Vlearning Privacy Policy

Release date: November 1, 2021

Effective date: November 10, 2021

Reminder terms:

Your trust is very important to us, and we fully understand the importance of personal information to you. We will take corresponding security measures in accordance with legal and regulatory requirements, and do our best to protect the security and controllability of your personal information. In view of this, the "Vlearning" service provider (or "us") has formulated this Privacy Policy (hereinafter referred to as "this Policy/this Privacy Policy") and reminds you:

This policy applies to:

The "Vlearning" products of Qingdao Hante Network Technology Co., Ltd., including but not limited to applications, web pages, software development kits (SDKs) and application programming interfaces (APIs) for third-party websites and applications, as well as continuously innovating and developing products and services. If you have a separate privacy policy for one or more services provided by Vlearning, the corresponding privacy policy for such services will form a complete set of privacy policies together with this privacy policy.

It should be noted that:

This policy does not apply to services provided to you by other third parties. To ensure a smooth product experience, you may receive content or links from third parties. Please carefully choose whether to access links, content, products, and services provided by third parties. Before submitting personal information to third parties, please carefully read these third-party privacy policies.

Before using our products or services:

Please carefully read and thoroughly understand this policy. Especially for clauses marked with bold/bold underline, please read them carefully and start using them only after confirming full understanding and agreement. If you have any questions, opinions or suggestions regarding the content of this policy, you can contact us through the various contact methods provided by Vlearning.

Part 1 Definition

"Vlearning" refers to the "Vlearning" learning platform, including but not limited to the computer end (domain name www.soke. cn) and mobile app end.

"Vlearning" service provider: refers to the legal entity that develops and provides "Vlearning" learning platform products and services, namely the Publicity and Public Opinion Research Center of the Central Propaganda Department.

Children: Refers to minors under the age of fourteen.

Personal information: refers to various information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person, either individually or in combination with other information.

Personal sensitive information: refers to personal confidential information including ID number, personal biometric information, bank account number, property information, travel trajectory, transaction information, children's information, etc. (We will prominently mark specific personal sensitive information in bold in this privacy policy).

Personal information deletion: refers to the act of removing personal information from systems involved in implementing daily business functions, keeping it in a state that is not retrievable or accessible.

Part 2 Privacy Policy

This privacy policy section will help you understand the following content:

• How do we collect and use your personal information
• How do we use cookies and similar technologies
• How do we share, transfer, and publicly disclose your personal information
• How do we protect your personal information
• How do you manage your personal information
• Declaration of Responsibility to Third Parties
• How do we handle children's personal information
• How to transfer your personal information globally
• How to update this privacy policy
• How to contact us

How do we collect and use your personal information

You understand and agree that:

• We are committed to creating diverse products and services to meet our needs. Due to the wide variety of products and services we provide to you, and the specific range of products/services that different users choose to use, there may be differences in various functions and the types and scope of personal information collected and used. Please refer to the specific product/service functions;
• To provide you with a better product and service experience, we are continuously striving to improve our technology. As a result, we may occasionally introduce new or optimized features, which may require the collection and use of new personal information or changes in the purpose or method of personal information usage. We will explain to you separately the purpose, scope, and usage of the corresponding information through updating this policy, pop ups, page prompts, and other means. We will also provide you with the option to choose and agree, and collect and use it with your explicit consent. During this process, if you have any questions, opinions or suggestions, you can contact us through the various contact methods provided in Article 10 "How to Contact Us", and we will provide you with answers as soon as possible.

(1) Help you become our user

• Registration Services: To help you become our user, so that we can provide you with user service. You need to provide your phone number to create an account, set a password (or verification code), and nickname to become our registered user.
• Complete information: You can choose to further improve the account information of this product, such as filling in your name, position, etc. However, if you do not provide this information, it will not affect your use of the basic services provided by this product.
• Real name authentication: In order to ensure the safety of the learning organization, we will conduct real name authentication by providing your name, ID card information, face recognition, or Alipay authorization information in the link where you create the learning organization.

(2) Providing you with browsing services

During your use of our services, in order to identify abnormal account status, understand product compatibility, and provide you with content display and search results that better meet your needs, and based on basic operational needs such as file caching, downloading, and log storage, we need to obtain your public area read and write permissions, and may automatically collect your usage information and store it as network log information, including:

• Device Information: We will receive and record device related information (including device model, operating system version, device settings, MAC address and IMEI, unique device identifier, device environment, and other software and hardware feature information) based on your specific operations during software installation and/or use.
• Service log information: When you use the products or services we provide, we will automatically collect detailed usage information of your services as a service log, including browsing, clicking to view, searching and querying, bookmarking, following and sharing information, publishing information, as well as IP address, browser type, telecommunications operator, language of use, access date and time, etc.

