Foreword
This is a privacy agreement between the user (hereinafter referred to as ‘you’) and the products and services provided by WELEARN TECHNOLOGY LTD.
Introductory
We understand the importance of your personal information and will do our best to protect your personal information safely and reliably, we are committed to maintaining your trust in us, adhere to the following principles to protect your personal information: the principle of consistency of authority and responsibility, the principle of clarity of purpose, the principle of opt-in consent, the principle of minimum sufficiency, to ensure the safety of the principle of the principle of the participation of the subject, the principle of openness and transparency, and so on. At the same time, we promise that we will take appropriate security measures to protect your personal information in accordance with the industry's mature security solutions.
This policy applies to [WeLearn Language] products or services.
In particular, this Policy does not apply to services provided to you by other third parties, nor does it apply to products or services for which a separate and independent privacy policy has been established.
Before using WeLearn Language's products or services, please be sure to read and thoroughly understand this policy and use the relevant products or services after confirming that you fully understand and agree to it. In order to ensure the safe operation of the software and services, WeLearn Language collects relevant device information and permissions when triggered by the corresponding function points.
This Privacy Policy explains how this information is collected, used, stored and shared when you use the services of WeLearn Language, and the ways in which you can access, update, control and protect this information. This Privacy Policy is relevant to your use of the [WeLearn Language] Services, and we hope that you will read it carefully and, if necessary, make choices that you deem appropriate in accordance with the guidelines in this Privacy Policy. By using or continuing to use the WeLearn Language services, you consent to the collection, use, storage and sharing of your information in accordance with this Privacy Policy.
If you have any questions about this Privacy Policy or matters related to this Privacy Policy, please contact us via the customer service telephone number.
This privacy policy will help you understand the following:
I. How we collect and use your personal information
II. How we use cookies and similar technologies
III. How we share, transfer and publicly disclose your personal information
IV. How we protect your personal information
V. How you manage your personal information
VI. How we handle minors' personal information
VII. How we store your personal information
VIII. Third Party SDK Privacy Policy
IX. How this privacy policy has been updated
X. How to contact us
I. How we collect and use your personal information
(i) Statement of Sensitive Personal Information
Personal information refers to all kinds of information recorded electronically or by other means that can identify a specific natural person individually or in combination with other information, or reflect the activities of a specific natural person, including name, date of birth, identity document number, personal biometric information, address, means of communication, communication records and content, account password, property information, credit information, whereabouts, accommodation information, health and physiological information, transaction information and so on. The information includes name, date of birth, identity document number, address, communication contact method, communication record and content, account password, property information, credit information, whereabouts, accommodation information, health information, transaction information, etc.
Sensitive personal information refers to personal information that, if leaked, illegally provided or misused, may endanger the safety of persons and property, and is highly likely to lead to damage to a person's reputation, physical and mental health, or discriminatory treatment, etc., including identity card numbers, personal biometric information, bank account numbers, communication records and contents, property information, credit information, whereabouts, accommodation information, health and physiological information, transaction information, personal information of children under the age of 14 (inclusive), etc. (We will prominently identify specific personal sensitive information in bold in this Privacy Policy. Personal information of children under the age of 14 (inclusive), etc. (We will prominently identify specific personal sensitive information in bold in this Privacy Policy).
You understand and agree:
（1）We are committed to creating a variety of products and services to meet your needs. As we provide you with a wide range of products and services, and the scope of specific products/services that different users choose to use varies, accordingly, the type and scope of personal information collected and used will vary, please refer to the specific product/service features;
（2）We may use the information we collect through certain features for our other services. For example, we may use the information we collect when you use one of our features or services for another feature or service to provide you with specific content. If we use your personal information beyond what is directly or reasonably related to the purpose for which it was collected, we will inform you again and obtain your express consent before using your personal information.
（3）In order to provide you with a better experience of our products and services, we are continually striving to improve our technology, and as a result, we may from time to time introduce new or optimised features that may require the collection or use of new personal information or change the purpose or manner of use of personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up windows, page reminders, etc., and provide you with the means to independently choose to agree to the collection and use of personal information after obtaining your express consent. In this process, if you have any questions, comments or suggestions, you can contact us through the various contact information we provide, we will answer your questions as soon as possible.
