Children's Privacy Policy
EnglishTube (hereinafter collectively referred to as "we") is well aware of the importance of children's personal information and privacy security, and thanks you for your trust in us. We will take appropriate security protection measures in accordance with the requirements of laws and regulations and try our best to protect the safety and security of children's personal information. control. Based on this, our product and service provider Shenzhen Time Value Information Technology Co., Ltd. and its affiliates have formulated this policy.
This policy mainly explains to you what children's personal information we collect, the purposes of collecting children's information, the protection measures for children's information, etc., and declares our commitment to protecting children's personal privacy. For matters not covered in this policy, the Privacy Policy shall prevail.
We may update or modify this policy in the future based on changes in information processing situations. Please be aware of this policy and any supplementary policies before using any products/services we provide. Unless otherwise agreed, the terms and abbreviations used in this policy are consistent with"User Agreement","Privacy Policy"The terms and abbreviations in have the same meaning.
Special instructions from the child guardian (hereinafter referred to as "you"):
If you are the guardian of a child user, please read carefully and choose whether to agree to this policy. We hope that you will work with us to protect children's personal information, educate and guide children to enhance their awareness and ability to protect personal information, and guide, remind and require them not to provide any information to any online product and service providers without your consent. personal information. If you do not agree with the contents of this policy, which will cause our products and services to fail to operate properly or achieve the intended service effects, you should ask your children to immediately stop accessing/using our products/services. When you click to agree to this policy online, or your child uses or continues to use our services and submits personal information, you agree that we collect, use, store and protect your child's personal information in accordance with this policy (including updated versions). .
Special instructions for children:
If you are a child under 14 years old, before using EnglishTube products or services or providing any personal information, you need to carefully read this "Children's Privacy Policy" with your guardian, and obtain the consent of your guardian before using our products, services or provide information to us.
We will abide by the following principles to protect children's personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of consent, the principle of least sufficiency, the principle of openness and transparency, the principle of ensuring safety, the principle of subject participation, etc. At the same time, we promise that we will take corresponding security protection measures to protect children's personal information in accordance with the industry's mature security standards.
[Special Reminder] Before using our products and services, please be sure to read and understand the entire content of this policy carefully. Make sure you fully understand and agree to all terms before starting to use it. Once you start using it, it means that you have fully understood and agreed to this policy.
We remind you that we have used bold fonts and/or underlining to specifically remind you of the important provisions in this statement that may be closely related to the rights and interests of you and the children under your custody, so please read them carefully.
If you have any questions, comments or suggestions about the content of this policy, please contact us through the method at the end of the article. For personal information provided by children without the consent of their guardians, we will promptly delete the relevant information after receiving notification from their guardians.
This privacy policy will help you understand the following:
· How we use and collect children’s personal information
· How we use cookies and similar technologies
· How we share, transfer, and publicly disclose your children’s personal information
· How we protect and store children’s personal information
· Rights of guardians and children
· How we process children’s personal information
· How to update this privacy policy
· Dispute Resolution
· How to contact us
· Appendix
Last updated: August 8, 2023
Effective date: August 8, 2023
1. How we use and collect children’s personal information
We will collect and use the following types of children's personal information with your consent for the following purposes described in this policy:
(1) User registration
When children intend to register as EnglishTube users, they need to provide: mobile phone number and password to create an account. If children log in through third-party accounts such as WeChat, QQ or Weibo, we will collect your nickname, avatar, city and other public information. Before collecting this information, we will obtain the child's authorization through the authorization function of the third-party account. Please note that if a child refuses to provide the above personal information, we will not be able to complete user registration, and the child will not be able to use any features of EnglishTube. If a child wants to upload a picture of the child to us to customize the avatar when registering as a user,You can choose to authorize us to call the camera permissions, photo album permissions (or read and write external storage permissions) of the device used by the child.
(2) Provide you with customer service
When you contact our customer service, we may need you to provide necessary information to verify your identity and collect your contact information so that we can contact you in time after the problem is solved. The record and content of your communication with customer service will also be is saved.
(3) To ensure user safety and carry out user service improvement plans
In order to continue to provide safe and continuously optimize the services you need, when children use the services we provide, we may collect information related to children's use of the services. Such information includes:
· When using our services or visiting our platform web pages, we automatically receive and record information on your browser and computer, including but not limited to IP address, browser type, language used, access date and time, software and hardware feature information and required web page records and other data; if you download or use our or its affiliated company client software, or access mobile web pages to use our platform services, we may read information related to location and mobile devices, including but not limited to device models. , device platform, device manufacturer, device brand, operating system, resolution, telecom operator and network information (such as IP address, WIFI information, base station information and other related information), etc.;
· Log information refers to technical information that the system may automatically collect through cookies or other methods when using our services to determine your country and language;
· Information searched or browsed when using our services, such as the web search terms you use, the URL addresses of social media pages visited, and other information and content details browsed or requested when using our services;
· Operation records when using our services, including but not limited to course purchase records, browsing records, etc.
