Introduction

Han Language International HK Limited (Hereinafter referred to as " Han Language International " or "we") is well aware of the importance of Privacy Policy. HanBook is the learning app for searching and studying Chinese. "HanBook Privacy Policy" (hereinafter referred to as "this policy") applies to the HanBook service we provide. We are committed to safeguarding the privacy of our app users under the age of 18, please read this policy with a legal guardian, and pay special attention to the terms. This policy applies where we are acting as a data controller with respect to the personal data of our app users; in other words, where we determine the purposes and means of the processing of that personal data. We can provide you with access, correction, deletion and protection of this personal data, so as to better protect your rights and interests.

Please read and understand this policy carefully before using HanBook service to make appropriate choice. Once you use or continue to use our products or services after we update this policy, it means that you agree to this policy and agree us to process your personal data in accordance with this policy.

FIRST:

How we collect and use your personal data

We collect your personal data mainly for you and other users to use HanBook service more easily and more satisfactorily. And that data helps us achieve that.

1、Personal data you provide

1.1 When you login to HanBook account or use HanBook service, you provide us with personal data, including your email account, and you can voluntarily choose to fill in your nickname, profile picture, gender, age, education, school and other basic data. If you only need to browse and understand HanBook, you do not need to log in to your account and provide the above data. If you do not provide this data, it will not affect your use of HanBook's basic functions;

1.2 The shared personal data you provide to other parties through the HanBook service, and the personal data stored when you use the HanBook service.

Please note that if you upload or publish your personal data in the public area visible to other users in the HanBook service, or disclose your personal data in your response to the data uploaded or published by others, the personal data may be exposed to others. As long as you do not delete the personal data that you have disclosed or shared, the personal data may remain in the public domain; even if you delete the shared personal data, the personal data may still be owned by other users or third parties that are not under our control. The third parties independently cache, copy or store, or are kept in the public domain by other users or such third parties. If you disclose or share your personal data through the above-mentioned channels, we will not be liable for the leakage of your personal data. Therefore, we remind and ask you to carefully consider whether to disclose or share your personal data through the above-mentioned channels.

2、We will collect and use your personal data for the following purposes:

2.1 Help you with your HanBook account, register and login.

In order to provide you with a full function HanBook, you need login with Google、Facebook、Apple and Line account or register an account with your email. The VIP features including Flashcards、professional assessment on Pinyin pronunciation and analysis of handwriting stroke orders. The systematic AI will offer specific guidance for one’s learning. If you only use HanBook for searching and looking up words, there is no need to register an account.

2.2 Customer Service

In accordance with laws, regulations and regulatory requirements, or when you contact us, our customer service or after-sales service may require you to provide email or account information to verify your identity in order to solve your problem.

2.3 We may process data about your use of service and website, the usage data. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, as well as data about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our services.

2.4 We may process your data included in your personal profile on our website or app. The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent.

2.5 We may process data that you provide to us for the purpose of subscribing to our newsletters or inviting friends to join HanBook or sharing your learning experience on social media. The notification data may be processed for the purposes of sending you the relevant notifications or newsletters. The legal basis for this processing is your consent. And also collect and process data when you browse HanBook website.

We may process data concerning devices used to access our app (“device data”). This data may include device ID names, models, operating system versions, IP addresses, crash logs, and hashed hardware serial numbers. The source of this data is data provided to our app by your device’s operating system. This data may be processed to improve our products and services, prevent fraud, and retrieve past purchase details when they cannot be recovered from your email address. The legal basis for this processing is our legitimate interests, namely improving our products and services, fraud prevention, and customer support.

3、To Maintain the normal operation of basic functions

During your usage of our services, in order to identify the abnormal status of your account, understand the suitability of the product, and provide you with browsing, searching, logging in, viewing and editing personal information, and watching courses, we may automatically collect and store information about your usage. Information about services and usage methods and linking these data, including:

3.1 Log data: When you use our services, we may automatically collect your detailed usage of our services and save them as relevant web logs. Log information includes your login account, search query content, IP address, browser type, network environment, language used, access date and time, and web browsing records you visit, push notifications, crash records, length of visit, refresh Record, publish record, follow, subscribe, bookmark and share.

