Violin ELF Privacy Policy
Thank you for using Violin ELF!
Violin ELF (hereinafter referred to as "we") has formulated this privacy policy in accordance with the "Network Security Law of the People's Republic of China", "Information Security Technology Personal Information Security Specification" (GB/T 35273-2017) and other relevant laws, regulations and technical specifications.
In order to better protect your personal information, it is recommended that you read the "Violin ELF Privacy Policy" carefully, especially the terms in black and bold. If you have any objections or questions about the terms of this Privacy Policy, you can communicate with us through the contact information published in Article 10 "Contact Us" of this " Violin ELF Privacy Policy".
"Violin ELF Privacy Policy" Table of Contents
I. Introduction
II. About us
III. Explanation of terms
IV. How we collect and use your personal information
V. How we share, transfer and publicly disclose your personal information
VI. About the use of cookies and similar technologies
VII. Our storage and protection of your personal information
VIII. Your right to manage personal information
IX. Our protection of minors
X. Contact us
XI. How to update this policy
XII. Dispute resolution
I. Introduction
1. This "Violin ELF Privacy Policy" (hereinafter referred to as "this Privacy Policy") applies to all products of Violin ELF, including the sites, iOS applications, and Android applications.
2. Please read and fully understand the entire contents of this Privacy Policy before using various products and/or services of Violin ELF. Once you use or continue to use Violin ELF's products/services, you agree to our use and processing of your relevant information in accordance with this Privacy Policy.
3. We may revise this Privacy Policy from time to time in accordance with laws and regulations or business adjustments. When this Privacy Policy is changed, we will show you the changed content by means of prompts in prominent positions or push notifications, messages, etc. after the version is updated.
4. You need to understand that we will collect, use, process and store your personal information in accordance with the changed Privacy Policy only after you confirm and agree to the changed Privacy Policy; you have the right to refuse to agree to the changed Privacy Policy However, please be aware that once you refuse to agree to the changed privacy policy, it may cause you to be unable or unable to continue to use the relevant services and functions of Violin ELF, or to achieve the service effect we intend to achieve.
II. About us
1. Violin ELF is provided by Beijing LiYueXingzhi Education Technology Co., Ltd. (hereinafter referred to as "Beijing LiYueXingzhi") and its affiliates to provide product operations and services.
2. Affiliated companies refer to companies that control Beijing LiYueXingzhi Education Technology Co., Ltd., are controlled by Beijing LiYueXingzhi Education Technology Co., Ltd. or are under common control with Beijing LiYueXingzhi Education Technology Co., Ltd. mechanism. Control refers to the ability to directly or indirectly affect the management/operation of the controlled object through ownership, voting shares, contracts, actual operational associations or other legally recognized means.
3. The basic information of our main operating entities is as follows: Beijing LiYueXingzhi Education Technology Co., Ltd. was established on May 23, 2019, and its registered address is 114, 1st Floor, Building 6, No. 41, Funan Road, Longwantun Town, Shunyi District, Beijing, China .
III. Explanation of terms
Unless otherwise agreed, the terms used in this Privacy Policy usually only have the following definitions:
1. Personal information (from GB/T 35273-2017 "Information Security Technology Personal Information Security Specification"): refers to electronic or other records that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information. The personal information involved in this Privacy Policy includes basic information of natural persons (including name, birthday, gender, address, phone number, email address), personally identifiable information (including ID number), personal biometric information (including fingerprints, facial features) ), network identification information (including system account numbers, IP addresses, email addresses, and passwords, and password-protected answers related to the foregoing), personal property information (including bank account numbers, passwords, transaction and consumption records, virtual currency, virtual transactions , redemption code and other virtual property information), address book information, personal Internet access records (including website browsing records, software usage records), personal commonly used device information (including hardware serial numbers, hardware models, device MAC addresses, operating system types, software lists , unique device identifier), personal location information (including approximate geographic location, precise location information). The specific types of personal information we actually collect are as described below.
