Last updated: March 30, 2021
Shandong Kexun Information Technology Co., Ltd. (hereinafter referred to as “SKIT”, “we” or “us”), having the principle place of business at Room 101, Building 5, Qingdao Innocenter, 480 Jiangshan South Road, Huangdao District, Qingdao City, Shandong Province, China, developed this Privacy Policy (hereinafter referred as “Privacy Policy”) for your reference so that you will be able to understand how we process your personal data when you use our LearnChinese-Global Chinese Learning Platform(hereinafter referred to as "products" or "LearnChinese") or services. Please read our privacy practices carefully and Contact Us if you have any questions (Email: ebg_gclpsupport@iflytek.com ).
Before you use this product, please read this policy carefully to ensure that you have fully understood and accepted all the terms, otherwise, please do not register, log in or use.
Privacy Policy
FULL PRIVACY POLICY
1． Terms and Definitions
2． Legal Grounds to Processing of Personal Data
3． Information We Collect
4． Purposes of Processing of Personal Data
5． Ways of Processing of Personal Data
6． How We Protect and Store Your Personal Data
7． How We Share, Transfer and Publicly Disclose Your Personal Data
8． Your Rights
9． Minor's Privacy
10．International Transfer
11. Terms and Conditions of Third-party Services
12．Cookies
13. Notification Regarding Updates
14. Contact Us
1. Terms and Definitions
Data controller: means the legal entity (alone or jointly with others) determining the purposes and means of the processing of personal data. SKIT is the data controller, if not otherwise determined by law.
Personal data: means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; You (user or visitor of the Services) are the data subject.
International transfer: means transmission of personal data to the territory of a foreign country or region, public authority of a foreign state, foreign individual or foreign legal entity.
Third Party: means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data, including but not limited: Amazon Web Serves (AWS) Inc., Google Inc.
2. Legal Grounds to Processing of Personal Data
SKIT will process your personal data only where there are legal grounds to do so. Those grounds include the following:
a. Consent: You have provided your explicit consent to the processing of your personal data.
b. Legal situations: The processing of your personal data is required or authorized by applicable laws, or relates to suspected unlawful activity, serious misconduct, legal proceedings or law enforcement.
c. Reasonable expectations:The processing of your personal data is necessary for the purposes of our legitimate interests. We believe that our processing of your personal data is within our legitimate interests and within your reasonable expectations in a number of situations, including but not limited to:
· To help us understand our customers better and provide improved, more relevant services to them;
· To ensure that our Services run smoothly;
· To help us keep our systems secure and prevent unauthorized access or cyber-attacks;
3. Information We Collect
a. Registration and account information: If you choose to register for an account, we require you to create a username (Email Address) and password. You will be asked to give us your personal data during the registration and such personal data is not anonymous to us.
b. Usage of products and services and customer service: We may collect information from you in the course of providing service to you in relation to the products and services. The information collected includes user voice recordings, photos, text and other personal data when you input your message.
c. Mobile information and device data information: We may collect additional information from you if you access our Services through a mobile device, e.g., country or region code of your device, IMEI (International Mobile Equipment Identity), IMSI (International Mobile Subscriber Identity), or other unique identifier of the device, IP address, MAC address, and other information that may relate to the mobile device you use.
d. Log information: Information related to your use of certain features, apps, and websites. For example, cookies, temporary message history and log information generated by using the products and services, including audio files and evaluated results.
e. Other Information: When you use some of the Services and such Services may require specific use of your information, we will specify such information in separate terms, agreements, or privacy policies and will collect, process, use, or transfer such information according thereto and get your consent where appropriate.
We do not generally ask you for sensitive personal data, i.e. personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal records, or trade union or professional association membership, genetic data for the purpose of uniquely identifying a natural person, and data concerning health or data concerning a natural person's sex life or sexual orientation. However, you may voluntarily provide sensitive personal data in the use of our services (e.g. by including it in the messages you input). If we need to collect or process sensitive personal data (such as facial feature, fingerprint feature, heart rate, step count, etc.) in other circumstances, we will do so with your consent or where we are otherwise required or permitted by law.