· In order to enable children to continue to enjoy the latest services, we may use the version information of children's applications and mobile phone models to provide application upgrade services for children. At the same time, we may collect the list and version number information of children's connected smart devices to provide children with smart device upgrade functions to ensure that children can use the latest version of the service (including firmware version).
At the same time, in order to collect the above basic personal device information, we will apply for permission to access children's device information. We collect this information to provide you with our basic services and basic functions. If children refuse to provide the above permissions, they may be unable to use it. Our products and services.
(4) Children’s personal information we collect through indirect means:
We may obtain relevant personal information that you authorize us to share from affiliated parties and third-party partners. We may obtain the account information (avatar, nickname, login time) you authorize to share from a third party and bind your third-party account to the child's EnglishTube account after you agree to this policy, so that you can log in directly through the third-party account and use our products and/or services.We will collect and use children's personal information in compliance with relevant laws and regulations, in accordance with agreements with affiliates or third-party partners, and on the premise that we are convinced that the source of personal information provided by them is legal.
(5) Exceptions to prior consent
We do not need your authorization to collect and use children's personal information under the following circumstances:
· Necessary for the conclusion and performance of a contract to which the individual is a party;
· Necessary to perform legal duties or legal obligations;
· In order to respond to public health emergencies, or necessary to protect the life, health and property safety of natural persons in emergency situations;
· Implement news reporting, public opinion supervision and other activities for the public interest, and process personal information within a reasonable scope;
· In accordance with the provisions of the "Personal Information Protection Law of the People's Republic of China", process personal information disclosed by individuals themselves or other information that has been legally disclosed within a reasonable scope;
· Other situations stipulated by laws and regulations.
Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot recover it, or we may de-identify the collected information. Research, statistical analysis and forecasting, providing product or service support for business decisions, and improving our products and services (including using anonymous data for machine learning or model algorithm training), the use of such processed data does not require separate consent from children. and guardian’s consent.
(11) If we stop operating EnglishTube products or services, we will promptly stop continuing to collect your personal information, notify you of the cessation of operations in the form of one-by-one delivery or announcements, and we will notify you of the relevant information we hold. Personal information related to business suspension will be deleted or anonymized.
2. How we use cookies and similar technical information
1. Cookies
To ensure that the website functions properly, we store small data files called cookies on your computer or mobile device. Cookies usually contain an identifier, the site name, and some numbers and characters. With the help of cookies, the website can collect and store data when you access and use this product.
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. See AboutCookies.org for details. You can clear all cookies saved on your computer or smart mobile device, and most web browsers have the ability to block cookies. However, if you do this, you will need to change your user settings yourself each time you visit our website.
2. Do Not Track
Many web browsers have a Do Not Track feature that issues a Do Not Track request to a website. Currently, the major Internet standards organizations have no policies in place that govern how websites should respond to such requests. However, if your browser has Do Not Track enabled, all of our sites will respect your choice.
3. How we share, transfer and publicly disclose children’s personal information
1. Share
We will not share children’s personal information with any company, organization or individual other than us and our affiliates, except in the following circumstances:
· Obtain your explicit consent or authorization in advance;
· Providing it to external parties when necessary in accordance with the requirements of laws, regulations, legal procedures, mandatory administrative or judicial requirements;
· Comply with the relevant agreements signed with you and the child (including electronic agreements signed online and corresponding platform rules) or other legal documents;
· We may share children’s personal information with our affiliates. However, we will only share children's personal information that is necessary and subject to the purposes stated in this Privacy Policy. If our affiliates want to change the purpose of processing children's personal information, they will again seek the guardian's authorization and consent.
· Sharing with authorized partners: To the extent permitted by laws and regulations, we only provide certain services with authorized contract partners to achieve the purposes stated in this privacy policy. We may share certain personal information of children with our partners to provide better customer service and user experience. We will only share children's personal information for legal, legitimate, necessary, specific, and clear purposes, and we will only share personal information necessary to provide services. Our partners have no right to use shared children’s personal information for any other purpose.
Currently, our authorized partners include the following types:
· Suppliers of goods or technical services. We may share children's personal information with third parties that support our features. This support includes providing us with payment services, data processing, etc. The purpose for us to share this information is to realize the core functions of our products and/or services. For example, we must share your order information with the logistics service provider to arrange delivery; or we need to compare your order number and order amount with the third party. Sharing with third-party payment institutions to enable them to confirm your payment instructions and complete payment, etc.; or we need to issue questionnaires to you and collect personal information through third-party questionnaire platforms (such as Questionnaire Star, Jindata), etc.