(ii) The types of personal information collected separately for the functions of the products or services we provide, as well as the rules for the collection and use of personal information (e.g., the purposes for which personal information is collected and used, and the manner in which personal information is used) are set forth below:
1、When you register for the WeLearn Language service, we will collect your nickname, avatar, mobile phone number, intended username and password for the purpose of creating a WeLearn Language account and using social features. If you agree and authorise us to authorise a third party to use your account information (avatar, nickname and other information indicated on the page) to enable you to conveniently register or log in to the third party's account, we will share the account information that you have agreed and authorised with the third party. In addition, we may obtain your registered account information (avatar, nickname and other information authorised by you) from the third party in accordance with your authorisation and bind it to your WeLearn Language account, so that you can log in and use our products and services directly through the third party account. We will use your information within the scope of your authorisation and consent. In the process of registering and using the services, if you provide the following information to complete your profile: avatar, nickname, mobile phone number, it will help us to provide you with better services and experience, and we can provide you with personalised services related to the above information. The above information provided by you will continue to be authorised to us for the duration of your use of the Service. When you voluntarily cancel your account, we will make it anonymous or delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations.
(iii) Personal information that we actively collect in the course of providing products or services to you:
Under the premise of complying with laws and regulations, in order to protect your account security as well as provide you with better services, the system may automatically collect technical information through cookies or other means, including:
1、Device or software information, such as that provided by your mobile device, web browser or other programme you use to access [WeLearn Language]'s services; device model number, device identifier (including IMEI/Android ID/IDFA/IDFV/OPEN UDID/GUID/OAID/SN ID/MEID, Ad ID, SIM phone number, IMSI, ICCID), software list, device operational status information of the device, system version MCC, MNC, IP address, MAC address information, device sensor information. The purpose of collecting this information is to help us carry out bug analysis, anti-cheating, anti-hacking and other security protection work, to ensure your normal use of our products and/or services, to improve and optimise our product experience, and to safeguard the security of your account.
2、Log information, including app crashes, system activity information, device connectivity, software usage history and IP address information. We collect the above information in order to better maintain and optimise our products and/or services for security purposes and to provide you with a better experience. If you do not want us to collect the above log information, we may not be able to provide you with normal service.
3、Location Information, means the information about your location collected by [WeLearn Language] when you turn on the device location function and use the relevant services provided by [WeLearn Language] based on location, including: When you use [WeLearn Language]'s services through a mobile device with location capabilities, [WeLearn Language] collects information about your geographic location by means of GPS or WiFi; We obtain your location in order to better provide a region-specific experience, and you can stop [WeLearn Language] from collecting your geolocation information at any time by turning off the location feature.
(iv) Information about you obtained by the App in the background during the provision of products and/or services to you:
When using the various services of [WeLearn Language], when switching [WeLearn Language] to run in the background, we collect information about you including:
1、Device information: device model, device identification code (including IMEI/Android ID/IDFA/IDFV/OPEN UDID/GUID/OAID/SN ID/MEID, advertised ID, SIM card phone number, IMSI, ICCID), software list, device running status information, system version MCC, MNC, IP address MAC address information (including mobile phone MAC address and Bluetooth MAC address), and device sensor information.
2、Log information: including App crash, device networking, IP address information. This information is used to safely maintain and optimise our products and services to better serve you.
(v) System permissions invoked by [WeLearn Language].
In order to provide you with [WeLearn Language] products and/or services, we may need to use the system privileges of your device (excluding the privileges of accessing third parties) to collect relevant personal information. You can choose whether or not to authorise us to use the relevant permissions on your device. If you do not authorise us to use the relevant permissions, some of the services may not be available to you, but it will not affect your ability to use the other functions of the [WeLearn Language] App.
1、Album and storage access, when you agree to enable this access, we will use the album reading and storage function on your device. This feature will be used to upload your avatar and QR code information, as well as to cache text, images, and video content generated by your use of WeLearn Language products and/or services. Please be aware that we do not automatically read the contents of your local photo albums, and will only access the image/video data after you have agreed to enable this permission and have actively selected the appropriate images in your albums. If you refuse this authorisation, the aforementioned features will not work properly.
2、Camera permission, when you agree to enable this permission, we will use the camera function on your device. This function will be used to take pictures and to capture and recognise the information in the pictures taken during the implementation of the above function. If you refuse this authorisation, the aforementioned functions will not be available.
3、Microphone permission, when you agree to enable this permission, we will use the microphone function on your device. This feature will be used for speech recognition to text parsing dialogue. If you refuse this authorisation, the aforementioned functions will not be available.
