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Privacy policy

Update date: June 10, 2021

Hangzhou Tianwa Network Technology Co., Ltd. (hereinafter referred to as "we" or "TianWa Chinese") respects and protects user privacy. When you use the services provided by the TianWa Chinese APP (hereinafter referred to as "TianWa Chinese"), we will provide services to you in accordance with the "TianWa Chinese User Service Agreement"; also, we will follow the "TianWa Chinese User Privacy Policy" (hereinafter referred to as "this privacy policy") to follow the principles of lawfulness, justification, and necessity, and publicly and expressly collect and use your personal information.

Please read all the terms of this privacy policy carefully so that you can understand the purpose, scope, and method of TianWa Chinese’s collection and use of your personal information. If you are a child, please review this privacy policy with your legal guardian. After the legal guardian has reviewed and agreed to it, you can use TianWa Chinese products and provide personal information to TianWa Chinese. If you or your guardian do not agree to any content in this privacy policy, you should immediately stop using TianWa Chinese products or services. When you use any service provided by TianWa Chinese, it means that you have agreed to our collection, use, storage, and protection of your relevant information in accordance with this privacy policy.

We are well aware of the importance of personal information to you, and will do our best to protect your personal information safe. We are committed to maintaining your trust in us and will abide by the following principles to protect your personal information: the principle of consistent power and responsibility, the principle of clear purpose, the principle of choice and consent, the principle of least necessity, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise that we will adopt security protection measures to protect your personal information in accordance with the mature security standards of the industry.

This privacy policy will help you understand the following:

I. Scope of application

II. How we collect and use your personal information

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

IV. How do you manage your own information and account cancellation

V. How do we store your personal information

VI. How do we protect your personal information

VII. Protection of minors

VIII. Revision of this policy

IX. Dispute jurisdiction

X. Contact Us

I. Scope of application

1. This privacy policy applies to all services provided by TianWa Chinese except for specific products and services that will be subject to specific privacy policies.

2. It should be noted that this privacy policy does not apply to services provided to you by third parties except for the sharing of information with third parties confirmed by you in Article 4 of this privacy policy. Please be aware that: if you provide personal information to a third-party website or use a third-party product or service, your information should be subject to the third-party’s privacy policy, and we do not assume any legal responsibility. Please be sure to read it carefully by then the third party’s privacy policy and confirm whether to accept it.

II. How we collect and use your personal information

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 can reflect the activities of a specific natural person. The personal information of children under the age of 14 (inclusive) is sensitive information. The products and services we provide need to rely on some of your information to operate. Therefore, when you use TianWa Chinese products, you need to provide us with or allow us to collect the necessary information for us to use this information to provide you with basic services and better personalized services, including:

1. Information you voluntarily provide to us

(1) To help you become our user-- The registration information you fill in, including your phone number used to register, log in to TianWa Chinese account, use TianWa Chinese products and services, our customer service, after-sales services, and consulting services, which aim to protect your account security. If you only need to browse and learn about TianWa Chinese, you do not need to register as our user and provide the above information;

(2) In order for us to provide services to you-- The personal information you fill in, including your name or nickname, gender, profile, identity, grade, class, school, year of enrollment, QQ, is used for interaction in class and recommend suitable courses, recommend nearby schools, distribute virtual rewards, and send online activities. You can choose whether to provide the above information according to whether you need personalized service;

(3) To ensure the safety of your funds, so that you can receive money transfers or gifts-- Your name, mailing address, contact information, and even your real-name authentication, etc. provided by you when you purchase products that need to be mailed or the supplementary materials attached to the course or when you participate in our relevant marketing activities. If you refuse to provide this information, we will not be able to send you your purchased products, teaching materials, gifts, or transfers;

(4) When you contact us, we may save your communication or call records and content or the contact information you leave in order to help you solve problems, or record solutions and results of related problems. Our customer service will use your account information to verify your identity with you. You may provide other information besides the above information when communicating with our customer service staff.