Third-party SDK. To ensure the implementation of EnglishTube related functions and the safe and stable operation of the application, we may access the development kit (SDK) provided by third-party software to achieve related purposes. We will conduct strict security testing on third parties and agree on data protection measures.
Please check for details"List of Personal Information Shared with Third Parties".
2. Transfer
We will not transfer children's personal information to any company, organization or individual, except in the following circumstances:
· Obtain your explicit consent or authorization in advance;
· When involving mergers, acquisitions, asset transfers or similar transactions, if the transfer of children's personal information is involved, we will require new companies and organizations that hold children's personal information to continue to be bound by this privacy policy. Otherwise, we will require The company or organization will seek your authorization and consent again.
3. Public disclosure
We will only publicly disclose children's personal information under the following circumstances and under the premise of taking safety protection measures that comply with industry standards:
· Based on your needs, disclose the personal information designated by the guardian in a disclosure method that has been explicitly agreed by the guardian;
· When it is necessary to provide children's personal information in accordance with the requirements of laws, regulations, mandatory administrative enforcement or judicial requirements, we may publicly disclose children's personal information based on the type of children's personal information requested and the method of disclosure. Under the premise of complying with laws and regulations, when we receive the above request to disclose information, we will require the recipient to issue corresponding legal documents, such as a subpoena or investigation letter. We carefully review all requests to ensure they have a legitimate basis and are limited to data that law enforcement has a legal right to obtain for specific investigative purposes.
4. Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information
In the following circumstances, we do not need to obtain the prior authorization and consent of the children and their guardians when sharing, transferring, or publicly disclosing children's information:
· Directly related to national security and national defense security;
· Directly related to public safety, public health, and major public interests;
· Directly related to criminal investigation, prosecution, trial and execution of judgment;
· In order to protect the life, property and other major legitimate rights and interests of children or other individuals but it is difficult to obtain the consent of the guardian;
· Information disclosed to the public by children or guardians on their own initiative;
· Collect children's personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
According to legal provisions, sharing, transferring, and disclosing de-identified personal information, and ensuring that the data recipient cannot recover and re-identify the information subject, does not constitute the external sharing, transfer, or public disclosure of personal information. The storage and processing will be without further notification to you and without your consent.
4. How we protect and preserve children’s personal information
(1) We have used security measures that comply with industry standards to protect children's personal information and prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable measures to protect children's personal information. For example, encryption technology is used to transmit your personal information; protection mechanisms are used to prevent personal information from being maliciously attacked; we hold security and privacy protection training courses to enhance employees' awareness of protecting personal information.
(2) We will take all reasonably feasible measures to ensure that no irrelevant personal information is collected. We will only retain children’s personal information for the period necessary to fulfill the purposes described in this policy, unless an extension of the retention period is required or permitted by law.
(3) All your personal information will be stored within the territory of the People's Republic of China. Currently, we do not provide personal information overseas.
(4) The Internet environment is not 100% safe, and we will try our best to ensure or guarantee the security of children's personal information. You know and understand,The systems and communication networks you use to access our services may have problems due to factors beyond our control. Therefore, you should take proactive measures to protect the security of children's personal information.We strongly recommend that you or children do not disclose personal information in the product to third parties (including other websites or products linked to this product) to avoid leakage of information; please use complex passwords and do not use your account password and related information. Disclose personal information to others to help us keep your account secure.
(5) After an unfortunate personal information security incident occurs, we will promptly inform children and guardians in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the handling measures we have taken or will take, and the measures you can take on your own Suggestions on preventing and reducing risks, remedial measures for you, etc. We will promptly notify you of the incident-related information through emails, letters, phone calls, push notifications, etc. When it is difficult to inform the personal information subjects one by one, we will issue announcements in a reasonable and effective manner. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.
5. Rights of guardians and children
In accordance with relevant Chinese laws, regulations, and standards, as well as common practices in other countries and regions, we protect guardians and children from exercising the following rights with respect to children’s personal information:
(1) Access to personal information
Children and their guardians have the right to access children's personal information, except for exceptions provided by laws and regulations. If you wish to exercise your right to access your data, you can access it yourself by:
· Account information - If you wish to access or edit the personal information and payment information in your account, change your password, add security information or close your account, etc., you can do so through our platform and/or log in to the relevant client. perform such operations.
· Search information - You can log in to your account to access or clear your search history.
· Order information - You can check or clear your order records, transaction records, etc. through our platform and/or log in to the relevant client.
If you are unable to access this personal information through the above methods, you can send an email to: 9317468@qq.com
We will respond to your access request within fifteen working days.
