consent will not affect your previous personal information processing activities based on your authorization.
7.5 You may withdraw your prior consent to us with respect to certain personal information by deleting the relevant personal information.
Canceling an account
7.6 You have the right to cancel your account registered with our products or services at any time.
You can log out your account in “My – Settings – Account Settings – Logout Account”.
7.7 You have the right to cancel your account registered with our products or services at any time.
Please note that the cancellation of our account for related products or services is not recoverable. After the cancellation of the account, we will stop providing products or services to you, and will delete your personal information under the account, unless otherwise stipulated by laws and regulations. You can log out your account in “My – Settings – Account Settings – Logout Account”.
Constraint information system automatic decision
7.8 If we only make decisions based on the non manual automatic decision-making mechanism including information system and algorithm, and these decisions significantly affect your legitimate rights and interests, you have the right to ask us to make an explanation, and we will also provide appropriate remedies.
Obtain a copy of personal information
7.9 Upon your request, we may provide you with a copy of the Personal Information (such as basic personal information) that we hold about you. You may make a request to us through our customer service or the contact information set forth in Chapter 11 of these Privacy Terms.
In response to your request above
7.11 For your reasonable request, we do not charge fees in principle, but for repeated, beyond the reasonable limit of the request, we will charge a certain cost fee. We may reject requests that are gratuitously repetitive, that require too much technology, that pose a risk to the legitimate interests of others, or that are unrealistic.
7.12 We may not be able to respond to your request under the following circumstances
7.12.1 Directly related to national security and national defense security；
7.12.2 Those directly related to public security, public health or major public interests；
7.12.3 Directly related to criminal investigation, prosecution, trial and execution of judgment, etc；
7.12.4 With evidence of subjective malice or abuse of power；
7.12.5 Responding to your request will cause serious damage to the legitimate rights and interests of other individuals and organizations；
7.12.6 Involving commercial secrets.
7.13 We have established a complaint management mechanism, including tracking process, etc. In order to ensure the security of the account and property, we may verify the relevant information with you. We will reply to your request as soon as possible after receiving your feedback, and the longest time is no more than 30 days. If you are not satisfied with the reply, you can appeal again by contacting our customers.
Chapter 8 Protection of minors’ information
8.3 If you are the guardian of a minor, if you have any questions about the use of our products or services by the minor under your supervision or the user information provided to us, please contact us in a timely manner. We will protect the confidentiality and security of minor users’ information in accordance with relevant national laws and regulations and the provisions of this policy. If we find that we have collected personal information from minors without first obtaining verifiable guardian consent, we will seek to delete the data as soon as possible.
Chapter 9 How to update this policy
9.1.1 Changes in the business functions involved in our products or services result in changes in the purpose, type and use of personal information；
9.1.2 Your rights to participate in the processing of personal information and how they are exercised have changed significantly；
9.1.3 The contact information of our department that handles the security of your personal information has changed；
9.1.4 Other changes that may affect the security of users’ personal information or affect users’ privacy rights, etc.
Chapter X Complaints and Suggestions
Company name: Proteux Technology Holding Limited Co., Ltd
Email for comments and feedback: email@example.com
Personal information leakage complaint and report E-mail: firstname.lastname@example.org
WeChat official account：Tang汉语学习（weekdays 9:30-12:00, 13:30-17:30）
Add: ROOM 5 13/F BLOCK II GOLDEN INDUSTRIAL BUILDING 16-26 KWAI TAK ST KWAI CHUNG NT
Chapter XI Others
11.1 If you have any dispute arising out of this Policy or our handling of your personal information, you may appeal to the competent people’s court.
11.2 If you think that our personal information processing behavior has harmed your legitimate rights and interests, you can also report to the relevant government departments.
Proteux Technology Holding Limited Co., Ltd
Updated: April 17, 2021