2. For the information we collect during your use of the service, we will obtain your consent in advance, except in circumstances prescribed by law:

(1) When you use the TianWa Chinese App for the first time, after obtaining your authorization, we will receive and record information about the device you are using, including device attribute information (such as IMEI, IMSI, device model, operating system version), device settings, unique device identifiers, and other software and hardware characteristics information), device connection information (such as IP address, telecommunications operator, access date and time, etc.) to protect your account and transaction security;

(2) When you use TianWa Chinese App for the first time, we will read your mobile phone status after you authorize it to ensure the normal use of TianWa Chinese App services, and more accurately locate and solve the problem during use, and improve and optimize the service experience of TianWa Chinese, and protect your account security;

(3) When you enter the subject page for the first time, we will apply for your geographic location permission to help you match the activities in the current area and recommend the courses of the corresponding regional textbook version;

(4) When you enter the live broadcast classroom for the first time, upload notes, edit your profile picture, and call up the camera shooting functions, we will apply for your camera permission for teacher-student interaction in class, photo sign-in, and video class;

(5) When the interactive function is triggered during your class, we will apply for your camera permission for the video interaction between students and teachers in class

(6) When you connect with the teacher, send voice bulletins, and follow-up reading during your class, we will apply for your microphone permission for teacher-student classroom interaction, voice answering, and audio input;

(7) When you participate in marketing activities and there is a need to contact you, we will obtain your phone permissions to enable our customer service staff to communicate with you

(8) When you purchase a live lesson service and write it into the calendar for the first time, we will apply for your calendar permission to remind you of the start of the course.

3. Exceptions with prior consent:

(1) It is related to the performance of the obligations stipulated by laws and regulations by the personal information controller;

(2) Directly related to national security and national defense security;

(3) It is directly related to public safety, public health, and major public interests;

(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

(5) In order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;

(6) The personal information involved is disclosed to the public by the subject of personal information on his own;

(7) Necessary for signing and performing contracts in accordance with the requirements of the subject of personal information;

(8) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(9) It is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and disposing of product or service failures;

(10)The personal information controller is a news organization, and it is necessary for it to carry out legal news reports.

4. Anonymization

For your information we collect, we will use technical means to anonymize it in a timely manner. Under the premise of not divulging your personal information, we have the right to analyze, mine and use the anonymized user data, and have the right to perform statistical analysis on the use of Tianwaa products and use it for possible third-party information sharing.

5.According to laws and regulations, sharing, transferring, and disclosing personal information that has been de-identified, and ensuring that the data recipient cannot restore and re-identify the subject of the information is not an act of external sharing, transfer, and public disclosure of personal information. The storage and processing of such data does not require your consent.

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

1. We will treat your information with a high degree of diligence. Unless we have your explicit consent, we will not share your personal information with any company, organization or individual other than our company, but after processing, we cannot identify specific individuals and cannot Except for restoration. At present, we will ask you for your authorization to share personal information in the following situations:

(1)Share your equipment information, network information, and location information to China Mobile Internet Co., Ltd., China United Network Communications Group Co., Ltd., China Telecom Group Co., Ltd., Shenzhen Hexun Huagu Information Technology Co., Ltd. for one-click login Verification, verification code reception;

(2) Share your device information to the Umeng SDK of Beijing Ruixunlingtong Technology Co., Ltd. for sending messages (including operational activities, version updates, etc.);

(3) If you use a Huawei/Oppo/Vivo/Xiaomi mobile phone, your Huawei/Oppo/Vivo/Xiaomi PushSDK needs to read your device identification number and other device information to push notification bar messages;

(4)Share your positioning information to the Baidu Map SDK positioning of Beijing Baidu Netcom Technology Co., Ltd. to locate nearby schools and provide you with better services when you improve your personal information and select schools;

(5) Share your IP address, browser type, language, access date and time, software and hardware feature information and web records you need, device model, device identification code, operating system, resolution, and telecom operators to The mtj SDK of Beijing Baidu Netcom Technology Co., Ltd. is used for data statistics in order to provide a better service experience;

(6) Share your Crash environment: Crash information and thread stack, ROM/RAM/SD card capacity, network/language and other status App information: package name, version, process name, device information: IMEI and other device identification to Shenzhen The BuglySDK of Tencent Computer System Co., Ltd. is used to judge Crash equipment statistics;

