Effective date: 21 May, 2021
Welcome to the XJTLU Learning Mall. XJTLU Learning Mall (hereinafter referred to as “XJTLU Learning Mall” or “we”) is well aware of the importance of the personal information of our users, so we warrant that we will protect the personal information and privacy of users (hereinafter referred to as “the Users” or “you”) when you use our products and services (hereinafter referred to as “the Services of XJTLU Learning Mall”). While you are using the Services of XJTLU Learning Mall, we might collect and use your relevant personal information (hereinafter referred to as “personal information”).
Article I. How we collect and use your personal information
Article III. Under what circumstances we may share, transfer and disclose your personal information
Article IV. How we retain, store and protect your personal information
Article V. How you can manage your personal information
Article VI. Services provided by third parties
Article VII. Protection of minors
Article VIII. Notifications and modifications
Article IX. How to contact us
We collect your personal information to provide better Services of XJTLU Learning Mall for you and other users. Such personal information as collected will help us achieve this purpose.
1. We may collect and obtain your personal information through:
1) The personal information you have provided.
(1) The personal information you provide when registering an account of XJTLU Learning Mall or use the Services of XJTLU Learning Mall;
(2) The personal information you share to other parties through the Services of XJTLU Learning Mall, and the personal information you store when you use the Services.
Please note that the personal information you upload or post in sections accessible to other users and the personal information you disclose in response to information uploaded or posted by other users might be collected and used by others. If you find your personal information is illegally collected or used, please contact us in the ways specified under Article IX.
2) Your personal information shared by any third party. It refers to your personal information provided by any third party when they use the Services of XJTLU Learning Mall.
3) Your personal information we have obtained. Your personal information that we collect, summarize and record when you use the Services of XJTLU Learning Mall.
2. We may collect and use the following types of personal information for the following purposes:
1) To help you register, login and delete your account
You shall provide your basic personal information for registrations and login, including your telephone number and email address, and you shall also create your account, user name and password so that we can provide you with the complete Services of XJTLU Learning Mall. If you only use basic services, such as browsing, query and searching, you do not need to register to be a user of XJTLU Learning Mall or provide the aforementioned personal information.
During your registration, login or follow-up use of the Services of XJTLU Learning Mall, extra personal information (including your nickname, profile photo, gender and areas of interest) you provide will help us offer informed, personalized recommendations and better services; your usage of the basic Services of XJTLU Learning Mall won’t be affected if you do not provide such extra personal information.
We may require you to provide authentic personally identifiable information (including but not limited to your name, ID card, passport, driving licence, household register, facial features, fingerprints) for your authentication in accordance with the applicable laws and regulations and the requirements of supervision, or to ensure the security of our system and services and ensure the functions of specific services. If you fail to provide the information aforementioned, you may not be able to access relevant functions and services.
For authentication, you agree and authorize us or entrust a third-party to query and check the personally identifiable information you provide or provide the aforementioned information to identify certificate authorities, such as the credit bureau and government authorities.
3) To maintain the proper operation of basic functions
While you are using our services, we may automatically collect, store and synchronize the information that is relevant to the services you use and the ways you use them in order to identify the unusual status on your account and improve our products’ suitability. The information includes:
(1) Log information: When you are using our services, we may automatically collect detailed information on how you use our services and store it as a log. Log information includes your login account; the contents you search and query; the IP address; the browser type; the mobile network operator; the network environment; the language; the date, time and web browsing history of the access; the Push browsing history; the crash history; the time on page/site; the refresh history; the release history; the history of following, subscriptions, favorites and shares.
(2) Device information: Pursuant to the specific permissions you authorized when you install and use the software, we will receive and record the relevant information of the device you use (including IMEI, MAC, UUID, Serial, the IMSI number of the SIM card, device model, the operating system and its version, the version of the client device, the device resolution, the package name, the setting of the device, the list of the process and the software, the unique device identifier, and the features of the software and the hardware), and the location of the device (including the IP address, the GPS location, and the wireless access point, the Bluetooth and the base station sensor that can provide relevant information).