2. Personal sensitive information (from GB/T 35273-2017 "Information Security Technology Personal Information Security Specification"): means that once leaked, illegally provided or abused, it may endanger personal and property safety, and easily lead to personal reputation, physical and mental health damage. Personal information such as damage or discriminatory treatment. The personal sensitive information involved in this Privacy Policy includes your personal property information, personal identification information (including ID number), personal biometric information, network identification information, address book information, precise positioning information, and shipping address. The types of personal sensitive information we actually collect are subject to the description below.
3. Device: means a device that can be used to access our products and/or services, such as a desktop computer, laptop, tablet or smartphone.
4. Unique Device Identifier (Unique ID or UUID): A string of characters programmed into a device by the device manufacturer that can be used to uniquely identify the corresponding device (for example, the IMEI number of a mobile phone). Unique device identifiers are used for a variety of purposes, among them serving advertisements when cookies cannot be used (eg in mobile applications).
5. IP Address: Every device connected to the Internet is assigned a number called an Internet Protocol (IP) address. These numbers are usually assigned by geographic area. An IP address can often be used to identify where a device is located when it is connected to the Internet.
6. SSL: SSL (Secure Socket Layer), also known as Secure Socket Layer, is a security protocol implemented on the Transmission Communication Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which use public key and symmetric key technology to achieve the effect of information confidentiality.
7. Cookies: Cookies are small files containing strings of characters that are sent and stored (usually encrypted) on your computer, mobile device or other device when you log in and use a website or other web content. Cookie-like technologies are other technologies that can be used for similar purposes as cookies, such as: WebBeacon, Proxy, embedded script, etc.
8. Account: When you register an account and provide us with some personal information, you can better use our services. When you visit Violin ELF, the system will use these account information to authenticate you to prevent unauthorized personnel from accessing your account.
9. De-identification/anonymization: refers to the process of technical processing of personal information so that the subject of personal information cannot be identified without additional information, and the processed information cannot be recovered.
10. Server logs: Usually, our server will automatically record the web page requests you make when you visit the website. These "server logs" typically include your web request, internet protocol address, browser type, browser language, date and time of the request, and one or more cookies that uniquely identify your browser.
IV. How we collect and use your personal information
1. In accordance with laws and regulations and in accordance with the principles of legitimacy, legality and necessity, Violin ELF collects and uses the personal information that you actively provide during the use of the service or that is generated due to the need for products and/or services. If we want to use your personal information for other purposes not specified in this Privacy Policy, or use the collected information for other purposes based on a specific purpose, we will inform you in a timely and reasonable manner, and before using it Ask for your consent again.
2. There are two types of your personal information that we collect and use: the first type: the information necessary for the core business functions of our products and/or services: such information is necessary for the normal operation of the products and/or services , you must authorize us to collect it. If you refuse to provide it, you will not be able to use our products and/or services normally; the second type: information that may be collected for additional business functions: this information is required for non-core business functions, and you can choose whether to authorize us to collect it . If you refuse to provide it, it will result in the failure of additional business functions or the effect we intend to achieve, but will not affect your normal use of core business functions.
3. We need to remind you that if a function or product/service that needs to collect your personal information cannot be described in this privacy policy, we will update this policy, page prompts, pop-up windows, website Announcements and other means will separately explain the purpose, content, use method and scope of the information collection to you, and provide you with a way to choose your own consent, and collect it after obtaining your express consent. During this process, if you have any doubts about related matters, you can contact us through the methods provided in Article 10 of this Privacy Policy, and we will answer you as soon as possible.
4. Usually, we will collect and use your personal information in the following scenarios:
4.1 Account Registration
(1) When you register and log in to the Violin ELF account, you need to follow our guidelines to complete a series of registration procedures. During this process, you need to provide us with the following information: account nickname, mobile phone number or email (personal sensitive information, use to accept the verification code to match the personal identity). Only by providing the above-mentioned true and accurate information can you successfully register a Violin ELF account and use the core functions of the product and/or service. If you choose not to provide the above-mentioned necessary information for realizing the core product functions of Violin ELF, it may cause us to be unable to provide you with the core product functions.