(7)Share your device IP address, device hardware serial number, device MAC address, device installation list, IMEI and other unique device identification codes to the device fingerprint SDK of Beijing Shumei Times Technology Co., Ltd. for device identification to protect you Security of your account;

(8) Share your mobile phone status, network status, read and write external storage to Alipay (China) Network Technology Co., Ltd.’s Alipay SDK for processing and caching your payment order and payment status;

(9) You can use the sharing function in the TianWa Chinese app to share the content you are interested in to WeChat, Moments, QQ, Qzone, Sina Weibo, etc. It is recommended that you understand the privacy policies of third-party services before sharing. It is convenient for you to make prudent decisions.

We will only share your personal information for legal, legitimate, necessary, specific and clear purposes. For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process information in accordance with our instructions, this policy and any other relevant confidentiality and security measures.

2. We will not illegally sell or provide your information to others; we will not provide your information to any third party or use it for any other purpose and purpose, except in the following circumstances:

(1)Disclosure to a third party with your prior consent;

(2)Disclosure to third parties or administrative or judicial institutions in accordance with relevant provisions of the law or the requirements of administrative or judicial institutions;

(3)When we provide services, your information may be used for identity verification, customer service, security prevention, fraud monitoring or archiving and backup, etc., to protect you, other users, our affiliates and the legitimate rights and interests of partners and other trusted third-party suppliers, service providers or agents and the general public to ensure the safety of the products and services we provide to you: prevent, detect or investigate behaviors that are fraudulent, endangering security, illegal or violating agreements, policies or rules with us.

(4)We cooperate with third parties to provide you with services related to the TianWa platform or other network services, and these third parties agree to assume the same responsibility for protecting user privacy as we do;

(5)Other disclosures that should be made in accordance with laws, regulations or policies.

3. We will only publicly disclose your personal information under the following circumstances:

(1)After obtaining your explicit consent;

(2)Disclosure based on law: We may publicly disclose your personal information in the case of laws, legal procedures, litigation or mandatory requirements of the competent government departments.

4.Exceptions for obtaining prior authorization and consent when sharing, transferring or publicly disclosing personal information:

(1)The information is related to the fulfillment of obligations stipulated by laws and regulations by the personal information controller;

(2)The information is directly related to national security or national defense security;

(3)The information is directly related to public safety, public health or major public interests;

(4)The information is directly related to criminal investigation, prosecution, trial, and execution of judgments;

(5)When it is difficult to obtain the authorization of the person, it is necessary to disclose the information in order to protect the life or property of the personal information subject or other individuals;

(6)The information is personal information disclosed to the public by the subject of personal information;

(7)The information is personal information collected from legally publicly disclosed information, such as personal information collected through legal news reports, government information disclosure, and other channels.

5.According to laws and regulations, sharing, transferring or disclosing personal information that has been de-identified and making it impossible for the data recipient to restore and re-identify the information subject does not belong to the external sharing, transfer and public disclosure of personal information. The storage and processing of such data does not require separate consent from you.

IV. How do you manage your own information and account cancellation

In accordance with relevant Chinese laws, regulations or standards, as well as common practices in other countries or regions, we guarantee that you exercise the following rights with respect to your personal information:

1.Inquiry right

Except for exceptions provided by laws and regulations, you have the right to inquire about your personal information. You can check or edit the personal information in your account through "TianWa-My-Avatar-Edit Profile", "TianWa-My-Settings-Account and Security"; modify your password, real-name authentication or Courier address and other information.

2. Right to correction

When you find an error in our processing of your personal information, you can modify the information through the query path.

3.Expurgation Right

You can request us to delete your personal information under the following circumstances: (1)If our handling of personal information violates laws and regulations (2)If we collect and use your personal information without your consent; (3)If our handling of personal information violates the agreement with you (4)If you no longer use our products or services, or if you cancel your account (5)If we no longer provide you with products or services

4.Revocation Right

(1)For the information you voluntarily provide, you can revoke your personal information in your personal account "TianWa Chinese - my - Avatar - edit data" and "TianWa Chinese - my - Settings - account and security" (2)For the information you have authorized us, you can revoke it in "mobile phone - Settings - Privacy - rights management". Please note that the paths may be different in different devices. Please refer to the instructions and guidelines of your device and system developer for details.