3.2 Device information: We may receive and record the device-related information (including device identifier (IMEI/MAC/OPEN UDID), Serial, SIM card IMSI identification code) according to the specific permissions granted by you during app installation and usage , Device model, operating system and version, client version, device resolution, package name, device settings, process and software list, Android ID, IDFA, UUID, software and hardware feature information), information about the location of the device (including IP Address, GPS location, and WLAN access point, Bluetooth and base station sensor information that can provide relevant personal information). At the same time, in order to collect the above basic personal device information, we will apply for permission to access your device information. We collect this information to provide you with our basic services and functions. If you refuse to provide the above permissions, you may not be able to use the product and service.

4、Provide you with courses or services

4.1 Sharing and publishing of personal information: When you use HanBook service, upload and/or publish personal information, and perform related actions (for example: the text/picture you enter in HanBook to be translated, follow-up audio, submit coursework content, and Commodity/service evaluation), we will collect your personal information uploaded, published or formed, and have the right to display your nickname, avatar and published content.

4.2 When you use OCR、handwriting and pronunciation guidance, HanBook will collect and store the pictures and voice information you upload, and our relevant recognition program will process and analyze these data and return the corresponding text results.

4.3 Help and Feedback

When you encounter problems with HanBook or have good suggestions or comments, you can contact us through the online form or email. We will collect information such as your email or IP address.

5、Personal data we may collect indirectly

We may obtain the account information (avatar, nickname, login time) you authorized to share from a third party and verify your account with HanBook after you agree to this policy, so that you can log in directly through the third-party account and use our products or services. We will collect and use your personal data in compliance with relevant laws and regulations, and in accordance with agreements with affiliates or third-party partners, and we are confident that the source of the personal information provided by them is legal.

6、Push and notifications for providing service

6.1 About Push

Based on the information you provide to us and the information we collect through indirect means (including your browsing and search cookies, device information, location information, email), we may perform recommendation algorithm modeling, programmatic advertising recommendation algorithm modeling, user behavior analysis, and user profile based on the combination of one or more of the above information to extract your browsing , Search preferences, behavior habits, and location information related features, so as to provide you with personalized content that better meets your needs. We may also send you marketing information via email or other methods based on feature tags to provide or recommend the following services of HanBook and its partners: including: online education services, translation, speech recognition and speech synthesis development platform services, online advertising and other social media service.

6.2 About Notification

We may send notices to you when necessary (for example, when we suspend the service, change, or terminate the provision of the service due to system maintenance). If you do not want to receive notifications, you can unsubscribe notifications; except in the case where we send messages in accordance with legal regulations or service agreements.

7、Security Guarantee

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. In addition to the specific purposes for which we may process your personal data set out in above section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8、Notice

HanBook apps are also distributed through Apple Inc.’s “App Store” and through Alphabet Inc.’s “Google Play”, but we do not share any personal data with them

9、You understand and agree that HanBook service may require you to open specific access rights in your device to realize the collection and use of personal data involved in these rights:

9.1 If we access your location information, it is to provide you with specific product services that are more in line with your needs;

9.2 If we access your camera, it is for you to use the camera to scan the code and take pictures, which is used to login, to upload avatars, to make picture comments, to use OCR and translate functions;

9.3 If we access your album, it is to enable you to upload the photos, pictures or videos in your device, so that to change your avatar (If you do not agree to enable the storage permission, you will not be able to use the "Album" function to upload your avatar, but you can use the "Take photo" function to upload your avatar by enabling the camera permission), to comment/share;

9.4 If we access your microphone, it is to enable you to use voice translation functions, voice comments, voice interaction with customer service, and voice teaching interaction functions. In these functions, we will collect your recording content to identify your specific demand;

9.5 When you access AI and live course service in HanBook, a video cache file will be generated, to enable you to experience our course services more smoothly or help you learn offline directly.