4. Purposes of Processing of Personal Data
We will process your personal data to fulfill the following purposes:
| Information | Purpose |
|---|---|
| Email Address | We may use email address as your account, maintain and update our records, and similar activities in connection with our services. We may use email address as your account to send notices to you of our software updates, updated policies or other information that we believe may be important to you. |
| Voice, text, photos | We may use your voice, text, photos to provide our services and products, including homework creation and edition, homework reviews. Users may select photos from local album and upload the photo as the head portraits. |
| Mobile information or device data | We will conduct the hardware and software analysis to further improve the user experience. |
| Log information | We will use log information to provide, process and maintain our services and products. |
We may not be able to do these things without your personal data. For example, we may not be able to communicate with you and deal with your enquiries.
5. Ways of Processing of Personal Data
We will carry out the following operations on your personal data: collection, recording, systematization, accumulation, storage, alteration (update, modification), retrieval, use, transfer (provision, access), depersonalization, blocking, and deletion (destruction) of personal data.
SKIT does not take any decisions involving the use of algorithms or profiling that significantly affect you
We are required to ensure such processing is subject to suitable safeguards, including reasonable steps to ensure personal data is accurate, complete, up-to-date and relevant, and your rights to access and correct personal data about you.
6. Retention Terms
We process your personal data for as long as is necessary to fulfill the purpose of its processing. The specific period depends on the different needs of certain service, please reference the privacy terms of specific service. We will terminate processing of your personal data if you cancel your account and withdraw your consent, unless we are entitled (or obliged) to continue processing your personal data on other legal grounds.
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems, unless the personal data is required to be stored for longer periods (e.g. for archiving purposes in the public interest, or for scientific or historical research purposes). While we will endeavor to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, such data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.
7. How We Share, Transfer and Publicly Disclose Your Personal Data
Generally, we will store your personal information in China. Personal data may be shared with:
a. SKIT Affiliated Entities. We may share the personal data we collect about you with the SKIT group companies and their and our affiliates and subsidiaries. SKIT affiliated entities may process personal data on the same bases as described in this Privacy Policy.
b. Third Parties. At times we may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help SKIT market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws and reasonable safeguards. SKIT does not sell personal information, and personal information will never be shared with third parties for their marketing purposes.
c. Legal and law enforcement. We are required to disclose your personal data by local judicial or governmental authorities, agencies or as mandated under applicable laws.
d. Change of control – New Owners. In the event of any actual or prospective merger, restructuring or bankruptcy, SKIT may also provide your personal data to related third parties without further consent from you.
8. Your Rights
Being a data subject, you have other rights with respect to your personal data in accordance with relevant laws. You can exercise your rights by sending your request to info@chinese.coach as set out in Contact Us Section of this Privacy Policy. We shall at no time however be responsible for the authenticity of the information you provide. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You have the following rights in relation to your personal data:
a. Right to object
This right enables you to object to us processing your personal data where we do so for one of the following reasons:
· because it is in our legitimate interests to do so;
· to enable us to perform a task in the public interest or exercise official authority;
· to send you direct marketing materials; or;
· for scientific, historical, research, or statistical purposes.
b. Right to withdraw consent
Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your personal data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your personal data for that purpose, in which case we will inform you of this basis.
You have the right to withdraw your consent to the processing of your personal data any time with effectiveness for the future. To do this, please send your withdrawal request to ebg_gclpsupport@iflytek.com. Your personal data will be deleted within a reasonable time period after receipt of your withdrawal. We draw your attention to the fact that we may continue processing your personal data if we are entitled (or obliged) to continue processing your personal data on other legal grounds.
c. Data subject access requests
You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. Additionally, you have the right to access the following information:
· the purposes of the processing of your personal data;
· the categories of personal data concerned;
· the recipients or categories of recipient of the personal data;
· the envisaged period for which the personal data will be stored, or the criteria used to determine that period;
· the existence of the right to request from us rectification or erasure of personal data, restriction of processing of personal data concerning you, or to object to such processing;
· the right to lodge a complaint with a supervisory authority;
· where the personal data are not collected from you, any available information as to their source;
· the existence of automated decision-making, including profiling;
· if personal data are transferred to a third country or to an international organization, the appropriate safeguards pursuant to requirements relating to the transfer.
