Personal Information Protection Policy of Xiaoe-tech
These Terms are written in Chinese, this English translation is for reference purposes only. In the event of any discrepancy between the Chinese original and this English translation, the Chinese original shall prevail. We assume no responsibility for this translation or for direct, indirect or any other form of damage arising from the translation.
Release date: May 15, 2024
Effective date: May 22, 2024
I. Introduction
II. About us
III. Rules for collection and use of personal information
IV. How we store and protect your personal information
V. How you exercise your rights to personal information
VI. How we protect the personal information of minors
VII. How we use Cookies and similar technologies
VIII. Updates to this Policy
IX. Contact us
I. Introduction
1.1 Shenzhen Xiaoe Network Technology Co., Ltd. and its affiliates (“Xiaoe-tech”, “we”, “us” or “our”) understand and value the importance of personal information and privacy to you, and will do our best to protect your personal information and privacy. The Personal Information Protection Policy of Xiaoe-tech (“this Policy”) is intended to describe to you how we collect, use, store, share and transfer such information when you use our products and services, as well as the methods offered by us to you for accessing, updating, deleting and protecting such information.
1.2 This Policy applies to all products and services provided by Xiaoe-tech that are used by users located outside of the mainland of the PRC (“Xiaoe-tech Services”), including but not limited to Xiaoe-tech’s website, app, client side, SDKs and other new forms of services provided to you as technology evolves. You must carefully read and fully understand all contents of this Policy, especially clauses about exclusion and limitation of liability and those about collection, use, sharing and transfer of personal information, etc. Clauses about exclusion or limitation of liability will be written in bold to draw your attention, while collection and use of sensitive personal information and other important terms will be written in bold and underlined to draw you attention, and you are supposed to read them with particular care.
1.3 We will process your personal information in accordance with this Policy. By using our services or providing us with your personal information, you have fully understood and agreed to this Policy. You do not have to provide us with your personal information. However, if you elect not to provide the same, we may not be able to provide relevant products or services to you. This Policy may not address all possible personal information processing scenarios. We will inform you of collection of specific personal information or data relating to certain products or services and of scenarios not covered herein through supplementary privacy policy, or publish the same in the notice or policy provided when the data is collected, and obtain your consent. Please pay attention to prompts or notices when you enable a specific feature or use a specific product or service.
1.4 Please note that our products and services may contain links to apps or websites independently provided by third parties, the services for which are provided or operated by third parties. When you use a third party’s services and provide your information to a third party, you will be governed by the User Agreement and Privacy Policy of the third party, but not by this Policy. We are not legally liable for the content or security of other linked websites or apps or for whether they have taken adequate privacy protection measures. We recommend that you carefully read the User Agreement, Privacy Policy or Statement of any other app or website when you enter such app or website through the link, determine on your own whether or not to agree to its Privacy Policy or Statement, and further decide whether or not to use such third-party services.
II. About us
2.1 Xiaoe-tech Services are offered by Shenzhen Xiaoe Network Technology Co., Ltd. and its affiliates.
2.2 Affiliates include Shenzhen Xiaoetong Technology Co., Ltd. and Shenzhen Yunyan Network Technology Co., Ltd..
2.3 The basic information of our main business entity is as follows: Shenzhen Xiaoe Network Technology Co., Ltd., established on February 2, 2015, having its registered office at: 702, 7/F, Building D2, Kexing Science Park, Yuehai Street, Nanshan District, Shenzhen City, Guangdong Province, China.
