Heyni Online Education Inc. and its associated company (hereinafter referred to as “Heyni Talk” or “us”respect and protect privacy right of all users using Heyni Talk service; when users use service provided by us, we may collect and use related information of use. It is hoped that we can inform users how we collect, store, protect and use user’s individual information as well as how we handle user’s individual information through Privacy Policy. The Privacy Policy is closely related to service of Heyni Talk used by users; therefore, it is recommended that users can completely read it to help users to protect user’s privacy better.

If users have any doubt for Privacy Policy, you can contact us through the contact method issued through our platform. If users don’t agree with any content in Privacy Policy, users shall immediately stop using our service. When users use any service provided by us, it means users have agreed with us on legally using and protecting user’s individual information based on the Privacy Policy.

I. Scope of application

1. The Privacy Policy is suitable for all services provided by us. The Privacy Policy is applicable if users visit our platform network / or login related client terminals to use service provided by us.

2. The privacy policy is not applicable for service provided by other third parties to users; for example, when the third party on our platform provides service to users through our platform, Privacy Policy is bit applicable for individual information provided by users to the third party. We shall not bear any responsibility of information provided by us to any third party.

II. How do we collect information

When we provide service, we may collect, preserve and use following information related to users. We collect information to provide better and more individualized service to users and the method for collecting information is listed below:

1. Information provided by user

When users register account and/or use related services provided by us, following information may be filled and/or mentioned, including user’s name, gender, nationality, language, career, education background, age, ID card number, phone number, email, address, hobby and related additional information (such as user’s country, province and city and postal code, etc.).

Shared information provided by users to other parties through our service and information preserved by users in using our service.

2. Information collected when users use service.

In order to provide and optimize service necessary for user, we may collect related information when users use service. The type of information includes:

(1)Information of users on browser and computer automatically received and recorded by us when they use our service or visit website of our platform, including but not limited to IP address of user, browser type, used language, visit date and time, software and hardware feature and information, website record of user demand and other data; if users download or use client terminal software of us or associated company or visit mobile website to use our platform service, we may read information related to user position and mobile equipment, including but not limited to equipment type, equipment identification code, operation system, resolution ratio and telecom operator, etc.;

(2) Log information, which refers to technical information which may be automatically collected by the system through cookies, web beacon or other methods when users use our service to formulate user’s country and used language, etc.;

(3) Information searched or browsed by users in using our service, such as word researched by users on the website, visited url address of social media page and other information and specific contents browsed or required to provide by users in using our service;

(4) Information when related users used our APP and other software in the past as well as information of the APP and software used by users in the past;

(5) Information communicated by users through our service, such as communication account, time, data and duration;

(6) Information (meta data) included in the content shared by users through our service, such as shooting or recording date, time or place, etc.;

(7) Information provided and recorded in using our service, including but not limited to purchasing course, course reservation and course video and audio recording.

3. Our cookies shall not research extra information on computer browser or hard disk of the user. The major part of browser has the selection of refusing to preserve data on computer to cookies. Users can revise the acceptance degree of Cookie or refuse our Cookie; however, it is not recommended that users make the setting as the action may influence users to visit our related websites safely and use service provided by us to a certain degree.

III. How do we use information

1. As the information of user collected by us is for providing service and improving service quality to users, so we may use user’s information to following usages for realizing the purpose:

(1) Provide various services used by users to users and design, maintain and improve these services;

(2) It is used for identification verification, client service, safety prevention, fraud monitoring, archiving and backup when we provide service to guarantee safety of products and services provided by us to users;

(3) Match Chinese supervisor and learning content suitable for users based on user’s demand, region, age, job, language ability, background, interest and learning preference;

(4) Analyze the state when users use our service so that we can learn more about how to access and user our service so as to pertinently respond user’s personalized demand, such as language setting, position setting and personalized assistance and indication or correspondence to users and other users in other aspects;

(5) When users use our service, we may use user’s information to send email and news or notices to user’s equipment. If users don’t want to receive these information, they can select to cancel subscription on equipment based on our related prompt;

(6) Recommend contents to uses that they may be interest in, including but not limited to sending product and service information to users, showing individualized third party popularization information to users through the system or sharing information with our partners in the circumstance of acquiring for user’s consent so that they can send related product and service information to users;

(7) Software certification and updating of management software;

(8) Provide advertisements more related to users to them to replace common advertisements;

(9) Let users participate in survey related to our product and service or promotion and lottery activity;

(10) Other usages permitted by users. 

