Dlearning Platform Privacy Policy
Update Date: November 1, 2021
Effective Date: November 10, 2021
Your trust is very important to us. Ding Xue (Hangzhou) Technology Co., Ltd. (hereinafter referred to as “we” or “Dlearning”) is well aware of the importance of personal information to you. We will provide full protection for the security of your personal information in accordance with legal regulations and industry best practices. To this end, Dlearning has formulated this “Dlearning Platform Privacy Policy” (hereinafter referred to as “this policy/this privacy policy”) to help you fully understand how we collect, use, share, store, and protect your personal information during your use of Dlearning products/services, as well as how you can manage your personal information. Before you start using our products/services, please read and understand this policy carefully, especially the terms highlighted in bold/underlined/highlighted, to ensure you fully understand and agree before starting to use. We try to explain the professional terms involved in this policy in a simple and popular way to facilitate your understanding. If you have any questions, opinions, or suggestions about the content of this policy, you can contact us through the various contact methods provided in this policy.
This privacy policy will help you understand the following content:
I. Definitions and Scope of Application
II. How We Collect and Use Your Personal Information
III. How We Share, Transfer, and Disclose Your Personal Information
IV. How We Protect Your Personal Information
V. How You Can Manage Your Information
VI. How We Handle the Personal Information of Minors
VII. Third-Party Services
VIII. How We Store Your Personal Information
IX. How This Policy is Updated
X. How to Contact Us
I. Definitions and Scope of Application
(1) Definitions
1. Dlearning Service Provider: Refers to the legal entity that develops and provides Dlearning products and services, namely Ding Xue (Hangzhou) Technology Co., Ltd., with the registered address at 407, 4th Floor, Block A, 3rd Building, Sanwei Zhihui Center, Cangqian Street, Yuhang District, Hangzhou, Zhejiang Province, hereinafter referred to as “Dlearning” or “we”.
2. Affiliated Companies: Refers to our affiliated companies, investment companies, and group company members.
3. Dlearning Enterprise/Organization Users: Refers to users who become enterprise edition users of the Dlearning learning platform through authorization by enterprises or other organizations, and manage and use the Dlearning learning platform services on behalf of enterprises/organizations by uploading enterprise/organization employee information to build enterprise/organizational structures. Dlearning enterprise/organization users include but are not limited to legal persons, government agencies, other organizations, partnerships, or individual industrial and commercial households, etc.
4. Dlearning Enterprise/Organization Administrators: Refers to individual users of Dlearning who are authorized or designated by Dlearning enterprise/organization users and have operational permissions for the enterprise/organization user management platform system, representing enterprises/organizations to open, manage, and use Dlearning services.
5. Dlearning Individual Users: Refers to individual users who register for Dlearning accounts. The first category includes users who directly register or obtain a UserID in the Dlearning backend through the Dlearning web version, Dlearning App, Feishu, Enterprise WeChat, DingTalk, other third-party OA platforms, or Dlearning WeChat mini programs by authorizing public information through the WeChat public account system. The second category of users are organizational users generated in batches through the Dlearning student management function, who receive Dlearning user login credentials and passwords or verification codes for login and subsequent operations; the third category of Dlearning account individual users are individual users with Dlearning enterprise/organization user administrator permissions and individual users as part of the Dlearning enterprise/organization student body without Dlearning enterprise/organization administrator permissions. All three categories of users are Dlearning individual users and are referred to as “you” below.
6. Personal Information: Refers to various information recorded electronically or in other ways that can identify a specific natural person’s identity alone or in combination with other information, or reflect the activities of a specific natural person.
7. Personal Sensitive Information: Refers to personal information that, if disclosed, illegally provided, or abused, may endanger personal and property safety, and is highly likely to cause damage to personal reputation, physical and mental health, or discriminatory treatment, etc. The personal sensitive information in Dlearning services includes ID card numbers, mobile phone numbers, email addresses, personal biometric information, bank account information (including but not limited to WeChat Pay, Alipay payment-related information), transaction information, and personal information of children under 14 years old (inclusive).
8. Personal Information Deletion: Refers to the act of removing personal information in the systems involved in daily business functions, making it unsearchable and inaccessible.