III. Rules for collection and use of personal information
3.1 How we collect and use your personal information
Generally, we will collect and use your personal information in the following scenarios:
3.1.1 Account registration/login
When you register, log in to Xiaoe-tech and use relevant Xiaoe-tech Services, you may register your account (“Xiaoe-tech Account”) through mobile number or email, and we will collect your mobile number or email, login password and verification code to help you complete registration or login of Xiaoe-tech Account. Please be aware that the mobile number or email you submitted will be used to receive the verification code when you register, log in to and recover Xiaoe-tech Account and retrieve the password, and log in to other Xiaoe-tech Services, and as one of contact details designated by you and Xiaoe-tech, also used for management and other relevant operations of Xiaoe-tech Account (including information change, change of services, and sensitive operations), and further that Xiaoe-tech will send business notifications (including bills) to you or communicate with you separately in connection with business through such mobile number (“Safe Mobile Number” or “Account Contact Mobile Number”). You can also elect to register or log in to Xiaoe-tech Account via your WeChat account, in which case, you need to provide Open ID, Union ID and mobile phone model of the authorized WeChat account, go through verification through mobile number to complete real-name authentication, and also need to provide your WeChat profile picture, nickname and other information prompted on the page to complete WeChat registration and login.
We provide you with the “One-click Login” function in some terminals, which is designed to provide you with a convenient login method so that you may log in not using password or SMS verification code. When you use the “One-click Login” function, with your consent, we will collect your mobile number, mobile number operator information, rough location and other device information (including IMEI/MAC/AndroidID/IDFA/OpenUDID/GUID/SIM Card IMSI/ICCID/IP) through U-VerifySDK. We collect such information to help you complete login in a convenient and secure manner. You may complete registration and login through other methods if you do not want to use the “One-click Login” function.
3.1.2 Entrusted by the merchant with processing your personal information
Any merchant of Xiaoe-tech (“Merchant User”) provides you with services (“Merchant Services”) through Xiaoe-tech platform (小鹅通-知识产品与用户服务的私域运营工具). When you use Merchant Services, the Merchant User will entrust us with providing backend and data management services, etc. and processing information and data generated by the Merchant User itself and submitted or generated by the end user (“You”) during your use of Merchant Services, including information submitted by or requested from you by the Merchant User, information allocated to you by the Merchant User, and information submitted by you to the Merchant User necessary for its provision of services (“Entrusted Processing of Personal Information”). The Merchant User is the personal information processor of such information, while we are entrusted by the Merchant User with processing such information based on the Merchant User’s instructions (including operations performed by the Merchant User and its administrator via the management backend) and in accordance with the agreement between us and the Merchant User. Please note that before using Merchant Services, you should carefully read the User Agreement, Privacy Policy and other documents provided by Merchant User and fully understand how the Merchant User collects, processes and protects your personal information.
3.1.3 Customer services and dispute resolution
When you make a complaint or report to us or consult with us, we may request you to provide necessary personal information (including account and order information) for your identity verification in order to keep secure your account and system.
To facilitate our contact with you, help you resolve problems as soon as possible or record the solutions and results of related problems, we may keep communications, correspondence/phone records between you and us and other relevant contents (including account and order information, or other information you provide to prove the relevant facts, or your phone number and email you leave). If you consult with us or make a complaint or suggestion to us in respect of a specific order, we will use your account and order information.
3.1.4 Goods or services trading
When you order specific services among our products and/services, you need to provide the information relating to completion of the transaction, including
(1) information regarding traded services
(2) trading amount, order placement time, order number, order status, payment method, payment serial number and payment status.
We collect such information to help you smoothly complete transaction, keep secure your transaction, facilitate your inquiry about orders and provide customer and after-sales services and for other purposes of which we expressly inform you.
3.1.5 Learning information
When you use our products or services to receive course learning, we will record your learning information, including: learning behavior data, examination results and learning time. We collect such data to analyze your learning state.
3.1.6 Payment
When you pay for the order by scanning the QR code, we will collect your user ID (WeChat open ID) in WeChat payment channel or your user ID (Alipay login user ID) in Alipay payment channel, or PayPal (payer_id). Such information is necessary for us providing goods and/or services purchased by you, and we cannot obtain your personal property information only based on such information.
3.1.7 Information publishing functions
You may publish the information, including image-text/videos/live contents, comments and Q&As as well as the relevant information about goods and/or services as well as shop posted as a merchant, through the comment, message interaction, live streaming and other information publishing functions offered by us to you. We respect and protect your settings on whether the relevant information is published or not and on publishing scope.