Please note that individual device information and service log information cannot identify the identity of a specific natural person. If we combine this type of non personal information with other information to identify a specific natural person's identity, or use it in combination with personal information, during the combined use period, this type of non personal information will be considered personal information. Unless authorized by you or otherwise required by laws and regulations, we will anonymize and de identify this type of information.

(3) Providing you with communication and exchange services

• When you need to send voice or video calls or conferences for unilateral or multi-party frequency based on communication and exchange; We need to obtain your microphone and camera permissions.
• When managing your contacts, friends, administrators, and students in Vlearning, we need to obtain your contact information.
• When you need to send location information or participate in "Vlearning" on-site learning in communication, we need to obtain your geographical location information.
• The files you are communicating with will be stored in the "Vlearning" cloud server. We need to obtain your storage permissions to help you upload files locally on the terminal device or download cloud server files to the terminal device.

(4) Providing you with information publishing and interactive services

• Content uploading and publishing: When you use content comments, replies, and other functions, we will collect the information content you choose to post, and display your profile picture and post content (graphics, audio, etc.).
• Please note that the information you publicly disclose may involve personal information or even sensitive information of yourself or others. If you choose to upload images containing personal information when publishing, please consider whether to share or even publicly share relevant information when using our services. If the information you publicly release involves personal information of children, you need to obtain authorization from the guardians of the children involved before publishing. Under the aforementioned circumstances, children or guardians have the right to contact us through the channels specified in Article 10 of this policy, requesting correction or deletion of content related to children's personal information; The information publisher shall bear the liability for infringement caused by refusal or delayed deletion.
• Live content authorization: To ensure that you can use live streaming, live playback and other functions normally, "Vlearning" needs to store, transmit, process the content you publish (including but not limited to the text, audio, video, images, files, web pages, trademarks, logos, and other content you upload and publish through this function) and display it to relevant audiences during your use of this service, You agree to authorize "Vlearning" to carry out such storage, transmission, and display, and "Vlearning" shall not be required to pay any fees to you.

(5) Please participate in the event

To continuously improve the functionality and user experience of this product, the platform will launch surveys and other activities for upcoming services or features, and provide you with information on related activities through page displays, notifications, on-site messaging, off-site push notifications, and the effective contact information you provide us with. If you participate in related activities, we may collect information such as your occupation, gender, political status, education level, etc. through the activity interface, in order to provide you with more accurate services. If you do not participate in the relevant activities, you do not need to provide the aforementioned information.

(6) Providing you with live streaming services

To participate in live streaming interactions, you need to enable your camera and microphone permissions in order to use the "Vlearning" live streaming function normally; If you activate the "Vlearning" live streaming function as a host, you need to provide valid identification documents that can prove your identity and complete real name authentication through facial scanning.

(7) Customer service and problem-solving

Contact us through customer service consultation and other means: When you contact us, we will collect the consultation content you provide as well as your contact information (account, address, email, communication/call records and content, or other contact information you leave), so as to contact you or help you solve problems, or record the solutions and results of related problems.

(8) Providing You with Security

To prevent, detect, investigate fraud, compromise account security, or other violations of our agreement, or to achieve the purpose of your access, we will collect your network information, device information, phone model hardware information, and system information. To better prevent security risks such as network vulnerabilities, computer viruses, network attacks, and network intrusions, and to more accurately identify violations of laws, regulations, or our relevant agreement rules, we may use or integrate your membership information, device information, services, and information authorized by our partners or shared by law to assess your account and transaction risks, conduct identity verification, detection, and prevent security incidents, And necessary recording, auditing, analysis, and disposal measures shall be taken in accordance with the law.

(9) Other

• If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing us with this personal information.
• If we use the information for other purposes not specified in this policy, or collect information for specific purposes for other purposes, or if we proactively 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 explicitly request in writing that the third party collect personal information after obtaining your consent in accordance with the law before collection, and inform you of the content of the shared information. If sensitive information is involved, it must be confirmed by you before being provided to us for use. We will require the third party to make a commitment to the legality and compliance of the source of personal information. If the third party violates the law, We will clearly require the other party to assume corresponding legal responsibilities; At the same time, our professional security team will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will use no less than the same protection measures and measures as we do for our own user personal information to protect indirectly obtained personal information.

3. Exceptions to obtaining authorized consent

You fully understand and agree that we do not require your authorized consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or request for information:

• Related to national security and national defense security;
• Related to public safety, public health, and major public interests;
• Related to criminal investigation, prosecution, trial, and enforcement of judgments;
• For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain my consent;
• Personal information that you disclose to the public on your own;
• Collecting personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;
• According to the necessary agreements or other written documents signed and fulfilled with you;
• Necessary for legitimate news reporting;
• Academic research institutions conduct statistical or academic research based on the public interest, and provide academic research or descriptions to the public, while de identifying the personal information contained in the results;
• Other situations stipulated by laws and regulations

4. If we cease to operate our products or services:

We will promptly cease the collection of your personal information, notify you of the cessation of operation in the form of individual deliveries or announcements, and delete or anonymize the personal information related to the closed business that we hold.