9. Personal Information Principal: Refers to the natural person identified by personal information.
10. Anonymization: Refers to the process of technically processing personal information so that the personal information principal cannot be identified or associated, and the processed information cannot be restored. Information obtained after anonymization processing is not considered personal information.
11. De-identification: Refers to the process of technically processing personal information so that it cannot be identified or associated with the personal information principal without additional information.
12. Personal Information Controller: Refers to the organization or individual who has the right to decide the purpose and method of personal information processing. In some cases of Dlearning service, the personal information controller is the Dlearning enterprise/organization user.
13. People’s Republic of China: Refers to the mainland area of the People’s Republic of China, and for the purposes of this privacy policy, does not include the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and Taiwan.
14. SDK: Also known as Software Development Kit, it is a collection of development tools for specific software packages, software frameworks, hardware platforms, operating systems, etc., when building application software.
(2) Scope of Application
This policy applies to all products and services provided by the Dlearning platform. If our affiliated companies’ products or services use the products or services provided by Dlearning and do not have an independent privacy policy, this policy also applies to that part of the products or services.
It is important to note that this policy does not apply to services provided to you by other third parties, nor does it apply to products or services within Dlearning that have separate privacy policies. For example, when third-party service providers rely on Dlearning to provide services to you, the personal information you provide to the third-party service providers does not apply to this policy. You need to read and refer to these third parties’ privacy policies on your own and independently judge whether to use their services.
In addition, if you voluntarily or at the request of the live broadcast party decide to provide personal information when listening to or purchasing courses on the Dlearning platform, all risks, consequences, and responsibilities shall be borne by you and the live broadcast party.
II. How We Collect and Use Your Personal Information
(1) How We Collect Your Personal Information
In order to provide you and Dlearning enterprise/organization users with Dlearning-related services, maintain the normal operation of Dlearning-related services, improve and optimize our service experience, and ensure the security of your account, we will collect information that you actively provide, authorize to provide, or provide based on the requirements of your enterprise/organization users when you register and use Dlearning services, as well as information generated when you use Dlearning services:
1. Providing User Registration and Profile Maintenance Services
1) When you create an account on the Dlearning platform to provide us with services, you need to provide a mobile phone number or email address; and set a password within the Dlearning platform. When you log in with a third-party platform account (including but not limited to WeChat account, DingTalk account, Feishu, Enterprise WeChat), if you decide to bind the Dlearning platform account, after your account binding authorization, the third-party platform will synchronize some information to us, such as name, gender, avatar, nickname, or ID, etc.
2) When you use the Dlearning platform, to maintain your basic information and improve your service experience, you need to choose to fill in and/or complete the necessary information for the service, including your email, gender, location, avatar, nickname, birthday, personal profile. If you do not provide this information, it will not affect your use of other functions of the Dlearning platform.
3) If you only need to participate in one-time interactive sessions designed by a third party, such as on-site voting, brain-teasing games, etc., which do not require logging in to use, you do not need to register as a Dlearning user and provide the above information.
4) If you only need to participate in courses designed by a third party that can be browsed without registration, if you only browse the course or interactive session content without speaking, liking, or other interactions, you do not need to register as a Dlearning user and provide the above information.
5) If you only need to browse, search for introductions to Dlearning products, features, and services displayed on the Dlearning official website, you do not need to register as a Dlearning user and provide the above information.
2. Providing Online Learning Services
The Dlearning platform is an online learning APP. In order to help you access courses and other learning resources on the Dlearning platform, we need to use your network (Wi-Fi or mobile cellular network).
3. Providing Learning Community Services
The Dlearning platform provides learning tools such as Q&A and notes. When using the Q&A and notes functions on the Dlearning platform, the images, comments, interactions, and other information you upload will be stored on the Dlearning platform’s server, as storage is necessary to achieve this function. You can delete the videos you upload at any time. Unless you choose to do so or in accordance with relevant laws and regulations, we will not provide the above information externally or use it for purposes other than the function. Please note that the content and information you share when using our services may involve your personal sensitive information. If it includes personal information of others, please ensure that you have obtained legal authorization from others. Please consider more cautiously whether to disclose or publicly share related personal sensitive information when using our services.