5.Cancellation Right

If you decide to stop using TianWa Chinese, you can log off your account. Account cancellation can be realized in "TianWa Chinese - my - Settings - account and security - cancel TianWa Chinese account". After the account is cancelled, the data in the account cannot be recovered, including but not limited to the asset information in the account, such as learning currency, helping currency, coupons, etc. The account information content will also be cleared, including but not limited to the articles and comments published by the account. The logout operation cannot be undone, please apply with caution.

Under the following circumstances, we will not be able to respond to your above request in accordance with the requirements of laws and regulations: (1)Related to the personal information controller's performance of obligations under laws and regulations (2)Directly related to national security and national defense security (3)Directly related to public safety, public health and major public interests (4)Directly related to criminal investigation, prosecution, trial and execution of judgment (5)The personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abuse of rights (6)For the purpose of safeguarding 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 authorization and consent of the person (7)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 and organizations (8)Involving business secrets

V. How do we save your personal data

In principle, the personal information collected and generated during our operations in the people's Republic of China shall be stored in China, and your personal information shall be stored within the storage period specified in the laws, regulations and departmental rules of the people's Republic of China.

VI. How do we protect your personal data

1. We take the security of your personal information very seriously. We make our greatest effort to take all reasonable physical, electronic and management security measures to protect your personal information, and try our best to make sure that your personal information will not be leaked, damaged or lost, including but not limited to SSL, encrypted information storage and access control of data center. We have also adopted strict management on employees or outsourcing personnel who may have access to your personal information, including but not limited to information access control, signing confidentiality agreements with personnel who have access to personal information, monitoring the operation of such personnel, etc.

2.Despite the agreement in paragraph 1 above, please understand that due to various unpredictable or defenseless malicious means, even if we have tried our best to take necessary protective measures, your information may still be leaked, damaged or lost. If you find that your account and password have been or will be disclosed for any reason, you should contact us immediately so that we can take timely countermeasures to prevent or reduce your related losses.

3.In case of business merger or division, the existing business entity will continue to perform the obligation of protection of your information, and we will notify you by announcement, SMS or other written means; If our products and services stop operating, we will stop collecting your information in time and notify you by announcement, SMS, etc. At that time, we will delete or hide your information.

VII Protection of Minors

We value the protection of personal information of minors. If you are a minor under the age of 18, please read this privacy policy carefully under the guidance of your guardian, and use our services with the consent of your guardian And submit your personal information. If your guardian does not agree with this privacy policy, you should immediately stop using TianWa's services and refuse to provide personal information. If you are a minor under the age of fourteen, please inform your guardian to read and accept our 'TianWa Children User Privacy Policy' and seek you before you use the TianWa service and submit personal information The consent and guidance of the guardian. Regarding the personal information of children collected with the consent of the guardian, we will only use or disclose the information to the extent permitted by laws and regulations, the guardian's explicit consent, or the protection of child users. For personal information provided by child users without the consent of the guardian, we will delete the relevant information as soon as possible after receiving the notice from the guardian.

VIII Amendments to This Policy

We may revise this privacy policy from time to time, and the revised privacy policy will be notified to you through the TianWa Chinese or other appropriate means before the revision takes effect. Under these circumstances, if you continue to use our services, you agree to be bound by the revised privacy policy.

IX Dispute Jurisdiction

1.The signing, entry into force, performance, and dispute resolution of this privacy policy shall be governed by the laws of the People's Republic of China.

2.Disputes related to this agreement shall be settled through friendly negotiation. If the negotiation fails, the dispute will be submitted to the court with jurisdiction in the company's place for settlement.

X. Contact us

If you have any questions or complaints, you can contact us through the following ways.

Hangzhou Tianwa Network Technology Co., LTD

Address: 1501 longwei Building, No.17 jugong Road, Binjiang District, Hangzhou, China

email:xingTianWa@163.com

Contact phone number:086-571-86805591or086-571-88002190

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