If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
d.Right to erasure
· It is no longer necessary for us to process your personal data;
· You have withdrawn your consent to us using your personal data, and there is no other valid reason for us to continue;
· The personal data has been processed unlawfully;
· It is necessary for the personal data to be erased in order for us to comply with our obligations under law; or
· You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
e. Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
f.Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties,we will notify them about the rectification unless this is impossible or involves disproportionate effort.You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to.Where we think that it is reasonable for us not to comply with your request,we will explain our reasons for this decision.
g. Right of data portability
You have the right to transfer your personal data between service providers, provided that: 1) the personal data is processed by automated means; 2) the personal data has been provided to us by data subjects; and 3) the basis for processing is consent, or that the data are being processed to fulfil a contract or steps preparatory to a contract. In effect, this means that you are able to transfer the details we hold about you to another third party. To allow you to do so, we will provide you with your personal data in a commonly used machine-readable format so that you can transfer the personal data. Alternatively, we may directly transfer the personal data for you.
h. Right to complain
You have the right to lodge a complaint with the relevant supervisory authority.
California
The California Consumer Privacy Act provides California consumers with the right to obtain from SKIT information about the personal information about you that we collect, use, and disclose. You can exercise your rights through making a request to ebg_gclpsupport@iflytek.com.
If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from SKIT.
Nevada
You have the right to opt-out of the sale of your personal information. SKIT does not sell your personal information.
See our page on understanding and controlling your personal information for more information on exercising your rights. A request may be made directly to ebg_gclpsupport@iflytek.com.
9. Cookies
To ensure the normal operation of the website, we will store a small data file called cookie on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With cookies, websites can store data such as your preferences or the progress of your uncommitted exercises.
We will not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your preferences. For details, see AboutCookies.org . You can clear all cookies saved on your computer. Most web browsers have the function of blocking cookies. But if you do, you need to change the user settings yourself every time you visit our website.
10. Security
SKIT takes security measures to protect your information, including but not limited to administrative, technical and physical measures. However, please note that although we have implemented these measures, there is no security measure that can guarantee the absolute safety and security of your information. If you believe that your login credentials have been compromised, please contact us at once.
When you use our products, services, or applications, the personal data you share is visible to other users and in some cases search engines and the public and can be read, collected, used and retained by those other parties. You are responsible for the personal data you choose to share or submit in these instances. It is your responsibility to make sure that your personal data is accurate.
Below are some examples of data security measures we undertake:
a. Ensuring the security of the premises where the information systems used to process personal data are located. Such security shall prevent any uncontrolled access to such premises by persons having no rights to access such premises.
b. Using technical means to protect the information including but not limited to encryption and anonymization techniques.
c. Approving the list of persons who are authorized to access the information systems where the personal data are processed.
d. Identifying threats to the security of personal data while they are being processed in our information systems.
e. Assessing the effectiveness of measures taken to ensure the security of personal data.
f. Detecting instances of unauthorized access to personal data and taking appropriate measures to mitigate the effects of such unauthorized access.
g. Taking all practicable measures to restore personal data which have been modified or destroyed as a result of unauthorized access.
h. Monitoring measures taken to ensure the security of personal data and the level of protection of personal data information systems.
Please note that we hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers.
11. Minor's Privacy
The Services are not intended for minors as defined by applicable laws. We do not knowingly collect personal data via our Services from minors. We will only use or disclose minor information if (a) legally permissible; (b) the parent or other legal representative of the minor has provided consent; or (c) there are other legal grounds as per applicable data protection laws. If we accidentally collect a child's personal data without verified prior consent from the child's parents, we will attempt to delete the data as soon as possible. If you believe a minor has provided personal data to us without parental/legal guardian consent, please contact us.
12. International Transfer
As we provide products or services through resources and servers around the world, this means that, with your authorized consent, your personal information may be transferred to foreign jurisdictions in the country where you use the product or service, or received visits from these jurisdictions.
Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is adequately protected in the People's Republic of China. For example, we may ask for your consent to the transfer of personal information across borders, or to implement security measures such as data de-identification prior to cross-border data transfer.
13. Notification Regarding Updates
From time to time, we may update this Privacy Policy. In the event of any material changes to our Privacy Policy, you will be notified via e-mail or other available approaches.
14. Contact Us
If you have any questions about the way we handle your personal data which have not been answered in this Privacy Policy, you may email us at ebg_gclpsupport@iflytek.com. We will review your queries as soon as possible and respond within 20 days after verifying your identity.