You may independently and selectively improve your network identification information, including your profile picture and nickname. Meanwhile, you also may selectively fill in your name, address, gender, birthday, employer, position and other introduction information based on your social communication needs to improve your personal information. Pleased note the information published by you may involve your or others’ personal information even sensitive personal information, e.g., the pictures containing personal information that you select and upload when you post comments. Please take a further discretion in considering whether or not to share and even publicly share the relevant information when you use our services. If the information published by you involves other’s personal information, you shall obtain other’s consent before publishing it.
3.1.8 Generative AI Functions
You may use the generative artificial intelligence services provided by us to you for interactive dialogue, content creation, voice recognition, and other intelligent services for content generation. We will automatically receive and record the text/voice/image and other dialogue information you input during your interactions with Xiaoe-tech, and we will use such information to output content towards you and provide human-computer interaction services. We will also use your input information to improve our understanding of the content you input. If you refuse to allow us to collect and process the aforementioned personal information, you should exercise prudence in inputting such information, but this may affect your normal use of some functions provided by Xiaoe-tech.
We understand that the dialogue information you input and the feedback you submit may contain others’ personal information. If so, you must obtain their legal authorization to avoid improper leakage of others’ personal information.
3.1.9 Additional services based on system permissions
In order to provide you with more convenient and quality products and/or services and strive to improve your experience, we may collect and use your personal information by enabling system permissions when providing you with the following additional services. If you do not agree to enable relevant permissions, your use of Xiaoe-tech’s basic services will not be affected, but you may not be able to experience such additional services.
You may view the status of such permissions in the “Settings” of your device, and may, at your sole discretion, decide to enable or disable these permissions at any time.
Please note that by enabling any permission, you authorize us to collect and use the relevant personal information to provide you with corresponding services, and by disabling any permission, you cancel the authorization and we will no longer collect and use your relevant personal information based on corresponding permissions, and we will not be able to provide you with the services corresponding to such permission.
You can click here to view the Instructions on Request for and use of Application Permissions.
3.1.10 Other scenarios
1. Please be aware that we may need to process your personal information in the following scenarios in accordance with the applicable laws of your country or region:
(1) necessary for the conclusion or performance of a contract in which the individual is a party, or necessary for human resources management in accordance with the labor rules and regulations established pursuant to laws and the collective contracts signed under laws;
(2) necessary for the performance of statutory duties or obligations;
(3) necessary for the response to public health emergencies, or for the protection of life, health, and property safety of natural persons in emergencies;
(4) the personal information is processed to the extent reasonable for news reporting, media supervision, and other activities conducted for the public interest;
(5) the personal information disclosed by the individual himself or other legally disclosed personal information of the individual is processed to the extent reasonable and in accordance with laws; or
(6) other circumstances as provided by laws and administrative regulations.
2. We will process your personal information to the extent necessary and in accordance with the applicable laws of your country or region. We will collect and use your personal information within such scope and for such purpose as specified by this Policy. When we intend to use your personal information for any other purposes not specified in this Policy, we will inform you promptly and seek your consent in advance in the form of your active confirmation.
3.2 How we entrust others with processing, sharing, transferring and publicly disclosing your personal information
3.2.1 Entrusted processing
Our products contain third-party SDKs (software development kits) or other similar apps. If you use the services or functions provided by a third party on Xiaoe-tech products, you agree to allow the third party to directly collect and process your information.
The collection and processing of information by such third-party SDKs or other similar apps will be governed by the third party’s Privacy Policy, but not by this Policy. To ensure the security of your information to the greatest extent, we recommend that you read the privacy clauses of the third party before using any third-party SDK service. You can click here to read the Third-party SDK Directory of Xiaoe-tech.
3.2.2 Sharing
Except with your consent, we will not share your personal information with any company, organization and individual other than our affiliates. You can click here to read the Data Sharing Description of Xiaoe-tech.