4、Geolocation Permission, when you agree to enable this permission, we will collect your geolocation information to match you with relevant services in your area. If you refuse such authorisation, the above features will not be available.
5、Device information access rights, when you agree to open this permission, in order to protect your account and login security, we will collect your corresponding device information, used to optimise the user experience, security checking, anomalies reported and so on.
6、Modify the system settings permissions, when you agree to open this permission, in order to better provide convenient service, when you refuse to app up the permissions, some functions need to use a certain permission, we will prompt you do not have to open the permissions, and then provide a link, when you click on this link will jump to the system settings interface, and then allow you to modify their own, if you refuse this kind of authorisation, the above functions will not be able to achieve! If you refuse this kind of authorisation, the above function will not be implemented.
(vi) Your personal information that we obtain from third parties
We may collect and use your personal information from third parties (our partners) within the scope of your consent. We ensure that your personal information is handled in accordance with the contract with the third party and relevant laws and regulations, and please read the personal information protection policy and user agreement of the third party. If you refuse the collection and use of your personal information by a third party in the provision of services, you may not be able to use some of the [WeLearn Language] and/or services.
For more information about the identity of third party partners, the type of information we obtain, the purpose of the information, etc., please refer to the Third Party SDK Privacy Policy below.
(vii) Exceptions to consent
In accordance with laws and regulations, your consent is not required for the collection and use of your personal information in the following cases:
1、Necessary for the conclusion and performance of a contract to which an individual is a party;
2、Necessary for the performance of legal duties or statutory obligations;
3、Necessary for the performance of legal duties or statutory obligations;
4、Necessary for the performance of legal duties or statutory obligations;
5、Necessary for the performance of legal duties or statutory obligations;
6、Necessary for the performance of legal duties or statutory obligations;
II. How we use cookies and similar technologies
(i) Cookie
In order to ensure that our websites work properly, to make your visit easier and to recommend content that may be of interest to you, we may store small data files on your computer or mobile device called cookies, which usually contain an identifier, the name of the site, and some numbers and characters. Cookies enable websites to store data such as your preferences. You can clear this data in your browser. If you do so, you may not be able to use the cookie-dependent services or functions provided by us.
(ii) Cookie-like technologies
In addition to cookies, we use other similar technologies on our websites. For example, the in-site notifications we send you may contain a link to an address that links to content on our site, and if you click on that link, we track the click to help us understand your product or service preferences so that we can proactively improve our customer service experience. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.
III. How we share, transfer and publicly disclose your personal information
We are aware of the legal responsibilities associated with the sharing, transferring, and public disclosure of personal information, and we will only share, transfer, and publicly disclose your personal information within the scope of this Privacy Policy:
(i) Sharing
We do not share your personal information with companies, organisations and individuals outside of the [WeLearn Language] service providers, except in the following circumstances:
1、Sharing with Explicit Consent: We may share your personal information with other parties when we have your explicit consent to do so.
2、Sharing under legal circumstances: We may share your personal information in accordance with the provisions of laws and regulations, the need to resolve litigation disputes, or at the request of administrative or judicial authorities in accordance with the law.
3、Sharing within WeLearn Language: Your personal information may be shared within WeLearn Language to facilitate the provision of services to you, to recommend information that may be of interest to you, to identify account anomalies, or to protect the personal and property safety of other users of the company or the public from harm. We will only share personal information that is necessary (e.g., we will share your account information within WeLearn Language if it is necessary for you to use your WeLearn Language account to access a product or service within WeLearn Language) and is subject to the purposes stated in this Privacy Policy, and we may share your personal information if we do so. If we share your sensitive personal information or if our affiliates change the purposes for which personal information is used and processed, we will ask for your authorisation again.
(ii) Transfers
We will not transfer your personal information to any companies, organisations or individuals except in the following circumstances:
1、Transfer with Explicit Consent: We may transfer your personal information to other parties with your explicit consent;
2、In the event of a merger, acquisition or insolvent liquidation, or other situation involving the transfer of personal information, we will require the new company or organisation holding your personal information to continue to be bound by this policy, or we will require that company, organisation and individual to seek authorised consent from you again.
(iii) Public disclosure
We will only publicly disclose your personal information in the following circumstances:
1、We may publicly disclose your personal information with your express consent or based on your active choice;
2、If we determine that you have violated laws and regulations or seriously violated the rules of WeLearn Language, or in order to protect the personal and property safety of users of WeLearn Language, its affiliates, or the public from being infringed upon, we may, in accordance with the laws and regulations or the rules of WeLearn Language, obtain your consent to disclose personal information about you, including the relevant violations and the measures that WeLearn Language has taken against you. We may disclose personal information about you with your consent in accordance with laws and regulations or the rules of WeLearn Language's relevant agreements, including relevant violations of law and the measures that WeLearn Language has taken against you.