IV. How do we share information

1. We bear the obligation of maintaining secrecy of user’s information without selling or renting any information of users. We shall share user’s information with the third party in following circumstances:

(1) Gain consent or authorization from users in advance;

(2) Based on laws and regulations or requirements of administrative or judicial institution;

(3) Share user’s individual information to our associated party;

(4) Provide user’s individual information to reliable partner so that they can handle these information based on our instruction by obeying our Privacy Policy and other corresponding secrecy and safety measures;

(5) If the user is competent intellectual property right complainant who has filed a complaint, it is needed to disclose to person complained based on the requirement of person complained so that both parties can handle possible right dispute;

(6) Service needed by users can be provided only by sharing user’s information or it is needed to handle the dispute between users and other people. For example, when users start a transaction on our platform, if any party performs or partially performs transaction obligations and put forward information disclosing requirement, we shall provide contact method and other necessary information of the other party in the transaction to users based on the situation to promote transaction completion or dispute solution;

(7) It is needed to disclose to the third party if users violate related laws and regulations or related agreements and rules between us;

(8) Search for, prevent or handle fraud, safety or technical problems;

(9) To maintain interests of users and the public in emergency;

(10) To maintain legal rights of us and our associated parties or users.

V. How do we protect user’s individual information

1. Individual information collected and generated by during operation is reserved in America. In order to safeguard user’s information safety, we make efforts to adopt various reasonable physical, electronic and management safety measures to protect user’s information so that user’s information shall not be leaked, damaged or lost, including but not limited to SSL, information encrypted preservation and control of visit to data center. We also adopt strict management for employees or outsourcing personnel who may contact user’s information, including but not limited to adopting different power controls based on different posts, signing secrecy agreement, monitoring their operation state and other measures. We shall provide corresponding safety measures based on existing technology to protect user’s information, provide reasonable safety safeguard and we shall try our best to protect user’s information from being leaked, damaged or lost.

2. User’s account all have safety protection function. Please keep user’s account and password. We shall guarantee user’s information from being lost, abused and changed through providing backup to other servers, encrypting user’s password and other safety measures; however, it is hoped that users can understand “perfect safety measures” don’t exist on information network.

3. In using the third party to conduct online transaction, it cannot be avoided that users shall disclose individual information to transaction target or potential transaction target, such as bank account information, contact method or e-mail address. So users need to properly protect own individual information which can be provided to other people if necessary.

VI. How do users protect individual information

Users can visit and manage user’s individual information through following methods:

1. Visit individual information

(1) Users have the right to visit user’s individual information, excluding exceptional situation regulated in laws and regulations. Users can independently visit user’s individual information through following methods:

(2) Account information – if users hope to visit or edit basic individual material and information, change user’s password or close user’s account in user’s account, users can implement the operation through “account management” through logging on the account.

(3) If users cannot visit individual information through previous routes, users can contact us through customer service personnel at any time. We shall reply user’s visit request within 15 days.

2. Change or supplement individual information

Users have the right to ask us to make change or supplement if they find there are errors in individual information about users handled by us.

3. Delete individual information

(1) Users can delete their partial individual information through the method listed in “1. Visit user’s individual information”. Users can ask us to delete individual information in following circumstances:

    1. If we violate laws and regulations in handling individual information;
    2. If we collect and use user’s individual information without getting clear agreement from users;
    3. If we seriously violate appointment with users in handling individual information;
    4. If users don’t use our product or service any more or users actively cancels the account;
    5. If we cannot provide product or service for users any more.

(2) We may not delete corresponding information from backup system immediately after users delete information from our service; however, we shall delete these information when the backup is updated.

4. Main body of individual information cancels account

VII. Minor protection

We encourage parents or legal guardians (hereinafter referred to as “guardian”) to guide minor under 18 to use our service. It is suggested that minors encourage their guardians to read Privacy Policy and ask for agreement and guidance from guardians in submitting individual information. Heyni Talk shall establish and maintain reasonable procedure to protect secrecy and safety of individual materials of minors.

VIII. Change

We may revise articles in Privacy Policy at appropriate time and revision constitutes one part of Privacy Policy. If the revision results in the rights of users in Privacy Policy are reduced in essence, we shall notify users by prompting at obvious position on the platform or sending email to users or in other methods. In such circumstance, if users continue to use our service, it means they agree with the restraint of revised Privacy Policy.