3.2.3 Transfer
Except with your explicit consent, we will not transfer your personal information to any company, organization or individual. In case of personal information transfer that may be involved in a merger, acquisition or bankruptcy liquidation, we will require the new company or organization holding your personal information to continue to be bound by this Policy. If the collection and processing method of personal information as provided in this Policy changes, such company or organization will seek your authorization and consent anew.
3.2.4 Public disclosure
We will publicly disclose your personal information only under the following circumstances:
(1) with your explicit consent;
(2) as required by laws: We may publicly disclose your personal information as mandated by laws, legal proceedings, lawsuits or competent government departments; or
(3) necessary to make an announcement of penalties imposed on non-compliant accounts and fraud.
Importance Notice: In terms of public disclosure of your personal information, we will diligently review the legitimacy, rationality, and legality of such public disclosure application immediately after we receive the same, and protect such information by using the strictest personal information safeguards and measures at the time of and after public disclosure.
3.2.5 Other scenarios
Please be aware that we may entrust others with processing, sharing, transferring and publicly disclosing your personal information in the following scenarios in accordance with the applicable laws of your country or region:
(1) necessary for the conclusion or performance of a contract in which the individual is a party, or necessary for human resources management in accordance with the labor rules and regulations established pursuant to laws and the collective contracts signed under laws;
(2) necessary for the performance of statutory duties or obligations;
(3) necessary for the response to public health emergencies, or for the protection of life, health, and property safety of natural persons in emergencies;
(4) the personal information is processed to the extent reasonable for news reporting, media supervision, and other activities conducted for the public interest;
(5) the personal information disclosed by the individual himself or other legally disclosed personal information of the individual is processed to the extent reasonable and in accordance with laws; or
(6) other circumstances as provided by laws and administrative regulations.
IV. How we store and protect your personal information
4.1 Storage of personal information
4.1.1 Generally, we will try our best to process your personal information in your country or region. However, as a part of the services provided to you via our products and services, the personal information you provide to us may be transferred to the regions outside of your country or region in order to enable us to provide you with products and services. We will take all necessary measures to safeguard the security of your personal information in accordance with applicable legal requirements.
4.1.2 We will not retain your personal information longer than as necessary for the fulfillment of purposes as set out in this Policy, unless there are mandatory retention requirements in the laws of your country or region. Upon expiration of the retention period, we will delete or anonymize your personal information.
4.1.3 If we cease to operate Xiaoe-tech Services, we will promptly stop collecting your personal information, notify you of this situation individually or through an announcement, and delete or anonymize all personal information we hold. If children’s personal information is involved, we will also promptly inform their guardians of this situation.
4.2 Protection of personal information
4.2.1 We will take safety precautions meeting the industry standards to protect the personal information you provide, and prevent unauthorized access to, public disclosure or use of, modification to, damage or loss of the personal information. We will take various safety precautions within a reasonable level to safeguard the security of information. For example, we will use encryption technology (e.g., SSL), anonymization and other means to protect your personal information. At present, Xiaoe-tech has passed the ISO27001 information security management system certification to ensure that the security of your personal information will meet the relevant national requirements.
4.2.2 We have established a special management mechanism, process and organization to ensure the security of your information. For example, we have established an access control mechanism to strictly limit the scope of personnel with access to the personal information.
4.2.3 We will take reasonably practicable measures and try our best to avoid collecting unrelated personal information. We will not store your personal information longer than as necessary for the fulfillment of purposes as set out in this Policy, unless the extension of storage period is required or except as permitted by laws.
4.2.4 The Internet is not an absolutely secure environment, so we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical or management protection facilities are destroyed, thereby resulting in unauthorized access to, public disclosure, tempering or destruction of the information such that your legitimate rights and interests are damaged, then we will assume corresponding legal liability.