(iv) Exceptions to prior authorised consent for the sharing, transfer and public disclosure of personal information
In the following cases, sharing, transferring or publicly disclosing your personal information does not require your prior authorised consent:
1、Related to the fulfilment of our obligations under laws and regulations;
2、Related to national security and defence security;
3、Related to public safety, public health, and vital public interests;
4、Related to the investigation, prosecution, adjudication and enforcement of sentences for offences;
5、For the purpose of safeguarding the vital legal rights and interests of you or other individuals, such as life and property, but it is difficult to obtain the consent of the person himself/herself;
6、Personal information that you disclose to the public on your own;
7、Where personal information is collected from lawful publicly disclosed information, such as lawful news reports, open government information and other channels.
In accordance with the law, if we take technical and other necessary measures to process personal information in such a way that the recipient of the data is unable to re-identify a specific individual and cannot be recovered, such processed data will be shared, transferred, and publicly disclosed without separate notification to you and without obtaining your consent.
IV. How we protect your personal information
(i) We endeavour to provide security for users' personal information to prevent unauthorised use, unauthorised access and disclosure, leakage, damage and loss of users' personal information. We will use a variety of security measures to safeguard the information within a reasonable level of security. For example, we will use encryption technology (e.g., SSL), anonymisation, and encrypted storage to protect your personal information; establish trusted protection mechanisms to prevent malicious attacks on personal information; establish access control mechanisms that adhere to the principle of least privilege to ensure that only authorised personnel have access to personal information; and carry out training courses on security and personal information protection to enhance employee awareness of the need to protect personal information. protection; conduct security and personal information protection training programmes to enhance employees' awareness of personal information protection.
(ii) We have an industry-advanced data security management system that focuses on data and revolves around the data lifecycle to enhance the security of the entire system in multiple dimensions, including management bodies, organisational construction, institutional systems and product technologies. We have established special management systems, processes and organisations to safeguard the security of personal information. For example, we strictly limit the scope of people who can access information, require them to comply with confidentiality obligations, and conduct audits. In the event of a security incident, such as the leakage of personal information, we will activate our emergency response plan to stop the security incident from expanding and inform you of it in the form of push notifications and announcements.
(iii) We will take reasonably practicable steps to endeavour to avoid the collection of irrelevant personal information.
(iv) The Internet is not an absolutely secure environment, and we strongly recommend that you do not send personal information using a method of communication that is not recommended by [WeLearn Language]. You can connect and share with each other through our services. When you create communication, transaction or sharing through our services, you can independently choose the object of communication, transaction or sharing as a third party who can see your transaction content, contact information, communication information or sharing content and other related information.
If you find that your personal information, especially your account or password, has been compromised, please contact [WeLearn Language] customer service immediately so that we can take appropriate measures according to your request.
Please help us keep your account secure by using a complex password. We will endeavour to keep any information you send us secure.
We will also report on the handling of personal information security incidents as required by the regulatory authorities.
V. How you manage your personal information
You can access and manage your personal information in the following ways:
(i) Enquire about, correct and supplement your personal information and obtain a copy of your personal information
You have the right to access your personal information, subject to the exceptions provided by law and regulation. You can access your personal information by yourself in the following ways:
Personal Information ------ If you wish to access or edit your avatar, nickname, mobile phone number, etc. in your personal information, you can do so by logging into your account through the ‘My’ screen and clicking on Avatar Nickname.
(ii) Deletion of your personal information
You may delete some of your personal information by the means set out in this section ‘(a) Accessing, correcting or supplementing your personal information and obtaining a copy of your personal information’.
In the following cases, you may make a request to us to delete your personal information:
1、If our handling of personal information violates laws and regulations;
2、If we collect and use your personal information without your explicit consent;
3、If our processing of personal data is a serious breach of our agreement with you;
4、If you no longer use our products or services, or if you voluntarily cancel your account;
5、If we permanently cease to provide products or services to you.
If we decide to respond to your request for deletion, we will also, as far as possible, at the same time notify the subjects who have obtained your personal information from us and ask them to delete it in a timely manner, unless otherwise required by law or regulation, or if these subjects have been independently authorised by you to do so.