4. Providing Basic User Learning Experience
To ensure your basic user experience when using the Dlearning platform, when you choose to use the Dlearning platform for learning, you need to provide or allow us to collect the following device permissions and information:
1) Obtain the WLAN connection status of your device, so that the Dlearning platform can remind you in time when playing video courses or live broadcasts require a lot of data traffic;
2) Determine the application running status to determine whether the Dlearning platform is running in the foreground, so as to provide you with appropriate notifications according to your usage scenario;
3) Change the volume to conveniently change the volume when you watch or listen to audio and video courses;
4) Control vibration, when you do not open the APP, receive IM chat messages or class notifications, etc., through vibration reminders;
5) Notification center, to quickly get reminders when you have class notifications;
6) Local database writing and reading, when you watch video courses, you can cache video files to your mobile phone for offline viewing and learning.
7) Login and share learning content, we use the third-party SDK “ShareSDK”, ShareSDK needs to monitor whether you have installed the corresponding APP to call WeChat, DingTalk for sharing. WeChat: Collects image data for sharing to Moments or WeChat Favorites, but will not be used for associating and tracking users; DingTalk see: DingTalk Privacy Policy.
8) Application new version installation reminder, to enhance your learning experience, the Dlearning platform will continue to upgrade online, we will remind you to download and install the latest version of the APP within the application.
9) Cancel push messages, to avoid frequent message push, we log in to the APP through “My-Settings and Feedback-New Message Notification” to set whether to push.
10) Geographic location information, to display your geographical location when learning, to facilitate enterprises to analyze learning behavior, we need to use your geographical location.
5. Data Submitted by Your Enterprise
If you, as a Dlearning enterprise/organization administrator, choose to open, manage, and use Dlearning services, we will collect the information and data (hereinafter referred to as “enterprise-controlled data”) submitted or generated during the use of Dlearning-related functions/applications by your enterprise/organization users. Enterprise-controlled data may include:
1) Information such as your position, department affiliation, office email account, office phone number assigned to you by your enterprise organization, as well as personal information and check-in information, course approval records, course release log information, learning task information, course file information, and facial recognition bottom maps, geographical location, and other personal sensitive information required or generated for you to complete enterprise organization daily operation and management tasks.
2) Order transaction information when you use Dlearning services or purchase third-party course services, to display and facilitate your management of orders. Such as transaction information when you, as an administrator, purchase Dlearning self-operated course services or third-party courses on the Dlearning learning platform.
3) Other data containing your personal information submitted by enterprise organization users, such as Dlearning learning platform enterprise contact information (including enterprise organization user position information, contact information, personal identity information, etc.).
You understand and agree that the enterprise/organization user is the controller of the above enterprise-controlled data, and Dlearning company only processes your personal information/data based on the enterprise/organization user administrator’s choice to open, manage, and use the above application services. Before enterprise organization users upload Dlearning enterprise organization contact information and other requirements for the enterprise organization’s Dlearning individual users to submit personnel information, external business contact information, etc., personal information, they should ensure that they have obtained the explicit consent of Dlearning individual users in advance, and only collect the final user information necessary to achieve enterprise operation and management purposes, and have fully informed the final users of the purposes, scope, and methods of data collection.
6. Other Additional Services
To provide you with more convenient and high-quality products and services, and strive to improve your experience, we may collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your use of Dlearning platform’s browsing, searching, purchasing, and other basic services, but you may not be able to obtain the user experience brought to you by these additional services. These additional services include:
1) Additional services based on camera/camera: You can use this feature to scan codes for learning data submission, take photos or videos for communication with other users after enabling camera/camera permissions.
2) Additional services for picture/video access and upload based on album (image library/video library): You can use this feature to upload your photos/pictures/videos to achieve changing avatars, uploading community pictures, etc. after enabling album permissions.
3) Additional services related to voice technology based on microphone: You can use the microphone to achieve learning training drills after enabling microphone permissions. Please be aware that even if you have agreed to enable microphone permissions, we will only obtain voice information through the microphone when you actively click the microphone icon in the client or record videos.