In order to collect the device information aforementioned, we will ask for the permission of accessing your device information. We collect this information so that we could provide you with our basic services. If you refuse to authorize the permissions aforementioned, we may not able to provide you with our products and services.
4) To provide you with the products and services
(1) The share and release of personal information: When you use the Services of XJTLU Learning Mall, upload and/or release your personal information and conduct relevant activities (such as post questions, answer questions in live stream classes, share and make comments on our products/services), we may collect the personal information you uploaded, posted or generated and shall be entitled to show your nickname, profile photo and the contents you have posted.
(2) The delivery of the products or services: When you purchase specific products or services, the order of such products or services will be generated in our system. When you use certain services, we may require you to provide your personally identifiable information, name, delivery address, postcode, telephone number and payment status. If you refuse to provide such personal information, we are not able to complete the delivery of services. If you purchase products or services for other people through the Services of XJTLU Learning Mall, you shall provide the personal information aforementioned of the actual user of such products or services. Before you provide the personal information aforementioned of the actual user, make sure you get his/her authorization. When you use specific functions of the Services of XJTLU Learning Mall, XJTLU Learning Mall may collect and store the pictures, texts and voice messages you uploaded, and our recognition programs will process and analyse these data and return the corresponding results in text.
(3) To complete the payment of an order, deliver the products or services, confirm the payment status and provide the after-sales services and dispute resolution services, we collect from or share the information related to your transaction, including your account, order, payment and logistics information to the transaction partner, the payment institution and the logistics company you have chosen based on your transaction.
(4) Order management: To show the order information under your account, secure your access to after-sales services and enable you to better manage your order, XJTLU Learning Mall collect your order information, transaction and purchase history and virtual assets information generated when you use our products and services.
(5) Customer support and after-sales services: When you contact our customer support or use other customer response functions (including sale or after-sales application, complaints or recommendations on personal information protection, and other customer complaints and requirements), we may require you to provide necessary personal information to authenticate your identity so as to ensure the security of your account and our system. We may also retain your contact information (the information you use or provide when you contact us), the history and contents of communications between you and us, and other necessary information related to your requirements so that we can contact you, help you resolve your problems, or record the resolutions of such problems.
6) To display and push our products or services to you
(1) To display our products and provide services to you
With the information you have provided to us, the information we may collect and the information we have collected indirectly about you (including your browsing and searching history, the device information, the location, the order information, the telephone number and your personal information provided through the on-line or off-line questionnaires of XJTLU Learning Mall), we may use one or more types of information aforementioned to develop the recommendation algorithm modeling, the programmatic advertising recommendation algorithm modeling, the user behavior analysis and the user profile. These will help us better understand the features of your browsing and searching preference, behaviours and location so that we can provide you with more personalized page displays and contents recommendations.
Based on those features, we may, through emails, messages, phone calls or other methods, send you the marketing information about, provide access to or conduct promotions for the following products and services either provided by us or third parties:
The products and services provided by us and our affiliated parties include: online education, translation and interpretation, speech recognition and synthesis development platforms, smart devices, cloud computing, E-commerce, instant messaging, online media services, interactive entertainment, social network services, payment services, applications and application services, data management software and services, on-line advertising and software and services about social media, entertainment, information and messaging; and third-party products and services, including internet services, logistics services, banking and financial services, entertainment, books and other publications, advertising, the points and rewarding program, and other products and services that you may want to use.
(2) To send you notifications. When necessary (such as a specific service is suspended when our system is under maintenance, or a service is changed and terminated), we will send you notifications related to this service.
If you do not want to receive the notifications we push, you can require us to stop sending such messages, for example, you can unsubscribe the advertising messages under the SMS directions, or set up on your mobile device. However, we will still send you the messages required by laws or the Service Agreement of XJTLU Learning Mall.
7) To keep your personal information secure
To improve the security of the services provided by us and our partners, secure the personal and property safety of you and other users, prevent security risks like phishing sites, scams, network vulnerabilities, computer viruses, cyber-attacks, network intrusions, and identify activities that violate applicable laws and regulations or the relevant agreements on the Services of XJTLU Learning Mall, we may collect, use or integrate your account information, transaction information, device information, log information and the personal information you have authorized to share with our affiliated companies and partners or information they obtain in accordance with the law. We use the information aforementioned to estimate the risks of your account and your transactions, authenticate your identity, detect and prevent security incidents and record, audit, analyse and deal with these events, when necessary, in accordance with applicable laws.