After you or we have assisted you in removing information from our services, and in accordance with relevant laws and regulations, we may not immediately remove the corresponding information from our back-up systems, and we will securely store your personal information and isolate it from any further processing until the back-ups can be erased or anonymised.
(iii) change the scope of your authorised consent
Please be aware that in order to use the WeLearn Language products and/or services, you will need to enable the relevant permissions on your device and/or provide us with basic personal information. If you wish to disable the device rights in paragraph 1(e) above, you can do so via the settings page on your device. If you wish to withdraw your previous access to features of the WeLearn Language product and/or service, you can do so via the settings page of WeLearn Language or the settings page of your device.
When you change the scope of your consent, we will no longer collect and use your personal information, but please understand that we will no longer be able to provide you with the corresponding products and/or services. You hereby agree that any change in the scope of your consent or withdrawal of your consent will not affect the processing of your personal information based on your previous consent.
(iv) Cancellation of your account
You can submit a request to cancel your account on your [WeLearn Language] My Page (click Account Settings).
After you have voluntarily cancelled your account, we will stop providing you with products or services, delete your personal information in accordance with the requirements of the applicable laws, or anonymise it.
The cancellation of your account is irreversible. Once your account is cancelled, we will no longer collect your personal information, but please understand that we will no longer be able to provide you with the products and services that correspond to it. We therefore recommend that you choose to cancel your account carefully.
(v) Responding to your request above
For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
In the following cases, as required by law or regulation, we will not be able to respond to your request:
1、Related to national security and defence security;
2、Related to public safety, public health, and vital public interests;
3、Related to the investigation, prosecution, adjudication and enforcement of sentences for offences;
4、Where there is sufficient evidence of subjective malice or abuse of rights on the part of the subject of the personal information;
5、Responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organisations;
6、Those involving trade secrets.
VI. How we handle minors' personal information
No minors under the age of 18 are allowed to create their own user accounts and use our services.
We will only use or disclose a minor's personal information when permitted by law or regulation, with the express consent of a parent or guardian, or when necessary to protect the minor.
VII. How we store your personal information
Your personal information collected and generated in the course of our operations within the country is stored within the territory.
We do not currently transfer information collected and generated in the course of our operations across borders. In the event that we need to transfer your collected personal information to other jurisdictions, we will comply with the requirements of the relevant applicable laws, carry out a security impact assessment of the data export, implement unified security measures and seek your consent to ensure that all such transfers satisfy the requirements of the locally applicable data protection laws.
We undertake to store your personal information for the minimum time necessary to fulfil the purposes for which you have authorised it to be used, unless otherwise required by law or regulation, or where you have requested us to delete your personal information in accordance with the law.
In the event that we partially or completely cease to operate due to operational difficulties or other reasons, unless otherwise provided for by laws, regulations or normative documents or otherwise agreed by both parties, we will inform you of such circumstances and cease to collect your personal information, as well as deleting or anonymising any personal information that has already been collected.
VIII. Third Party SDK Privacy Policy
When you use the services provided by the third party, we will share the corresponding information after obtaining or ensuring that the third party obtains your authorised consent, and in other cases in compliance with laws and regulations. You can find out how the third party handles your personal information by using the information in this list.
IX. How this privacy policy has been updated
We may update or modify this policy from time to time due to business development, regulatory updates, etc. We will post the updated Privacy Policy on this page, but we will not reduce your rights under this Policy without your express consent. Such changes form part of this Policy.
In the event of a significant, material change, we will notify you in a conspicuous manner on a case-by-case basis.
Circumstances of significant, material change include, but are not limited to, the following:
1、Significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, and how personal information is used;
2、Significant changes in our ownership structure, organisational structure, etc. such as changes in ownership resulting from business restructuring, bankruptcy and mergers and acquisitions;
3、Changes in the primary recipients of personal information to be shared, transferred or publicly disclosed;
4、Significant changes in your rights to participate in the processing of personal information and how you can exercise them;
5、In the event of a change in the department responsible for handling the security of personal information, our contact details and complaint channels;
6、When the personal information protection impact assessment report indicates a high risk.
X. How to contact us
If you have any questions, reports or complaints about this Privacy Policy when using WeLearn Language's products and/or services, you can send an email (official@welearn-tech.com) to us and we will review the issue as soon as possible, and will complete the verification and processing of your request and provide a response within 15 business days of receiving your request.