Duunokid Privacy Policy

1. User Guideline

In order to ensure the proper operation of the basic business functions of user registration, course services, online courses, customer service, and the extended business functions of personalized marketing and providing personalized user experience, we collect and use the following information related to you. If you do not provide the relevant information, you may not be able to register as our user or use and enjoy certain products and services provided by us, or achieve the intended effect of the relevant products and/or services.

1.1 Basic Business Functions

1.1.1 User Registration

In order to use any of Duunokid’s products and/or services, you must become a full Duunokid member. When you register your Duunokid user center account or use the products and/or services provided by Duunokid, you need to provide us with your cell phone number, email address, WeChat / Whatsapp, age information of the student. We will verify the validity of your identity information by means of SMS verification code or email verification code. We will store this data encrypted in a secure server.

1.1.2 Course Service

In order to provide you with perfect products and/or exclusive services, Duunokid will ask you to provide your name, gender, language and your WeChat/Whatsapp information, which Duunokid needs in order to provide you with relevant course services quickly and conveniently, and constantly optimize the service content to better meet your needs. At the same time, according to the relevant laws and policies, you need to complete the information of students and parents in your personal center after logging in, and provide the real names of students and parents.

1.1.3 Online Courses

In order for you to successfully complete the online course, you need to ensure that the network connection is smooth and you have sufficient internet speed. You need to download relevant online class software according to Duunokid. You also need to check whether the network, camera and microphone functions of your device are working before the class. When using these functions, you need to give us access to the camera and microphone functions on your device, and you can use these functions to communicate with the course instructor online and to interact through video. In order to provide you with better products and/or exclusive services, we will record the lessons when you use our products and/or services. You will be able to play back and watch the lessons after they are completed. By turning on these permissions, you are authorizing us to collect and use your personal information to perform the functions described above, and you can revoke the corresponding access permissions at any time in your device, and by revoking the permissions, you are canceling these authorizations, and we will not continue to collect and use your personal information, nor will we be able to provide you with the functions corresponding to these authorizations. If you continue to use these features you will need to re-enable access. Your decision to disable access will not affect the processing of personal information based on your authorization.

1.1.4 Customer Service

To ensure the security of your account, we may use your account information to verify your identity when providing customer service to you; when you need us to provide customer service consultation or after-sales service, we will look for your order information to help you solve your order problems. When you communicate and consult with our customer service, we might record the call or video to ensure the quality of our service.

1.2 Additional Business Functions

1.2.1 Personalized Marketing

In order to enhance the effectiveness of Duunokid’s products, services, and promotions, we may ask you to provide personal information about yourself or your children, including information about your occupation, education, age, gender and your location. Duunokid may use such personal information to create aggregate reports about its user base.

1.2.2 Providing Personalized User Experience

In order to provide better personalized user experience, we will automatically collect information about you or obtain system access based on analysis of your use of our products and/or services, for advertising optimization purposes, including: device or software information, configuration information provided by your mobile device, web browser or other program used to access our products and/or services, the version and device identifier used by the mobile device, and information about the location of the device (IP address, GPS location and WLAN access point, Bluetooth and base station sensor information that can provide relevant information).

1.2.3 How We Use Cookies and Similar Technologies

We, or our third party partners, may collect and use information about you through cookies and store such information as log information. We use our own cookies for the purpose of providing you with a more personalized user experience and products and/or services, and for the following purposes:

1.2.3.1  Cookies help us to identify you as our registered user or to save information you provide to us about your preferences or other information.

1.2.3.2  To analyze your use of our products and/or services. We may use cookies to understand what activities you do with our products and/or services or which pages or products and/or services are most popular with you.

1.2.3.3  Advertising optimization. Cookies and web beacons help us to provide you with advertising related to our products and/or services based on your information.

While we use cookies for these purposes, we may use non-personally identifiable information collected through cookies to analyze how users use our products and/or services and to serve our advertisements. You can refuse or manage cookies through your browser settings, but please note that if cookies and web beacons are deactivated, you may not be able to enjoy the best service experience and certain products and/or services may not work properly. In order to confirm your usage patterns and website usage, our website records the IP address and browser type of your device, user browsing behavior and operational behavior, etc., to help us improve the design and layout format of Duunokid.

2. How We Store Your Personal Information

Your personal information will be stored for the shortest period of time necessary to achieve the purposes necessary for business functions, and beyond such retention period, personal information will be deleted or anonymized. Your personal information will be securely protected to ensure our accordance with local laws, regulations, and this Privacy Policy.