Please understand and agree that the above additional services may require you to enable access permissions for your camera (camera), album (image library), and microphone (voice) in your device to achieve the collection and use of information involved in these permissions. You can view the status of the above permissions one by one in your device settings and can decide to enable or disable these permissions at any time. Please note that enabling any permission means you authorize us to collect and use related personal information to provide you with corresponding services, and once you close any permission, it means you have canceled the authorization, and we will no longer continue to collect and use related personal information based on the corresponding permission, and we will also be unable to provide you with the services corresponding to that permission. However, your decision to close permissions will not affect the information collection and use carried out based on your authorization before.
7. Other
1) If the information you provide contains personal information of other users, before providing this personal information to the Dlearning platform, you need to ensure that you have obtained legal authorization. If it involves children’s personal information, you need to obtain the consent of the corresponding child’s guardian before publishing, and in the above circumstances, the guardian has the right to contact us through the ways mentioned in Article 10 of this policy, requesting correction or deletion of content involving children’s personal information.
2) If we use the information for other purposes not stated in this policy, or use the information collected for a specific purpose for other purposes, or if we actively obtain your personal information from a third party, we will obtain your consent in advance.
If we indirectly obtain your information from a third party, we will clearly require the third party in writing to collect personal information after legally obtaining your consent, and inform you of the shared information content, and for sensitive information, it needs to be explicitly confirmed by you before it is provided to us for use. We require the third party to make a commitment to the legality and compliance of the source of personal information, and if the third party violates the behavior, we will clearly require the other party to bear the corresponding legal responsibility; at the same time, our professional security team will strengthen the security of personal information (including sensitive information encryption storage, access permission control, etc.). We will use protection means and measures that are not lower than our own user personal information to protect the indirectly obtained personal information.
3) Exception to obtaining authorization consent You fully understand and agree that we do not need your authorization consent when collecting and using your personal information in the following cases, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, and information requests: (1) related to national security, national defense security; (2) related to public safety, public health, significant public interest; (3) related to crime investigation, prosecution, trial, and execution of judgments, etc., judicial or administrative law enforcement; (4) to protect your or other individuals’ life, property, and other significant legal interests but it is difficult to obtain consent; (5) your personal information that you have publicly disclosed to the public; (6) collecting personal information from legally disclosed information, such as legal news reports, government information disclosure, etc.; (7) necessary for fulfilling the relevant agreements or other written documents signed with you; (8) necessary to maintain the safe and stable operation of the products and/or services provided, such as discovering and handling product and/or service failures; (9) necessary for legal news reporting; (10) academic research institutions conduct statistics or academic research based on public interest, and when providing academic research or descriptions, the personal information included in the results is de-identified; (11) other situations stipulated by laws and regulations. Please be aware that according to applicable laws, if we take technical measures and other necessary measures to process personal information, making it impossible for the data recipient to re-identify a specific individual and unable to restore, or we may conduct research, statistical analysis, and prediction on the collected information for de-identification, to improve the content and layout of the Dlearning platform, provide product or service support for commercial decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training), then the use of such processed data does not need to notify you separately and obtain your consent.
4) You understand and agree that the functions and services we provide are constantly being iterated and upgraded. If we do not explicitly state the personal information you need to collect in the above scenarios, we will promptly disclose the content, scope, and purpose of information collection to you through page prompts, interactive designs, and other methods and obtain your consent.
5) If we cease to operate the Dlearning platform products or services, we will promptly stop collecting your personal information, notify you of the cessation of operations in the form of email and/or station letter and/or push notification, and delete or anonymize the personal information we hold related to the discontinued business. For children’s personal information, we will also promptly notify the child’s guardian of the cessation of operations.
(2) How We Use Information
1. Collecting your personal information is to provide you with services and improve service quality. To achieve this purpose, we will use your information for the following purposes:
1) To provide you with the Dlearning products or services you use and maintain, improve, and optimize these services and service experiences, including using your personal information in an anonymized manner for model training.
2) To prevent, detect, investigate fraud, infringement, endangering safety, illegal or violation of agreements, policies, or rules with us or our affiliated companies, and to protect your, other users, or the public and our or our affiliated companies’ legal rights and interests, we will use or integrate your personal information, service usage information, device information, log information, and information obtained from our affiliated companies with your authorization or shared according to the law, to comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures according to the law.
3) Other purposes permitted by you.