8) To improve our services
We might use the information we collect when you use one of XJTLU Learning Mall services for other services we provide. The information we collect when you use one of our services may be used in other services to provide you with some specific contents or to display the push information related to you rather than to our general users; we might invite you to take part in our surveys of the Services of XJTLU Learning Mall so that we can improve the services we currently provide or develop new services; and, we might use your personal information in our software updates.
You understand and agree that after we collect your personal information, we will de-identify these data and the de-identified data will not be used to identify your identity. Under this condition, we are entitled to use the de-identified personal information and analyse the user database and use them for commercial purposes.
9) Other usages
In accordance with applicable laws and regulations, we are entitled to collect the following personal information without your authorization:
(1) Information relevant to national security and national defence of China;
(2) Information relevant to public safety, public health and significant public interests;
(3) Information relevant to a criminal investigation, prosecution, trial and enforcement of judgments;
(4) Information that is necessary for protecting the personal safety, property safety, and other significantly legitimate rights and interests or those of other individuals but is difficult to obtain authorization from you for collection;
(5) Information that you have disclosed to the public;
(6) Information collected from legally and publicly disclosed information, such as from news reports, government information disclosure, and other legal sources;
(7) Information required for signing the contract pursuant to your requirements;
(8) Information required for maintaining the safe and stable operation of the Services of XJTLU Learning Mall, such as discovering or dealing with the problems about our products or services;
(9) Information necessary for legally reported news;
(10) Necessary information that academic and research institutions use for statistics and academic research based on public interests, and the de-identified personal information included in the academic research results provided or described by the institutions to other parties;
(11) Other information subject to laws and regulations.
11) You understand and agree that XJTLU Learning Mall may require you to grant us specific access permissions as follows on your device so that your personal information related to these permissions can be collected and used:
(1) We access your location information in order to provide you with more personalized page displays and product services based on your region;
(2) We access your camera in order to enable you to scan or take pictures with your camera so that you can log in, make payments, make comments on pictures, extract texts from pictures, upload your homework/materials, watch the videos, interact with others in the live stream classes and use the pictures translation function;
(3) We access your album in order to enable you to use and upload photos, pictures or videos on your device, and to change your profile photo, make comments and share with other users;
(4) We access your microphone in order to enable you to use the voice translation function, the voice comment function, the interactive voice teaching-learning function and to interact with the customer service staff. When you use these functions, we will collect the contents of your recording to identify your specific requirements;
(5) Once these permissions are granted, you may receive our notifications about the updates of the courses, the live broadcast and the instant news from the lecturers;
(6) When you use the Services of XJTLU Learning Mall, video cache files may be generated and we may access these files so that you can watch our courses smoothly or offline.
Most mobile devices support the disabling of the aforementioned functions. If you want to turn off these functions, please contact the service provider or producer of your mobile device for more information. Please note that when you give any of the permissions said above, you authorize us to collect and use the relevant personal information when we provide services to you. Once you turn off any of the permissions, you cancel the authorization and we will stop collecting and using your personal information based on this permission and we will not be able to continue providing you with services requiring such permission. However, your decision to turn off the permissions does not affect the collection and usage of your personal information based on your previous authorization.
12). Reminder on sensitive personal information
We or our third-party partners may collect or use your personal information through COOKIES and store such information as log information.
COOKIES can help us provide you with better services and in a faster manner, and can help you enjoy more personalized experiences. However, you may control whether and how COOKIES shall be accepted by your browser. Please refer to the files of your browser to obtain more information about customization.
We or our third-party partners may collect or use your personal information through COOKIES and store such information.
We use our own COOKIES for:
(1) Remembering your identity. COOKIES will help us identify your identity or store information about your preferences or other personal information that you provide to us.
(2) Analysing your usage of our services. COOKIES will help us find out what activities you use the Services of XJTLU Learning Mall for, or which service or services you prefer.