9.6 If we have access to your floating window authority, it is to enable you use OCR

SECOND: How we use COOKIES

1、COOKIES

COOKIES enables us to serve you better and faster, and makes your experience on HanBook website and app more personalized. However, you should be able to make settings and manage how COOKIES are accepted and stored by your browser.

We use COOKIES for the following purposes:

1.1 Remember your identity. COOKIES helps us to recognize your identity as our registered user, or save your preferences or other personal information you provide to us;

1.2 Analyze your usage of our services.

1.3 Advertising optimization.

2、Pixel Labels and tags of websites

In addition to Cookies, we also use other similar technologies such labels and pixel tags on our websites. For example, the email we send you may contain a link to our website, if you click on that link, we will track that click to help us understand your preferences so that we can proactively improve our customer service. With the pixel tags in the E-mail, we can tell if the E-mail has been viewed. If you do not wish your activities being tracked in this way, you may unsubscribe from our email list at any time.

THIRD: How we Retain, Store and delete your personal data

1、We retain your Personal data only for the period necessary for the purposes stated in this Policy and for the period required by laws, regulations and regulations.

If your personal data exceeds the retention period, HanBook will delete or anonymize it as required by applicable laws (if you are under 18, HanBook will process your personal data in accordance with relevant laws and regulations after your personal data exceeds the retention period). If the relevant requirements cannot be deleted due to special circumstances, the platform will explain this part of matters to you. If we terminate the Service or operation, we will stop the activities of continuing to collect your personal information in a timely manner, and we will comply with the relevant laws and regulations to inform you in advance, and after the termination of the Service or operation, we will delete or anonymize your personal information, unless otherwise stipulated by laws, regulations or regulatory authorities.

2、The personal information collected and generated during our operations within the territory of the People's Republic of China is stored in the territory of China. Except in the following situations:

2.1 There are clear provisions in laws and regulations;

2.2 Obtain your authorization and consent;

2.3 The products and services you use involve cross-border, and we need to provide your personal information overseas. In response to the above circumstances, we will ensure that your personal information is adequately protected in accordance with this policy and national laws and regulations.

3、We attach great importance to the safety of personal data. We have established a dedicated security team and adopted all reasonable and feasible measures to protect your personal information:

3.1 Data security technical measures

We will adopt safety protection measures that comply with industry standards, including the establishment of reasonable systems, specifications, and safety technologies to prevent unauthorized access, use, and modification of your personal information, and to avoid data damage or loss. Network services adopt a variety of encryption technologies. For example, in some services, we will use encryption technology (such as SSL) to protect your personal information, and use encryption technology to encrypt and store your personal information, and isolate it through isolation technology. When using personal information, such as personal information display and personal information association calculations, we will use a variety of data desensitization technologies to enhance the security of personal information in use. Strict data access control and multi-identity authentication technology are adopted to protect personal information and prevent data from being used in violation of regulations.

3.2 Other security measures we take to protect personal information

1) We manage and regulate the storage and use of personal information by establishing a data classification and grading system, data security management specifications, and data security development specifications.

2) We conduct comprehensive security control of data through confidentiality agreements, monitoring and auditing mechanisms for personal data contacts.

3.3 The Internet is not an absolutely secure environment, and the communication methods with other users such as e-mail, instant messaging, social media cannot be determined whether it is completely encrypted. We recommend that you use complex passwords when using such tools, and pay attention to protect your personal data security.

3.4 We will do our best to ensure or guarantee the security of any personal data you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of personal information, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.

4、Security incident handling

Please understand that due to technical limitations and risk prevention limitations, even if we have tried our best to strengthen security measures, we cannot always guarantee the 100% security of personal information. You need to understand that the system and communication network you use to access the HanBook service may have problems due to circumstances beyond our control.

FOURTH: How to manage your personal data

We encourage you to update and modify your personal data to make it more accurate and effective. Please understand that your decision to correct, delete, withdraw your authorization or stop using the HanBook service will not affect our previous personal data processing based on your authorization. When some info is deleted, we may require you to verify your identity to protect the security of your personal data.