2. Please note that all personal information you provide or authorize us to collect when using our products and/or services will continue to be authorized for our use unless you delete it or refuse our collection through account settings or system settings. When you cancel your account, we will stop using and delete your personal information, except as otherwise provided by laws and regulations.
3. When we display your personal information, we will use content replacement, anonymization, and other methods to desensitize your information to protect your information security.
III. How We Share, Transfer, and Disclose Your Personal Information
(1) Sharing
1. Sharing Principles:
1) Authorization Consent Principle: Sharing your personal information with our affiliates and third parties requires your authorization and consent, unless the shared personal information is de-identified and the third party cannot re-identify the natural person subject of such information. If the affiliates and third parties use the information beyond the original authorized consent scope, they need to obtain your consent again.
2) Legality, Legitimacy, and Minimum Necessity Principle: The data shared with affiliates and third parties must have a legal and legitimate purpose, and the shared data must be limited to the extent necessary to achieve the purpose.
3) Safety and Prudence Principle: We will prudently evaluate the purpose of the affiliates and third parties using and sharing information, comprehensively assess their security capabilities, and require them to follow cooperation legal agreements. We will strictly monitor the software tool development kits (SDKs) and application programming interfaces (APIs) to protect data security.
2. We will not share your personal information with any company, organization, or individual outside of Dlearning and its affiliates, except in the following cases:
1) Shared with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
2) We may share your personal information in accordance with legal regulations or mandatory requirements of government authorities.
3) Only by disclosing your information can we provide you with the third-party products and services you request, such as:
① If you, as a Dlearning enterprise/organization user administrator, choose to open, manage, and use third-party course services through the Dlearning learning platform, you agree that Dlearning will provide your enterprise/organization user’s basic personal information (such as UserID, user name) and basic permissions to the third-party application service provider, otherwise, you will not be able to use the third-party course services. When you enjoy the course services provided by the third party, you need to read and fully understand and comply with the third-party service’s product features and privacy protection policy.
② For voice recognition services, Dlearning provides voice recognition services in video assignments. You agree that the voice recognition service provider, ZhongAn Information Technology Service Co., Ltd. (hereinafter referred to as “ZhongAn Technology”), will only obtain your voice content for the purpose of voice-to-text recognition and display, otherwise, you will not be able to use the voice-to-text function provided by the third party. ZhongAn Technology will not store your personal information during the provision of voice-to-text services. When using video assignment and other related services, in addition to complying with this policy, you need to read and comply with the relevant agreements and rules of ZhongAn Technology.
Person-related services. If you choose to enable and use real-person authentication-related functions (“person-related services”), these services will be provided by Alibaba Cloud. To facilitate your use of Alibaba Cloud’s person-related services in different scenarios and applications and to improve the accuracy and security of facial recognition, Alibaba Cloud will save your facial information and comply with Alibaba Cloud’s privacy policy and this policy. To improve the accuracy of real-person authentication, you agree that Alibaba Cloud will only use your provided facial information for the person-related services stated in this policy and when necessary, compare and verify your facial information with the facial information saved by institutions or government agencies authorized by laws and regulations, otherwise, you will not be able to use the related person services. The App will store facial data during your account usage period for facial recognition verification when using learning tasks or exam functions. The facial recognition technology is provided by Alibaba Cloud, and the facial data is stored in Alibaba Cloud’s private storage space.
4) When you are complained by others for infringing on intellectual property rights or other legitimate rights and interests, and it is necessary to disclose your necessary information to the complainant for complaint handling;
5) Shared with affiliated companies: To facilitate us to provide services to you based on affiliated accounts, your personal information may be shared with our affiliated companies. We will only share necessary personal information (for example, to facilitate your use of Dlearning account to use our affiliated company products or services, we will share your necessary account information with affiliated companies), and if we share your personal sensitive information or if the affiliated company changes the use and processing purposes of personal information, we will ask for your authorization consent again.
6) Shared with authorized partners: Only to achieve the purposes stated in this privacy policy, some of our services will be provided by us and authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. For example, when you purchase courses or services on the Dlearning learning platform, you need to arrange for you to choose partners to provide services. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share the personal information necessary to provide services. Except for obtaining your explicit consent separately, our partners are not allowed to use the shared personal information for other purposes unrelated to the products or services.