(2) At the same time, you need to understand that the matching result of mobile phone number or email address and verification code belongs to your personal sensitive information. We collect such information based on the relevant requirements of laws and regulations. If you refuse to provide it, you may not be able to register an account, and use related product functions. Please consider carefully before choosing whether to provide it.
4.2 Customer Service
When you file a complaint, appeal or inquire with Violin ELF, for the security of your account and system, we may require you to provide your account information first and match your previous personal information to verify your user identity. At the same time, in order to facilitate contacting you or help you solve problems, we may also require you to provide personal information (personal sensitive information) such as name, mobile phone number, email and other contact information. In addition, we will also collect your communication with us (including text/pictures/audio/video/call records) and other necessary information related to your needs. We collect this information to investigate facts and help you solve problems. If you refuse to provide the above information, we may not be able to give you timely feedback on the results of complaints, appeals or consultations.
4.3 For other reasonable and necessary purposes
(1) As mentioned above, if a function or product/service that needs to collect your personal information cannot be described in this Privacy Policy, or we exceed the stated purpose and purpose of collecting your personal information and If it is directly or reasonably related, before collecting and using your personal information, we will explain to you separately by updating this privacy policy, page prompts, pop-up windows, in-site letters, website announcements or other means that are convenient for you to know, and Provide you with a means of choosing your own consent, and collect and use it with your express consent.
(2) You understand and agree that we can collect and use your personal information without your authorization under the following circumstances:
a) related to national security and national defense security;
b) related to public safety, public health, and major public interests;
c) Directly related to criminal investigation, prosecution, trial and execution of judgments;
d) It is difficult to obtain your consent for the protection of your or other personal life, property and other major legitimate rights and interests;
e) The collected information is disclosed to the public by you or collected from legal public channels (such as legal news reports, government information disclosure, etc.);
f) Necessary in accordance with the execution and performance of relevant agreements or other written documents with you;
g) Necessary for maintaining the safe and stable operation of our products and/or services, such as finding and disposing of faults in products and/or services;
h) Other circumstances as required by competent authorities, laws and regulations, etc.
V. How we share, transfer and publicly disclose your personal information
1. Share
We attach great importance to the protection of your personal information. Your personal information is an important basis and part of us to provide you with products and/or services. For your personal information, we will only use it within the purpose and scope described in this Privacy Policy or collect and use according to the requirements of laws and regulations, and keep it strictly confidential. Under normal circumstances, we will not share your personal information with any companies, organizations and individuals, with the following exceptions:
1.1 Your express authorization or consent has been obtained in advance;
1.2 It is necessary to share your personal information in accordance with applicable laws and regulations, legal procedures, government mandatory orders or judicial rulings;
1.3 To the extent required or permitted by law, it is necessary to provide your personal information to a third party in order to protect the interests, property or safety of Violin ELF and its users or the public from damage;
1.4 Your personal information may be shared among our affiliates. We will only share necessary personal information and such sharing is also governed by the purpose of this Privacy Policy Statement. If the affiliated company wants to change the purpose of processing personal information, it will ask for your authorization again;
1.5 In order to provide you with better products and services, some of our services will be provided by authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. At the same time, we will sign strict confidentiality agreements with our partners, requiring them to process your personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures. Our partners are not authorized to use the shared personal information for any other purpose. If you refuse our partners to collect personal information necessary to provide services when providing services, you may not be able to use the third-party services on our platform. Usually our partners have the following categories:
(1) Service providers that provide functional support for our products and/or services: such as payment institutions that provide payment services, the purpose of our sharing information is only to realize the functions of our products and/or services;
(2) Third-party merchants on our platform: In order to meet your needs for purchasing products or services (including enjoying after-sales service), we will share your order information and transaction-related information with third-party merchants on our platform.