For other children's personal information generated during the use of our products or services, we will provide it as long as it does not require too much investment on our part.
(2) Correction of children’s personal information
When errors are discovered in the personal information we process about children, children and their guardians have the right to ask us to make corrections. You may make a correction request through the methods listed in "(1) Access to your personal information".
If you cannot correct this personal information through the above methods, you can send an email to: 9317468@qq.com
We will respond to your correction request within fifteen working days.
(3) Delete children’s personal information
Children and guardians may request us to delete personal information under the following circumstances:
· If our processing of personal information violates laws and regulations;
· If we collect and use your personal information without the consent of children and guardians;
· If our processing of personal information violates the agreement with the child or guardian;
· If you no longer use our products or services, or cancel your account;
· If we no longer provide products or services to you.
When you decide to delete one or more pieces of information, you can send an email to: 9317468@qq.com. We will respond within fifteen working days.
When we delete children's personal information, we may not delete the corresponding information from the immediate backup system, but we will delete the information when the backup is updated.
(4) Change the scope of authorization and consent
Each business function requires some basic personal information to be completed. For the collection and use of additional children's personal information, children and their guardians can give or withdraw their authorized consent at any time.
When consent is withdrawn, we will no longer process the corresponding children's personal information. However, the decision to withdraw consent will not affect the previous processing of children’s personal information based on authorization.
(5) Cancel account
You can cancel your previously registered account at any time. You can apply for account cancellation through "Help and Feedback-How to Cancel Account"; please also send a request to the following email: 9317468@qq.com. We will complete the cancellation within 15 working days after receiving your cancellation request.
Please note that to ensure account security, we will perform necessary identity verification. After canceling the account, we will stop providing products or services, purchased services will no longer be valid, and children's personal information will be anonymized, unless otherwise provided by laws and regulations.
(6) Children’s personal information subjects obtain copies of personal information
Children and guardians have the right to obtain a copy of your personal information. You can apply to obtain it through the following methods: 9317468@qq.com
(7) Respond to your above request
To ensure safety, children and guardians 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.
We will respond within fifteen working days. In principle, we do not charge fees for reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the circumstances. For those that are gratuitously repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes) request, we may deny it.
In the following circumstances, in accordance with the requirements of laws and regulations, we will not be able to respond to your above request:
· Relevant to the personal information controller’s performance of obligations stipulated in laws and regulations;
· Directly related to national security and national defense security;
· Directly related to public safety, public health, and major public interests;
· Directly related to criminal investigation, prosecution, trial and execution of judgments;
· The personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abused rights;
· To protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals but it is difficult to obtain the consent of the individual;
· Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;
· Involving trade secrets.
6. How to update this privacy policy
We may make changes to this Privacy Policy from time to time.
We will not reduce children's rights under this privacy policy without your explicit consent. We will post any changes to this policy on this page.
For major changes, we will also provide more prominent notices.
Major changes referred to in this policy include but are not limited to:
· Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
· We undergo significant changes in ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers, etc.;
· The main recipients of personal information sharing, transfer or public disclosure change;
· Significant changes in your rights to participate in the processing of personal information and how you exercise them;
· When our responsible department, contact information and complaint channels for handling personal information security change;
· When the personal information security impact assessment report indicates that there is a high risk.
7. How to contact us
If you have any questions, comments or suggestions about this Privacy Policy, please contact us through the following methods:
Shenzhen Time Value Information Technology Co., Ltd.
Email: 9317468@qq.com
Tel: 18126201952 (working days 9:30-12:00, 14:00-18:30)
Registered address: Room 311, Building H, OCT Creative Park, Nanshan District, Shenzhen
Contact information of Personal Information Protection Specialist: 9317468@qq.com
We will respond within fifteen working days after receiving your request.
appendix:
1. Personal information: refers to various information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person. Personal information that may be involved in this privacy policy includes but is not limited to: basic personal information (including name, phone number, gender, location, school, grade, etc.); personal identity information (including ID card, teacher qualification certificate, etc.); network Identity information (including system account, email address and password related to the above); personal property information (including transaction and consumption records, etc.); personal device information (including IMEI, IDFA, Android ID, MAC, OAID, IMSI and other device identifiers and other device-related information), network information (IP address, WiFi information, base station information and other network-related information), application information (application crash information, notification switch status, application installation list and other application-related information) and device parameters and System information (device type, device model, operating system and hardware-related information).
2. Personal sensitive information: refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety, and can easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment. Personally sensitive information that may be involved in this privacy policy includes: personal identity authentication information (including ID card, teacher qualification certificate, etc.); information of minors under 14 years of age.
3. Related companies: namely, subsidiaries of Shenzhen Time Value Information Technology Co., Ltd. or other companies that are related to Time Value