In the following situations, you can request us to delete personal information:

1、If our handling of personal data violates laws and regulations;

2、If we collect and use your personal data without obtaining your authorization;

3、If our handling of personal data seriously violates our agreement with you;

4、If we no longer provide you with HanBook services.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal data from us as much as possible at the same time, requiring them to delete them in a timely manner, unless laws and regulations provide otherwise, or these entities obtain your independent authorization.

5、Log out your account

If you no longer use the HanBook service, you can log in to "HanBook"-"Account Settings"-"Cancel Account" under the condition that the terms agreed in the service agreement and relevant national laws and regulations are met. In general, we will cancel your account within fifteen working days, then we will stop providing you with HanBook services. When your account is cancelled or deleted, all service information and data under the HanBook service related to the account will be deleted or anonymized, except as otherwise provided by laws and regulations.

FIFTH: Third-party services

The HanBook Service may link to social media or other services (including websites or other forms of services) provided by third parties. Include:

5.1 You may use the "Share" function of HanBook to a third party, or you may share content of a third-party service to HanBook. These functions may collect your information (including your log info) and may install COOKIES on your computer to properly operate the above functions.

5.2 Through advertising links or other means of our Services, We provide you gateways to third party services or websites.

5.3 Other circumstances of accessing third-party services. For the purposes stated in this Policy, we may access the SDK or other similar applications provided by third party service providers, and share some of your information that we collect in accordance with this Policy with such third-party service providers, in order to provide better customer service. At present, the third-party service providers we access mainly include the following types:

1) For advertising related services, including advertising display, advertising data monitoring/statistics, etc.;

2) Used for push, including mobile phone manufacturer Push, specific event reminder, etc.;

3) For payment related services, including order payment, transaction behavior verification, etc.;

4) To obtain device location permissions, collect device information and log information, etc., with your consent;

5) For third-party authorization services, including login of third-party accounts and sharing of relevant content to third-party products;

6) To support product functions, including online live broadcasting, video playback, voice recognition, intelligent customer service, content storage, etc.;

Some third-party SDKs or similar applications we access may collect your personal data. If you use such services provided by third parties in our Services, you agree that your information will be directly collected and processed by them. We will evaluate the legality, legitimacy and necessity of collecting personal data by such third party services, require such third parties to take measures to protect your personal data, and strictly comply with relevant laws, regulations and regulatory requirements. The services described above are operated by the relevant third parties. Your use of such third-party services (including any personal information provided by you to such third parties) is subject to the third party's own terms of service and personal data protection statement (not this Policy), and you need to read its terms carefully. We will only share your information for legitimate, necessary and specific purposes. We will require them to fulfill their obligations of confidentiality and take appropriate security measures.

SIXTH: Protection of minors

If you are a minor under the age of 18, please make sure that your guardian reads this Policy carefully, and use our services or provide personal information to us under the precondition of obtaining your guardian's consent. If the guardian finds that the personal information of the minors is filled by the minors themselves and needs to be modified or deleted, please contact us at any time.

SEVENTH: Amendments

We may update this policy from time to time by publishing a new version on our website or app. You should check this page occasionally to ensure you get the changes to this policy. In any case, you must keep your account and password information confidential and take care of it.

EIGHTH: Laws and jurisdiction

In case of any dispute, both parties shall settle it by consensus through consultation. If the parties are unable to resolve the dispute through negotiation, the parties agree that arbitration shall be conducted by China International Economic and Trade Arbitration Commission (" CIETAC ") in Beijing, China in accordance with CIETAC's arbitration rules in force and applicable laws and shall be heard by 3 arbitrators.

NINTH: How to Contact Us

We have set up a dedicated department for personal data protection. If you have any complaints or feedback regarding the security of your personal data, or if you have any questions, comments or suggestions regarding this Policy of HanBook, please contact us via online form or send email to support@hanlanguage.com