3. How We Share, Transfer and Publicly Disclose Your Personal Information

3.1 Sharing

Currently, we may ask you for your authorized consent to share your personal information in the following cases:

3.1.1 Our Affiliated Companies

We will share your course video information with our affiliates for the purposes of group management and as necessary and reasonable to enable basic business functions and to help us design new business models, evaluate and improve our services, enhance user experience, etc. For this purpose, your personal information may be transferred to the countries or regions where our affiliates are located. Our affiliates will process the service recipient’s information securely and in accordance with applicable laws, including applicable data protection laws.

3.1.2 Partners

We may share your personal information with our partners for business promotion purposes and as necessary and reasonable to jointly market and promote products, services or events that may be of interest to you, to analyze and understand user needs through big data analytics and other means, to design new business models, to evaluate and improve our services, and to enhance the user experience. Any such sharing is subject to confidentiality and security responsibilities.

3.1.3 Our Service Providers

We may appoint third party service providers to manage and/or operate certain features or services on our behalf, and the proper performance of such features or services may require the transfer of information submitted by you. For example, we will share your shipping information and cell phone number with logistics companies based on delivery needs in order to complete the delivery of items; we may also provide your personal information to service providers based on the provision of services to you on a necessary and reasonable basis in order to complete or enhance the services provided to you.

3.1.4 Other Organizations

We may share your personal information with the public in accordance with laws and regulations, or in accordance with the mandatory requirements of government authorities. We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share your personal information, requiring them to handle personal information in accordance with our requirements, this Privacy Policy and any other relevant confidentiality and security measures.

3.2 Public Disclosure

We will only disclose your personal information publicly if:

3.2.1 Your Explicit Consent

We will not transfer your personal information to any company, organization or individual, except in certain cases:

3.2.1.1 Transfer with explicit consent: we will transfer your personal information to other parties after obtaining your explicit consent.

3.2.1.2 In the event of a merger, acquisition or bankruptcy and liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy before we require that company or organization to seek your authorized consent again.

3.2.2 Disclosure Based on Law

We may disclose your personal information publicly if compelled to do so by law, legal process, litigation or governmental authority.

4. Your Rights

4.1 Your Rights with Respect to Your Personal Information

In accordance with the relevant local laws, regulations and standards, as well as the common practices of other countries and regions, we protect your right to exercise the following rights with respect to your personal information.

4.1.1 Access Your Personal Information

You have the right to access your personal information, except for the exceptions provided by laws and regulations. If you wish to exercise your right of data access, you can view or modify your account settings and information by logging into your account.

4.1.2 Correct Your Personal Information

You have the right to ask us to correct personal information we have processed about you if you find it to be incorrect. You can request a correction by using the methods listed under “Accessing Your Personal Information”.

4.1.3 Delete Your Personal Information

If you no longer use our products or services, you may delete your personal information and/or your account by logging onto Duunokid User Center. After you delete your Duunokid account, we will stop providing any Duunokid product or service.

4.1.4 Change The Scope of Your Consent

Each basic business function requires some basic personal information in order to be completed. You may give or withdraw your consent to the collection and use of personal information collected for the purpose of expanding business functions at any time, and you may manage your consent through the device system permission settings. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.

4.1.5 Responding to Your Request

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity first before processing your request. We will respond as soon as we can. If you are not satisfied, you may file a complaint through the customer service hotline on the homepage of the Duunokid website (www.duunokid.com) or through online consultation. For your reasonable requests, we do not charge a fee in principle, but for repeated requests that exceed reasonable limits, we will charge a cost fee as appropriate. We may refuse requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tapes).

4.2 Cases in Which We Cannot Respond to Your Request

We will not be able to respond to your request in the following cases.

4.2.1 Law and Regulation

In connection with the performance of obligations imposed by laws and regulations by the controller of personal information;

4.2.2 National Security

Directly related to national security, national defense security;

4.2.3 Public Interests

Directly related to public safety, public health, and vital public interests;

4.2.4 Crime Investigation

Directly related to crime investigation, prosecution, trial and execution of judgments, etc.;

4.2.5 Prevention of Abuse

Where the controller of personal information has sufficient evidence of subjective malice or abuse of rights by the subject of personal information;

4.2.6 Individual Rights

For the purpose of safeguarding the major legitimate rights and interests of the subject of personal information or other individuals, such as life and property, but where it is difficult to obtain the consent of the individual;

4.2.7 Per Request

When responding to the request of the subject of personal information will result in serious damage to the legitimate rights and interests of the subject of personal information or other individuals or organizations;

4.2.8 Commercial Secrets

Where commercial secrets are involved.