At present, our authorized partners include the following types: a. Vendors, service providers, and other partners. We send information to vendors, service providers, and other partners who support our business globally. This support includes providing technical infrastructure services, analyzing how our services are used, the effectiveness of the services, and providing customer service. For the companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements, requiring them to handle personal information according to our instructions, this privacy policy, and any other relevant confidentiality and security measures.
Dlearning services contain links to other websites. Except as otherwise provided by law, Dlearning is not legally responsible for the privacy protection measures of other websites. We may add business partners when needed, but what we provide to them will only be comprehensive information, and we will not disclose your personal information.
(2) Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following cases:
1. Transferred with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
2. To meet the requirements of laws and legal procedures or mandatory government requirements or judicial rulings;
3. In the event of a merger, division, acquisition, or bankruptcy liquidation involving Dlearning or Dlearning’s affiliated companies, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, otherwise, we will require the said company or organization to seek your authorization consent again.
(3) Public Disclosure
We will only publicly disclose your personal information in the following cases:
1. After obtaining your explicit consent;
2. Disclosure based on law: In the case of laws, legal procedures, litigation, or mandatory requirements of government authorities, we may publicly disclose your personal information.
IV. How We Protect Your Personal Information
(1) We have used industry-standard security protection measures to protect the personal information you provide, to prevent data from being accessed, publicly disclosed, used, modified, damaged, or lost without authorization. For example, the data exchanged between your browser and the “service” (such as credit card information) is protected by SSL encryption; we also provide a secure browsing method for the Dlearning platform through HTTPS; we use encryption technology to ensure the confidentiality of data; we use trusted protection mechanisms to prevent data from being maliciously attacked.
(2) We will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to strengthen Dlearning employees’ understanding of the importance of protecting personal information.
(3) Dlearning has an industry-advanced data-centric data security management system that enhances the security of the entire system from multiple dimensions such as organizational construction, system design, personnel management, and product technology. Currently, our important information systems have passed the ISO27001:2013 information security management system standard certification and the third-level evaluation certification of the information system security protection.
(4) The internet is not an absolutely safe environment, and emails, instant messaging, and other communication methods with other Dlearning platform users are not encrypted. We strongly recommend that you do not send personal information through these methods. Please use a complex password to help us ensure the security of your account.
(5) We will regularly update and disclose the contents of security risk and personal information security impact assessment reports. You can obtain relevant information through our official website.
(6) The internet environment is not one hundred percent safe, and we will try our best to ensure or guarantee the security of any information you send to us. In the unfortunate event of a personal information security incident, we will promptly notify you of: the basic situation and possible impact of the security incident, the measures we have taken or will take, your suggestions for self-protection and risk reduction, and your remedies, etc. We will promptly notify you of the relevant situation of the incident by email, letter, phone call, push notification, and other methods. At the same time, we will also actively report the handling situation of personal information security incidents to the regulatory authorities as required.
V. How You Can Manage Your Information
In accordance with relevant laws, regulations, standards of China, and common practices of other countries and regions, we guarantee your rights to exercise the following rights over your personal information:
(1) Access to Your Personal Information
You have the right to access your personal information, except for exceptions stipulated by laws and regulations. If you want to exercise your data access right, you can access it in the following ways: Account information – If you want to access or edit your personal information and payment information in your account, change your password, add security information, or close your account, you can visit to perform such operations. Search information – You can access or clear your user information in “My – Personal Information” and manage other data.
(2) Correcting Your Personal Information
When you find that the personal information we process about you is incorrect, you have the right to request us to make corrections. You can submit a correction application through the methods listed in “Access to Your Personal Information” above.
(3) Deleting Your Personal Information
You can request us to delete your personal information in the following circumstances:
1. If our processing of personal information violates laws and regulations;
2. If we collect and use your personal information without obtaining your consent;
3. If our processing of personal information violates the agreement with you.
4. If we permanently no longer provide you with products or services.
After you delete information from our services, we may not immediately delete the corresponding information from our backup systems, but we will delete this information when the backup is updated.