(3) Optimising advertising. COOKIES may help us show you ads that are relevant to your preferences based on your personal information.
While using COOKIES for these purposes, we may provide non-personally identifiable information collected through COOKIES to advertisers and other partners of XJTLU Learning Mall to analyse how you and other users use the XJTLU Learning Mall services, with which we can thus optimize our advertising services.
2. Web beacons and pixel tags
In addition to COOKIES, we also use other similar technologies such as web beacons and pixel tags on our website. The emails we send you may contain a hyperlink to our website, and if you click that link, we will track it to understand your preferences about products or services so that we can proactively improve our customer services. A web beacon is usually a transparent image embedded in a web page or email. A pixel tag in an email enables us to know whether this email has been read or not. If you do not want your activity to be tracked in this way, you can unsubscribe from our receiver list at any time.
We may share, transfer or disclose your personal information under the following circumstances:
We will not share your personal information with any third party (our affiliated parties excluded) without your consent except under the following circumstances:
1) We will offer our services to you. We may share your personal information with our partners and other third parties to enable core functions or provide services you need, such as providing order information to logistics providers;
2) We will maintain and improve our services. We may share your personal information with partners and other third parties (e.g., communication service providers who send emails or push notifications on our behalf) to help us provide you with more targeted and improved services;
5) We will provide information to third parties such as our partners who rely on us for advertising, to help them better understand the reach and effectiveness of their ads. For example, we may inform them of the number of people who have seen their ads or, have bought their goods after seeing the ads, or provide them with statistics about those whose identities cannot be identified, to help them better understand their audience or customers;
7) Upon your legitimate request, we will provide assistance to you in the resolution of disputes with others;
8) We will provide access to your personal information at the legitimate request of your guardian;
9) We will provide your personal information in accordance with individual service agreements (including electronic agreements signed online and the corresponding platform rules) or other legal documents we have signed with you;
10) We will conduct academic research;
11) We will maintain public interests pursuant to applicable laws and regulations.
2) We may transfer your personal information to other parties after obtaining your expressed consent.
We will disclose your personal information only under the following circumstances and the disclosure is subject to security measures that meet industry standards:
1) Disclosing the personal information you’ve specified according to your needs and in the manner that you expressly agree to be disclosed.
2) In circumstances where the provision of your personal information is required by applicable laws and regulations, or in response to compulsory administrative enforcement or judicial requests, we may disclose your personal information and in manners as requested. When we receive a request for disclosure of personal information as described above, we will, subject to applicable laws and regulations, require that the information recipient to present appropriate legal documents, such as a subpoena or a letter of inquiry. To the extent permitted by law, we are fully committed to providing the personal information that we are required to provide in a manner that is as transparent as possible. All requests are carefully reviewed by us to ensure that they have a legitimate basis and that data used for specific investigative purposes by law enforcement agencies that have the legitimate right for access shall be disclosed.
4. Exceptions to the sharing, transfer, and disclosure of your personal information with your prior consent
Your prior consent is not required for sharing, transferring, or disclosing your personal information when the information is:
1) Relevant to national security and national defence of China;
2) Relevant to public safety, public health and significant public interest;
3) Relevant to justice or administrative law enforcement such as crime investigation, prosecution, trial and sentence enforcement;
4) Necessary for protecting the personal safety, property safety, and other significantly legitimate rights and interests or those of other individuals but is difficult to obtain authorization from you for collection;
5) Disclosed to the public by yourself;
6) Collected from legally and publicly disclosed information, such as from news reports, government information disclosure, and other legal sources;
As provided in by applicable laws, if the personal information being shared or transferred is de-identified, and the recipient of such information cannot recover and re-identify the subject of the personal information, then such sharing or transfer shall not be deemed as an act of sharing, transferring or publicly disclosing the personal information, and the storage and processing of such information will not require extra notification to you or your prior consent.
2. Personal information collected and generated in the course of our operations in the People’s Republic of China is stored in the PRC, except under the following circumstances:
1) Applicable laws and regulations have stipulated provisions to the contrary;
2) We obtain your consent to preserve your personal information outside of the PRC;
3) You need to transfer your personal information overseas to complete a transaction when you use the XJTLU Learning Mall services.