2、 How do we use cookies and similar technologies

• Cookies: To ensure the normal operation of the "Vlearning" learning platform, provide you with an easier access experience, and recommend content that you may be interested in, we will store cookies, Flash cookies, or other local storage provided by browsers (or associated applications) that typically contain identifiers, site names, and some numbers and characters (collectively referred to as "cookies") on your computer or mobile device. With the help of cookies, this platform can store your preferences and other data.
• Cookie related technologies: In addition to cookies, we also use other similar technologies such as website beacons, pixel tags, ETags, etc.

3. How do we share, transfer, and publicly disclose your personal information

• Sharing: We will not share your personal information with companies, organizations, or individuals outside of the "Vlearning" service provider, except in the following circumstances:
• Transfer: We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
• Public disclosure: We will only publicly disclose your personal information in the following circumstances:

4. How do we protect the security of your personal information

• We have taken reasonable and feasible security measures that comply with industry standards to protect your information, preventing unauthorized access, public disclosure, use, modification, damage or loss of personal information.
• We have an advanced data security management system that takes data as the core data lifecycle in the industry, including system design, personnel management, product technology, etc., to enhance the security of the entire system.
• We will take reasonable and feasible measures to avoid collecting irrelevant personal information as much as possible. We will only retain your personal information for the period specified in this policy, unless there are mandatory retention requirements by law.

5. How do you manage your personal information

• Access your personal information: You have the right to access your personal information, except in exceptional circumstances stipulated by laws and regulations.
• Correcting or supplementing your personal information: When you discover errors in the personal information we process about you, you have the right to request us to make corrections or supplements.
• Delete your personalinformation: You can remove some of your personal information through the methods listed in "(1) Accessing Your Personal Information".
• Change the scope of your consent: Each business function requires some basic personal information to be completed (see Part 2 of this Privacy Policy). In addition, you can revoke partial authorization by unbinding, modifying personal settings, removing relevant information, or by disabling the function.
• Personal information subject annotation account: You can submit an account cancellation application on the "Account and Security" page by yourself.
• Constrained Information System Automatic Decision Making: In certain business functions, we may make decisions based on non manual automatic decision-making mechanisms such as information systems and algorithms.
• Respond to your writing request: To ensure security, you may need to provide a written request or other means of proving your identity.

6. Declaration of Responsibility to Third Parties

When you access third-party services or programs accessed by "Vlearning", the third party may collect, use, store your relevant data or information in accordance with their privacy policy or relevant agreements, and may also place their own cookies or network beacons. These cookies or network beacons are not under our control, and their use is not subject to this privacy policy. We will strive to require third parties to take protective measures against your personal information. We suggest that you fully understand the terms of service and privacy policies of third-party products or services before accepting or using them. If you find that third-party products or service providers have engaged in illegal or irregular behavior, we suggest that you terminate the relevant operations.

7. How do we handle children's personal information

Children are not allowed to create their own user accounts without the consent of their guardians. If you are a child, we require your guardian to carefully read this privacy policy and use our services or provide information to us with the consent of your guardian. For the collection of personal information of children using our products or services with the consent of our guardians, we will only use, share, transfer or disclose this information when permitted by laws and regulations, with the explicit consent of our guardians, or necessary to protect children.

8. How to transfer your personal information globally

Personal information collected and generated during our operations in the People's Republic of China, stored within China, except for the following situations: 1. Clear provisions in laws and regulations; 2. Obtaining your explicit authorization. In response to the above situations, we will ensure that your personal information is adequately protected in accordance with this privacy policy. If there is an exit situation, an exit security assessment will be conducted in accordance with relevant national regulations.

9. How to update our privacy policy

Our privacy policy may change. Unless otherwise mandatory by laws, regulations or regulatory provisions, the adjusted or changed content will take effect 7 days after being notified or published. If you continue to use any services provided by "Learning Power" or access relevant websites or applications after adjusting or changing your privacy policy, we believe that this represents that you have fully read, understood, and accepted the revised privacy policy and are bound by it. Without your explicit consent, we will not limit your rights under this privacy policy. We will post any changes made to the privacy policy on a dedicated page. For significant changes, we will also provide more prominent notifications (such as pop-up notifications to you).

10. How to contact us

You can contact us through the following ways, and we will respond to your request within 15 days. If you have any questions, comments or suggestions about the content of this policy, you can contact us by calling our customer service number "0532-88983839" or online customer service, or by emailing to the following address:

Recipient: Qingdao Hante Network Technology Co., Ltd.

Address: Room 301, 3rd Floor, Building 4, Optics Valley Software Park, No. 396, Emeishan Road, Huangdao District, Qingdao City, Shandong Province

If you are not satisfied with our response, especially if you believe that our handling of personal information has damaged your legal rights, you can also seek a solution by filing a lawsuit with the court that has jurisdiction over the defendant's domicile.