5. Information Security

5.1

We will retain your personal information only for the purposes described in this Privacy Policy and for as long as permitted by law and regulation.

To safeguard the security of your information, Duunokid takes such measures as are reasonably necessary to protect your information given the level of technology available, taking physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure and alteration, including, but not limited to, transport layer data encryption, firewalls and encrypted storage, physical access controls, and information access authorization controls. To this end we have security procedures in place to protect your information from theft by unauthorized access.

5.2

Duunokid also insists on the use of passwords when logging in to prevent unauthorized access to your personal data files and learning records.

5.3

When you use Duunokid products and/or services, please keep your account and password secure, as we will use your account and password to identify you. If you disclose your Duunokid account and its password, you may lose your information and there may be legal consequences against you. If you become aware that your Duunokid account and password have been or will be compromised for any reason, you should contact our customer service immediately so that we can take appropriate action. However, we are not responsible for this until we become aware of the situation and act within a reasonable time.

5.4

In the unfortunate event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation of the security incident and the possible impact, the measures we have taken or will take to deal with it, suggestions for your own prevention and risk reduction, remedial measures for you, etc. We will inform you by email, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish the announcement. At the same time, we will also report the disposition of personal information security incidents in a timely manner in accordance with the requirements of regulatory authorities.

6. Protection of Children's Personal Information

6.1

We understand that the personal information of students that we collect and process may come from minors under the age of 14 (“children”), and we attach great importance to the protection of children’s personal information. In this regard, according to the Hong Kong Personal Data Privacy Office’s relevant provisions on the protection of personal information in Hong Kong, we make the following commitments:

6.1.1

Children shall not create their own Duunokid User Center accounts without the consent of their guardians;

6.1.2

Before collecting children’s personal information, we will remind children and their guardians to read this Privacy Policy to inform them of the scenarios in which we collect and process children’s personal information, and the information security protection measures we have taken;

6.2

We will collect and process children’s personal information only with the consent of the children’s guardians, and we will process such personal information only with the consent of the guardians or when necessary for the protection of the children in strict accordance with the law. We have provided children and their guardians with the means to refuse the above collection and processing practices. Children and their guardians may contact us through the website to express explicit refusal, and we will process it after correct identification.

6.3

In general, we will not collect personal information that is not related to the realization of the corresponding functional scenarios described in this Privacy Policy; if, due to business needs, it is necessary to collect and process information beyond the agreed purpose and scope, we will specifically inform the child’s guardian and obtain his or her consent.

6.4

We will strictly set the information access rights under different functions to control the scope of children’s personal information knowledge.

6.5

Children and their guardians have the same rights as the subjects of personal information as described in this Privacy Policy.

6.6

To safeguard the security of children’s personal information in accordance with the requirements of domestic laws, regulations and standards related to personal information, and the storage requirements and protection measures shown in this Privacy Policy.

6.7

To better protect the information protection of minors, we will designate a person responsible for the protection of children’s personal information, if you have any relevant questions, you can send an email to contact us.

7. Scope of Application of Privacy Policy

This Privacy Policy applies to all of our products and/or services, with the exception of certain specific products and services. These specific products and services will be subject to a specific privacy policy. The specific privacy policy for certain specific products and services will be more specific about how we use your information in connection with those products and services. The privacy policy for that particular product and/or service forms part of this Privacy Policy. In the event of any inconsistency between the privacy policy of the particular service in question and this Privacy Policy, the privacy policy of that particular product and/or service will apply.

Please note that this Privacy Policy applies only to the information we collect, store, use, share, transfer, and publicly disclose. Unless otherwise expressly stated in this Privacy Policy, this Privacy Policy does not apply to:

7.1

Information collected through third party services accessed through our products and/or services, including any third party websites;

7.2

 Information collected through other companies or organizations that serve advertisements in our products and/or services.

Please be aware that if you provide your personal information to a third party when you visit that third party’s website or use that third party’s products and/or services, your information shall be subject to that third party’s privacy statement or similar policy, and we shall not be liable for any improper use or disclosure of information provided by you by any third party, regardless of whether your access to or browsing of said website, software, or use of its products and/or services is based on a link or lead from Duunokid.

8. Changes to the Privacy Policy

We may revise the terms of this Privacy Policy from time to time, and such revisions form part of this Privacy Policy. If such revisions result in a material reduction of your rights under this Privacy Policy, we will post the changes to this Privacy Policy by prominently displaying them on our home page or by other means we deem appropriate (including sending you an email or otherwise notifying you) before the revisions become effective. In such events, by continuing to use our products and/or services, you agree to be bound by this Privacy Policy, as amended.