(3) Third-party SDK service providers: Our products may include third-party SDKs or other similar applications. If you use such services provided by third parties on our platform, you agree to be directly collected by them and processing your information (e.g. in the form of embed codes, plugins, etc.). For example: if you use a Huawei mobile phone, the Huawei Push SDK needs to read your IMEl information to push/deliver notifications in the notification bar (if you use another brand, the mobile phone brand also has a similar Push SDK); if you use Alipay for payment , in order for you to complete the transaction and achieve the purpose of the transaction, the Alipay SDK needs to read your IMEl information; you share the content of Violin ELF to a third-party platform, such as Weibo, and its SDK may collect the information you provide; we may The umeng SDK will be used to count the activity of users using products or services, and the umeng SDK may need to read your device information; we will use the Tencent bugly SDK to count crashes or no response during your use of our products or services, etc. In some cases, the bugly SDK may need to read your device information. The collection and processing of information by the aforementioned service providers abide by their own privacy terms and do not apply to this policy. In order to maximize the security of your information, we recommend that you review the privacy policy of any third-party SDK services before using them. In order to protect your legitimate rights and interests, if you find that these SDKs or other similar applications are at risk, it is recommended that you immediately terminate the relevant operations and contact us in time.
2. Transfer
We will not transfer your personal information to any company, organization or individual without your express consent. In the event of a merger, acquisition or bankruptcy liquidation, the transfer of personal information may be involved. In this case, we will require new companies and organizations that hold your personal information to continue to be bound by this Privacy Policy. If there is any change in the collection and processing of personal information stipulated in this Privacy Policy, the company or organization will seek your authorization and consent again.
3. Public Disclosure
3.1 Public disclosure is the act of releasing information to the society or to an unspecified group of people. We will not publicly disclose your personal information, except for necessary disclosures due to the need to announce penalties for illegal accounts, fraudulent acts, etc., and to desensitize and display relevant information when announcing the list of winners. If there are reasonable reasons for public disclosure, we will inform you of the purpose and type of the publicly disclosed information before the public disclosure (if it involves your personal sensitive information, we will also inform you of the content of the sensitive information involved) and Public disclosure shall be made after obtaining your authorization and consent, unless otherwise stipulated by laws and regulations or otherwise stipulated in this policy.
3.2 For your personal information disclosed publicly, we will prudently review its legitimacy, rationality and legality as soon as we receive the application for public disclosure, and take the strictest personal information security measures during and after public disclosure. Protective measures and means to protect it.
4. Exceptions to Sharing, Transfer, and Public Disclosure of Your Personal Information.
Please be aware that in accordance with the provisions of laws and regulations, in the following cases, sharing, transferring and publicly disclosing your personal information does not require your prior authorization and consent:
4.1 Those directly related to national security and national defense security;
4.2 Directly related to public safety, public health and major public interests;
4.3 Directly related to criminal investigation, prosecution, trial and execution of judgments; or in accordance with the requirements of laws and regulations, the requirements of administrative organs or public prosecutors and other competent authorities;
4.4 In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain your consent;
4.5 Personal information is disclosed to the public by you or collected from legally disclosed channels (such as legal news reports, government information disclosure, etc.);
4.6 Necessary in accordance with the signing and performance of relevant agreements or other written documents with you;
4.7 Other situations stipulated by laws and regulations.
VI. About the use of cookies and similar technologies
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 website visit habits, your browsing information, your login information, cookies and similar technologies collected, This type of information is necessary for you to use our products and/or services, simplify your repetitive steps (such as registration, login), facilitate your viewing of usage history (such as video viewing history), and provide you with more tailored to your personal needs service content and content that you may be more interested in, protect your information and account security, improve our products and services, etc.
2. If you reject our use of cookies and similar technologies to collect and use your relevant information, you can manage, (partly/fully) reject cookies and/or through the settings of your browser on the premise that your browser has this function. or similar technologies; or delete cookies and/or similar technologies already stored on your computer, mobile device or other device so that we cannot track your personal information in whole or in part. For more information on how to change your browser settings, please check the relevant settings page of the browser you are using. You understand and know that some of our products/services can only be realized by using cookies or similar technologies. If you refuse to use or delete them, you may not be able to use our related products and/or services normally or fail to pass the our products and/or services provide the best service experience, but may also have a certain impact on your information protection and account security.