(4) Changing the Scope of Your Authorized Consent
Each business function requires some basic personal information to be completed. For the collection and use of additional personal information, you can give or withdraw your authorized consent at any time. The client has the function of revoking agreed authorization. Users can close related privacy authorizations in Settings –> Permissions, specifically: Android phone –> Settings –> Apps –> Permissions; iOS phone –> Settings –> Privacy –> Permissions –> Apps; when you withdraw consent, we will not be able to continue to provide the services corresponding to the withdrawal of consent or authorization, and we will also stop processing the corresponding personal information. However, your decision to withdraw consent will not affect the personal information processing carried out based on your authorization before.
(5) Account Cancellation
You can cancel your previously registered account at any time. You can operate in the following ways: contact the system administrator of your learning platform and request account cancellation. After canceling the account, we will stop providing you with products or services and delete your personal information or anonymize it according to your request, except as otherwise provided by laws and regulations.
(6) Responding to Your Above Requests
To ensure security, you may need to provide a written request or otherwise prove your identity. We may first require you to verify your identity before processing your request. For multiple repeated requests beyond a reasonable limit, we will charge a certain cost fee. For those requests that are repeatedly made without reason, require a lot of technical means (for example, need to develop a new system or fundamentally change current practices), pose a risk to the legitimate rights and interests of others, or are very impractical (for example, involve information stored on backup tapes), we may refuse. In the following circumstances, as required by laws and regulations, we will not be able to respond to your requests:
1. Related to Dlearning’s fulfillment of legal obligations;
2. Directly related to national security, national defense security;
3. Directly related to public safety, public health, significant public interest;
4. Directly related to crime investigation, prosecution, trial, and execution of judgments;
5. There is sufficient evidence that you have subjective malice or abuse of rights (for example, your request will endanger public safety and the legitimate rights and interests of others, or your request exceeds the scope that general technical means and commercial costs can cover);
6. To protect your or other individuals’ life, property, and other significant legal interests but it is difficult to obtain consent;
7. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
8. Involving trade secrets.
VI. How We Handle the Personal Information of Minors
We attach great importance to the protection of minors’ personal information. According to the provisions of relevant laws and regulations, if you are a minor under the age of 18, you should obtain the written consent of your parents or legal guardians before using our services. If you are a guardian of a minor, if you have any questions about the personal information of the minor you are guardians of, please contact us through the contact information published by Dlearning.
VII. Third-Party Services
The Dlearning platform may link to third-party social media or other services (including websites or other service forms). Including:
(1) You can use the “Share” button to share certain content on other third-party social media, or you can use third-party services to log in to the Dlearning platform. These functions may collect your information (including your log information) to properly operate the above functions;
(2) Other situations where third-party services are accessed. When you communicate or purchase goods and services through the Dlearning platform with third parties, you inevitably have to disclose your own information to the transaction party or potential transaction party, such as contact methods or postal addresses. Please protect your information properly and only provide it to third parties when necessary. Your use of third-party services (including any information you provide to third parties) is subject to the third party’s own service terms (not this privacy policy), and you need to read their terms carefully. This privacy policy only applies to any information we collect and does not apply to any services provided by third parties or third-party information usage rules, and we do not assume any responsibility for any third party’s use of information you provide.
(3) Self-start and associated start instructions 1. To ensure that this application can receive client push information normally when it is closed or running in the background, this application must use (self-start) capabilities, and there will be a certain frequency of sending broadcasts through the system to wake up this application for self-start or associated start behavior, which is necessary to achieve functions and services. 2. When you open content-type push notifications, after obtaining your explicit consent, you will jump to open the relevant content. Without your consent, it will not self-start or associated start. 3. When you open files downloaded within this App, it will associated start a third-party App.