4.2.5 If any personal information security incident occurs unfortunately, we will timely inform you of: basic information on the security incident and its possible impacts, handling measures taken or to be taken by us, suggestions that you may solely prevent and reduce risks, remedies granted to you, among others as required by laws and regulations of your country or region. We will timely inform you of the relevant information on the incident through such methods as email, mail, phone, or system push notification. If it is difficult to inform the personal information subjects one after another, we will take reasonable and effective methods to make announcements.
4.2.6 We will also proactively report the handling progress of personal information security incidents as required by regulatory authorities.
V. How you exercise your rights to personal information
We will protect your rights to personal information in accordance with the legal requirements of your country or region. Please be aware that the legal requirements vary among countries or regions and the products or services you use are different, with some granting more personal information rights than others. You can exercise any personal information rights you are entitled to in accordance with the laws of your country or region, and we will promptly respond to your request and protect your legitimate rights and interests.
5.1 You have the right to view, correct or supplement your information
You may view, correct or supplement your information by yourself by the following ways:
Web: Log in to Xiaoe-tech account, enter “Account Home”, and click “Account Settings” to view and correct personal data and personal account information.
APP: Enter “Me” and click “Profile Picture” to view or supplement personal data and other relevant information;
If you are unable to correct your information by the aforementioned ways, you may contact our customer service personnel using the contact details as set out in Section 9 of this Policy. We will give feedback to you within 15 working days and the backend will synchronously correct relevant information.
5.2 You have the right to delete your personal information:
You may make requests for deletion of your personal information using the contact details as set out in Section 9 under the following circumstances:
(1) if our processing of your personal information violates the laws or regulations of your country or region;
(2) if we collect and use your personal information without your consent where required;
(3) if our processing of your personal information violates the agreement with you;
(4) if you no longer use our products or services, or you have de-registered your account; or
(5) if we cease to provide you with products or services.
After receiving your request for deletion, we will delete your personal information upon your request and give feedback to you within 15 working days (except for data that must be retained in accordance with the legal requirements of your country or region).
When you delete the information from our services, we may not immediately delete the corresponding information from our backup system, but will delete it when the backup system is updated.
5.3 You have the right to change the scope of your authorization and consent or withdraw your authorization and consent
Each of business functions may be realized with some basic personal information. If your personal information is processed with your consent, you may at any time change the scope of your authorization or withdraw your authorization and consent. If you want to change the scope of your authorization or withdraw your authorization, you may contact our customer service personnel using the contact details as set out in Section 9 of this Policy.
5.4 You have the right to cancel your account by the following ways
If you want to cancel your account, you may contact our customer service personnel using the contact details as set out in Section 9 of this Policy for cancellation, or you may cancel your account through “Me - Profile Picture - Account Cancellation” at the APP terminal or “Login - Profile Picture - Account Settings - Account Cancellation” at the official website of Xiaoe-tech.
After you take the initiative to cancel your account, we will stop providing you with products or services, and delete or anonymize your personal information as required by applicable laws.
5.5 Personal information subjects obtain a copy of personal information
You may contact our customer service personnel using the contact details as set out in Section 9 of this Policy to obtain a copy of your personal information, and the customer service personnel will provide you with a copy of personal information after verifying your identity.
5.6 Restrict automated decision-making by information system
For some business functions, we may make decisions only based on a non-human automated decision-making mechanism such as information system and algorithm. If such decisions significantly affect your legitimate rights and interests, you will have the right to request us to make explanations and we will also provide appropriate remedies.
5.7 Respond to your aforementioned requests
For the security, you need to provide written document or otherwise prove your identity when contacting customer service personnel to make your requests above. We will request you to verify your identity before responding to your requests.
We will have 15 working days to respond to your written requests.
We may freely provide services for your reasonable requests. If any third-party costs are incurred, you will solely bear such costs after we provide you with the corresponding evidence. Please note that we will charge you certain fees and expenses depending on circumstances for your repeated requests beyond a reasonable limit.