VII. Our storage and protection of your personal information
1. Information Storage
1.1 Storage location: In accordance with the provisions of laws and regulations, we will only store the collected personal information about you in the territory of the People's Republic of China. At present, we do not currently have the scenario of cross-border storage of your personal information or provision of personal information overseas. If it is really necessary to transfer data across borders, we will clearly inform you separately (including the purpose of data export, recipient, method and scope of use, content of use, security measures, security risks, etc.), and obtain your consent. Authorized consent, we will ensure that the data recipient has sufficient data protection capabilities to protect your personal information.
1.2 Storage period: We keep your personal information for the shortest period necessary to provide you with products and services. For example: when you use our registration and membership functions, we need to collect your mobile phone number and After you provide it and while you are using this function, we need to keep your mobile phone number in order to provide you with this function normally and ensure the security of your account and system. In addition, we may keep your relevant information for the necessary period specified by relevant laws (for example, the Electronic Commerce Law stipulates that the storage time of commodity and service information and transaction information shall not be less than three years from the date of completion of the transaction).
After the above storage period is exceeded, we will delete or anonymize your personal information.
2. Information Protection
2.1 The security of your personal information is of the utmost importance to us. We will strictly abide by relevant laws and regulations and take reasonable and feasible measures recognized by the industry to protect your personal information. Protect information from unauthorized access, disclosure, use, modification, and avoid damage or loss of information.
2.2 We use industry-standard security measures to protect the personal information you provide to prevent unauthorized access, public disclosure, use, and modification of data, and to prevent data damage or loss. We will take all reasonably practicable steps to protect your personal information. For example, data is encrypted and protected using SSL; we have established an access control mechanism to ensure that only authorized personnel can access personal information; we hold security and privacy protection training courses from time to time to enhance employees' awareness of the importance of protecting personal information.
2.3 In order to prevent the occurrence of security accidents, we have established a special data security department and formulated a proper early warning mechanism and emergency plan. In the event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions and suggestions that you can take to prevent and reduce risks on your own. Be aware of your remedial measures and activate contingency plans immediately to minimize damage. We will promptly notify you of the incident by phone, push notification, etc.
VIII. Your right to manage personal information
We understand your concern about your personal information, and do our best to ensure your rights to access, correct, delete, and withdraw authorization for your personal information, so that you have adequate capabilities to protect your privacy and security. Your rights include:
1. You have the right to access your personal information
You can check the relevant personal information you have provided to us by following the relevant instructions (or settings) of the products and services we provide. include:
1.1 Account information: You can log in to your personal center at any time through the relevant product page to access the personal information in your account, including: avatar, nickname, UID, QR code business card, gender, date of birth, personal signature, etc.;
1.2 Usage information: You can check your usage information at any time through the relevant product pages, including: dynamic publishing content, submission content, collection records, historical records, order information, address information, billing records, etc.;
1.3 Other information: If you encounter operational problems during your visit, for example, you need to obtain other personal information that you cannot know above, you can contact us through the methods provided in this Privacy Policy.
2. Your right to correct/amend your personal information
When you find that the personal information you have provided to us is incorrect, incomplete or updated, you can correct/amend your personal information in our products and/or services.
2.1 For some of your personal information, we provide you with operation settings on the relevant function page of the product, and you can directly correct/modify it.
2.2 For the difficulties you encounter in the process of exercising the above rights, or other services that may not be able to provide you with online self-correction/modification at present, your identity has been verified, and the correction/modification does not affect the objectivity and accuracy of the information You have the right to correct or revise the incorrect or incomplete information, or in specific cases, especially when the data is incorrect, submit your correction/amendment application to us through measures such as feedback and error reporting published by us , require us to correct or amend your data, unless otherwise provided by laws and regulations. However, for security and identification reasons, you may not be able to modify some of the initial registration information submitted during registration.
3. You have the right to delete your personal information
3.1 For some of your personal information, you can also voluntarily delete the information you provide through the functional pages of the relevant products and services we provide. Once you delete, we will delete or anonymize such information, unless otherwise required by laws and regulations.
