| 1. | Data Controller Shanghai Huangdou Network Technology Co., Ltd., a company incorporated under the laws of the People’s Republic of China (the “PRC”), is the controller who collects and processes your personal information for the purposes of this Policy. |
| 2. | Personal Information We Collect and Use The following chart lists the types of personal information we collect and use to provide our services: |
| No. | Types of Personal Information | How We Collect and Use Personal Information |
|---|---|---|
| (1) | Account information: phone number and password are required to create and manage your account. Profile photo, nickname, gender, birthday, occupation, educational background and other information are optional. If you choose to log in with a third-party platform account, we will collect basic information of that account. | The information will enable you to create, log in and manage your account. Except for phone number and password, it is up to you to decide whether or not to provide additional information to enjoy more services. |
| (2) | Device and connectivity information: device type and model, device identifier (such as the IMEI number for phones), browser type and settings, language settings, sensors, operating system and application version, IP address, and information about network connection in your device. | We collect your device and connectivity information to ensure the safe operation of our services and protect your account. |
| (3) | Log information: time and frequency of your use, and device status. | We will collect the log information when you use our services, which is necessary for us to maintain and improve our services. |
| (4) | Your interaction and communications with us: such as your requests, feedback and survey responses. | When you contact us for inquiries and customer services, we will need relevant information to help us address your questions. We may also keep a record of our communications (e.g. message and voice recording). |
| (5) | Usage information: information about how you use our services, such as notes you post, learning history and your reading preferences. | We collect your usage information to provide and improve our services. If you want to use the learning history or learning rankings feature or to generate and display your annual learning report, we will collect details about your reading and learning data. |
| (6) | Purchase information: account name, phone number, delivery address and transaction record. | When you purchase items and services from our online shop, we will collect the required information to complete the transaction and deliver our products and services. |
| (7) | Information for enterprise edition: name and location of enterprise, information of the contact person, and usage data of the authorized users within the enterprise. | We collect such information to deliver our services to enterprise users. |
In addition to the above, we may collect and use your personal information if there is a legal basis to do so, which includes:
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| 3. | Third-party Products and Services Our services may include links to third-party products and services, and clicking on those links may allow you to visit their products and services. How those third parties collect and use your personal information will be governed by their respective privacy policies. | ||||||||||||||||
| 4. | How We Share Your Personal Information We will not share your personal information with any third party unless we have obtained your consent, except for the following circumstances:
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| 5. | International Transfer of Personal Information We maintain our servers in the PRC and our people are located in the PRC to provide our services to users around the world. Collecting and processing your personal information may constitute international transfer of personal information under the laws of the country where you live. Personal information protection laws vary among countries and we apply the same level of protection as described in this Policy. We will comply with the legal requirements relating to international transfer of personal information under the applicable law. | ||||||||||||||||
| 6. | Personal Information Retention We will only retain your personal information for as long as reasonably necessary to fulfil the purposes set out in this Policy. We will either delete or anonymize your personal information when it is no longer required to satisfy the purposes set out in this Policy. If you cancel your account, all personal information in your account will be deleted and we will not keep a backup of the personal information. | ||||||||||||||||
| 7. | Your Rights | ||||||||||||||||
| 7.1 | You may have certain rights (if applicable in your jurisdiction) in relation to processing of your personal information, which may include:
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| 7.2 | Please contact us at kefu@dushu365.com if you wish to exercise any of the applicable rights set out above. | ||||||||||||||||
| 7.3 | Unless otherwise provided by applicable laws, we will generally reply to you as soon as reasonably practicable. If it may take longer to respond to complicated requests, we will inform you. | ||||||||||||||||
| 7.4 | Please note that the above rights may only apply in limited circumstances under applicable law and if we decide not to respond to your request for excising the above rights, we will explain reasons. | ||||||||||||||||
| 8. | Children’s Personal Information If you are under 18, please obtain the consent of your parent or legal guardian before you use our services and provide your personal information to us. If parents or legal guardians suspect that their children have provided us with personal information without their consent, they can request such personal information be removed by contacting us at kefu@dushu365.com. | ||||||||||||||||
| 9. | Personal Information Security | ||||||||||||||||
| 9.1 | We will implement technical and organizational measures to ensure a level of security appropriate to the risk and will ensure that your personal information is adequately protected against unlawful or unauthorized access and disclosure. | ||||||||||||||||
| 9.2 | If a personal information incident occurs, we will take immediate actions to mitigate adverse effects. If we are required to notify you and any supervisory authority of such incident, we will notify the relevant parties accordingly. | ||||||||||||||||
| 10. | Changes to this Policy We may amend this Policy from time to time as required by applicable law and as necessary to provide our services. We will provide the updated Policy on our App in a timely manner. | ||||||||||||||||
| 11. | How to Contact Us We have established a Personal Information Protection Department. If you have any questions about this Policy, including any requests to exercise your rights in relation to your personal information, please contact us as described below.
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