(4) Third-party push services
1. Alibaba Cloud push SDK (AliCloudAndroidPush)
1.1 Collection of personal information purpose/purpose: push messages
1.2 Collection of personal information type/scope: obtain device identifiers (IMEI, ICCID, IMSI, Android ID, GAID), application information (application package name, version number, running status), network information (such as BSSID (Wi-Fi MAC address), IP or domain connection results, current network type, MAC address), the name of the mobile network operator, application installation list, device hardware serial number, storage card (attempt to read/write SDCard data) (public storage area)
1.3 Third-party privacy policy link: [Link](https://terms.aliyun.com/legal-agreement /terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202112071754_83380.html)
2. OPPO push SDK (GpushOPPOSDK, com.heytap.msp)
2.1 Collection of personal information purpose/purpose: push messages
2.2 Collection of personal information type/scope: network permissions, view network status, read phone status and identity, SD card read/write permissions (attempt to read SDCard data (public storage area), attempt to write SDCard card data (public storage area)), detect Wi-Fi status, phone vibration permissions, collect including IMEI/OAID (for Android Q and above systems), IMEI MD5/MEI MD5, Android ID, VAID, AAID, device model, application installation list
2.3 Third-party privacy policy link: [Link](https://security.oppo.com/cn/privacy.html)
VIII. How We Store Your Personal Information
(1) Storage Location
We will store the personal information collected and generated during the operation of Dlearning services within the territory of the People’s Republic of China. For personal information generated during the use of Dlearning products and services by users outside the People’s Republic of China, it will be stored on servers in China; otherwise, you will not be able to use the existing Dlearning products and services. Under the following circumstances, we will provide your personal information to overseas entities after fulfilling the obligations stipulated by law:
1) Applicable laws have explicit provisions;
2) Obtain your explicit authorization; or
3) You actively engage in cross-border transactions through the internet and other personal actions.
For the above circumstances, we will ensure the protection of your personal information to a degree not lower than this policy through contracts and other forms.
(2) Storage Period
We will take reasonable and feasible measures to store your personal information and strive to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy and the period required by applicable laws and regulations. For example, Dlearning will retain transaction product and service information, transaction information for paid applications and in-app paid services in the Dlearning app market for not less than three years from the date of transaction completion according to the requirements of the E-Commerce Law of the People’s Republic of China. Dlearning will retain relevant network logs for not less than six months according to the requirements of the Cybersecurity Law of the People’s Republic of China. The criteria for us to judge the above period include:
1) To complete the service purposes related to you, maintain corresponding service and business records, and respond to your possible inquiries or complaints;
2) To ensure the safety and quality of the services we provide you;
3) Whether you agree to a longer retention period;
4) Whether there are other special agreements on the retention period.
After your personal information exceeds the retention period, we will delete your personal information or anonymize it according to the requirements of applicable laws.
IX. How This Policy is Updated
(1) Our privacy policy may be revised from time to time. If such changes will substantially reduce your rights under this policy, we will notify you before the changes take effect through email and/or station letter and/or push notification.
(2) We will post any changes to this policy on this page. For significant changes, we will also provide more prominent notifications (including for some services, we will send notifications through email and/or station letter and/or push notifications, explaining the specific changes to the personal information protection policy).
(3) The significant changes referred to in this policy include but are not limited to:
1. Our service model has undergone significant changes. Such as the purpose of processing personal information, the types of personal information processed, and the ways in which personal information is used;
2. We have undergone significant changes in our ownership structure and organizational structure. Such as changes in owners caused by business adjustments, mergers and acquisitions, etc.;
3. The main objects of personal information sharing, transfer, or public disclosure have changed;
4. Your rights and ways of participating in personal information processing have undergone significant changes;
5. The department responsible for processing personal information, contact methods, and complaint channels have changed;
6. The personal information security impact assessment report indicates a high risk.
X. How to Contact Us
When you have other complaints, suggestions, or issues related to minors’ personal information, you can contact us by calling our customer service phone “0532-88983839” or mailing to the following address: 407, 4th Floor, Block A, 3rd Building, Sanwei Zhihui Center, Cangqian Street, Yuhang District, Hangzhou, Zhejiang Province. We will review the issues involved as soon as possible. To ensure that we handle your problem efficiently and feedback to you in a timely manner, you need to submit identity proof, valid contact information, and written requests and related evidence. We will process your request after verifying your identity. Generally, we will reply within 15 working days. The effectiveness, performance, interpretation, and dispute resolution of this policy, and all disputes, claims, or other matters related to your use of the Dlearning platform or services, are governed by the laws of the People’s Republic of China. All disputes between you and Dlearning or the Dlearning platform should be settled amicably. If the negotiation fails, the people’s court under the jurisdiction of the place where Dlearning is registered may submit a lawsuit.
Please confirm again that you have read and fully understood the above terms.