3.2 When the following situations occur, you can directly ask us to delete your personal information, unless it has been anonymized or otherwise stipulated by laws and regulations:
(1) When our handling of personal information violates laws and regulations;
(2) When we collect and use your personal information without your consent;
(3) When our handling of personal information violates our agreement with you;
(4) When you cancel your Violin ELF account;
(5) When we terminate the service and operation.
4. You have the right to withdraw your authorization for personal information
As mentioned above, some functions of the products and services we provide require your permission to use the device (including: location, camera, microphone, schedule, etc., which are subject to the actual functions obtained by the product). You may revoke (or stop) further authorization of this permission at any time after authorization. For example, you can turn off your authorization to your phone's photo album through "Settings-Privacy-Photos" in your iOS device. You can also permanently withdraw all authorization for us to continue to collect your personal information by canceling your account. You need to understand that after you withdraw your authorization, we cannot continue to provide you with the specific functions and/or services corresponding to the withdrawn authorization. However, your decision to withdraw your authorization will not affect the previous processing of personal information based on your authorization.
If you have any questions about the disposal of your personal information, you can communicate with us through the contact information published in Article 10 "Contact Us" of this Privacy Policy.
IX. Our protection of minors
1. Minors should obtain the consent of their guardians before using our products and/or services. If you are a minor, before using our products and/or services, you should read this Privacy Policy together under the supervision and guidance of your guardian, and you should use our products and/or services, submit personal information. We protect the personal information of minors in accordance with the relevant national laws and regulations, and will only collect, use or publicly disclose the personal information of minors when permitted by laws and regulations, with the explicit consent of the guardian or necessary to protect your rights and interests.
2. If you are the guardian of a minor, when you have questions about the personal information of the minor under your guardianship, you can communicate with us through the contact information published in Article 10 "Contact Us" of this Privacy Policy solve. If we discover that personal information of minors has been collected without the prior consent of a verifiable guardian, the relevant data will be deleted as soon as possible.
X. Contact us
1. If you have any questions, inquiries or complaints about the content of this "Violin ELF Privacy Policy" or issues related to privacy protection encountered when using our services, you can contact us in any of the following ways :
1.1 You can submit feedback online through Violin ELF;
1.2 You can contact us by sending an email to our support@yuejingling.com customer service email;
2. After receiving your comments and suggestions, we will reply to you as soon as possible within 30 days after verifying your user identity. In addition, you understand and acknowledge that we will not be able to respond to your request in the following circumstances related to personal information:
2.1 Related to national security and national defense security;
2.2 Related to public safety, public health, and major public interests;
2.3 Related to criminal investigation, prosecution and trial;
2.4 There is sufficient evidence to show that you have subjective malice or abuse your rights;
2.5 Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
2.6 Involving commercial secrets;
2.7 Other situations stipulated by laws and regulations.
XI. How to update this policy
1. In order to provide you with better services, we will update the terms of this "Privacy Policy" according to product updates and relevant requirements of laws and regulations, and such updates constitute part of this "Privacy Policy". We will not reduce your rights under this policy without your express consent. If such updates result in a substantial reduction or major change in your rights under this Privacy Policy, we will notify you in a prominent position or send you a push message or otherwise notify you before this policy takes effect, if you continue to use Our service means that you fully read, understand and agree to be bound by the revised "Privacy Policy".
2. Significant changes include but are not limited to:
2.1 Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;
2.2 Significant changes have taken place in our ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
2.3 The main objects of personal information sharing, transfer or public disclosure have changed;
2.4 Significant changes in your rights to participate in the processing of personal information and the manner in which it is exercised;
2.5 Changes in our responsible department, contact information and complaint channels for handling personal information security;
2.6 When the personal information security impact assessment report indicates that there is a high risk.
XII. Dispute Resolution
1. The interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of the Mainland of the People's Republic of China. For any disputes arising from this Privacy Policy and our handling of your personal information, you agree to submit to the Beijing Arbitration Commission for arbitration; the arbitration shall be final and legally binding on both parties.
2. If you think that our processing of personal information damages your legitimate rights and interests, you can also choose to report to the relevant government department.
3. The title of this Privacy Policy is for convenience and reading only, and does not affect the meaning or interpretation of any provisions in the text.