5.8 We will not be able to respond to you requests under the following circumstances:
(1) in connection with the fulfillment by the personal information controller of obligations under the laws of your country or region;
(2) directly related to national security or national defense security;
(3) directly related to public security, public health or major public interests;
(4) directly related to criminal investigations, prosecutions, trials or execution of court decisions;
(5) the personal information controller has sufficient proof that the personal information subject has subjective malice or abuses its rights;
(6) for the purpose of safeguarding the personal information subjects’ or others’ life, property or other significant legitimate rights and interests, in which case, it is hard to obtain their consent;
(7) respondence to the personal information subjects’ request will cause serious harm to legitimate rights and interests of the personal information subjects or of other individuals or organizations; or
(8) involving trade secrets.
VI. How we protect the personal information of minors
6.1 We attaches great importance to protection of minors’ personal information, and will process such information in accordance with the laws of your country or region. Except as required by applicable laws, we do not knowingly collect personal information of minors (as defined in the laws of your country or region). No minor shall provide us with their personal information without the consent of their parents or other guardians. If there is proof that we have collected any minor’s personal information without age verification, we will strive to delete relevant information as soon as possible upon discovery and verification. If you are a parent or guardian of a minor, please contact us using the contact details as set out in Section 9 if you have any question about the personal information of the minor under your guardianship.
VII. How we use Cookies and similar technologies
7.1 When you use our products and/or services, we may use Cookies and similar technologies to collect some of your personal information, including your login information, in order to facilitate your use of our products and/or services, simplify your repeated steps (such as registration, login), protect the security of your information and account, as well as improve our products and services.
7.2 If you refuse our collection and use of your relevant information with Cookies and similar technologies, you may manage or (in whole or part) reject Cookies and/or similar technologies through your browser settings as permitted by your browser with such function, or delete Cookies and/or similar technologies that have been stored on your computer, mobile device or any other devices, such that we cannot track your personal information in whole or part. If you need to learn more about how to change browser settings, please view the relevant setting page of the browser you are using.
You understand and know that: some of our products/services can be achieved only by using Cookies or similar technologies; your refusal to use or delete such technologies may result in your failure to use our relevant products and/or services normally or to get the best service experience via our products and/or services, and may also have a certain impact on your information protection and the security of your account.
VIII. Updates to this Policy
To provide you with better services, we will update the terms of this Policy based on the product updates and in accordance with the relevant requirements of the laws of your country or region, and the updated terms will constitute a part of this Policy. Without your explicit consent, we will not reduce the rights that you should have in accordance with this Policy. If such update results in a substantial reduction or major change in your rights under this Policy, we will inform you thereof prior to effectiveness of this Policy through making a prompt in a prominent place, sending you a push message or otherwise. By continuing to use our services, you have fully read, understood and agreed to be bound by this Policy as amended.
Major changes include but are not limited to:
(1) major changes in our service mode, such as the purpose of processing personal information, the type of processed personal information and how personal information is used;
(2) major changes in our ownership structure or organization chart, such as the change of owners due to business adjustments, a bankruptcy, merger and acquisition;
(3) changes of the main objects which personal information is shared with, transferred or publicly disclosed to;
(4) major changes in your rights in relation to personal information processing and in how you exercise such rights;
(5) changes of our department responsible for processed personal information security, contact details and complaint channels; and
(6) personal information security considered to be high risk as a personal information security impact assessment report indicates.
IX. Contact us
If you have any question, consult with us or make a compliant about the contents of this Policy or the matters relating to personal information protection you encounter when using our services, you may contact us by any of the following means:
(1) logging in to the account at www.xiaoe-tech.com to contact online customer service personnel;
(2) following “Xiaoe-tech” WeChat official account and clicking “Me - Consult Now”;
(3) dialing our customer service phone at 4001026665; or
(4) contacting our personal information protection team via email to legal@xiaoe-tech.com.
After receiving your comments and suggestions, we will reply to you within 15 working days from verification of your user identity. Please note that we may not reply to any question unrelated to this Policy or personal information protection.