3. We take the security of your personal information very seriously and have established a dedicated security team to protect your personal information in all reasonable and practicable measures. These measures include:
1) Technical measures for data security
We adopt security measures in accordance with industry standards, including the establishment of reasonable systems and the application of security technology to protect your personal information from unauthorized access and modification and to avoid damage to or loss of your data. Various encryption technologies are adopted in our web services. For example, we will use encryption technologies (such as Security Socket Layer, SSL) in some services to store your personal information, and protect such information through compartmentalization. We employ various data masking techniques to enhance security when using personal information for purposes such as display and related calculation. Strict control over data access and multi-factor authentication techniques are also exercised and applied by us to protect personal information from unauthorized use.
2) Other safety measures
(1) We manage and regulate the storage and usage of personal information by establishing classification systems, security governance specifications, and security development specifications for data.
(2) We have full security control over data through auditing mechanisms, data monitoring and requiring those who have access to personal information to sign confidentiality agreements.
(3) We also provide our staff with security and privacy training to raise their awareness of the importance of protecting personal information.
(4) We restrict the access to your personal information to the staff of our own, our affiliated parties and our partners who may reasonably need it for the purposes of this Agreement, and we have strict control and monitoring mechanisms on such access. We require all those who may have access to your personal information to meet in full the obligations of confidentiality. Any party aforementioned that fails to perform the confidentiality obligations established herein shall be held liable, and we may suspend our collaboration with such a party or parties.
3) Cyberspace is not absolutely secure, and it is impossible to determine whether channels of your communication with other users, such as emails, instant messages, social networking software or other service software, are fully encrypted or not. Therefore, we recommend that you use complex passwords when using such communication tools and pay attention to protecting your personal information.
4) We are committed to ensuring the security of any personal information you send to us. We shall be liable for any unauthorized access, public disclosure, falsification, or destruction of your personal information caused by the breakdown of our physical, technical, or administrative safeguards.
4. Response to information security incidents
In the event of a security incident involving your personal information, we will promptly inform you of the following information in accordance with applicable laws and regulations: Basic information about the incident and its potential impact; disposal measures that we have taken or are about to take; suggestions on preventing and reducing such risk on your part; and remedies for such an incident. We will notify you of the aforementioned information by email, letter, short message, phone call or push notification. In circumstances where it is difficult to inform the owner of such information one by one, we will publish announcements in reasonable and effective ways. In addition, we will proactively report to regulatory agencies about our disposition of such an incident as required.
Please note that due to the limits of technologies and risk prevention, we cannot guarantee the complete security of your personal information even though we have made our best efforts to strengthen security measures. Please note that the systems and communication networks you use to access the XJTLU Learning Mall services may be subject to problems that are beyond our control.
We encourage you to update and modify your personal information to make it more accurate and valid. Please note that your decision to correct, delete, or revoke authorization to access your personal information, or stop using the XJTLU Learning Mall services shall not affect our previous handling of your personal information based on your authorization. Unless otherwise provided by laws or regulations, when you correct or delete your personal information or apply for account cancellation, we may not immediately correct or delete the corresponding personal information in our backup system, but will do so when the backup is updated. You must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will remove the compromised information and update our records accordingly.
You can manage your personal information by:
1. Accessing, correcting and deleting your personal information
You can access your personal information via the Services of XJTLU Learning Mall, and correct, add or delete it by yourself or by requiring us to do so. We use appropriate technical means or provide a contact channel for submitting such requests to ensure that you can, to the extent possible, access, update and correct your own personal information or other personal information provided when using the Services of XJTLU Learning Mall.
You may make a request to us to delete personal information under the following circumstances:
1) Our handling of your personal information violates applicable laws and regulations;
2) We collect and use your personal information without your prior consent;
3) Our handling of your personal information constitutes a material breach of our agreement with you;
4) We no longer offer you the Services of XJTLU Learning Mall.
Unless otherwise provided by laws or regulations, if we decide to respond to your request for deletion, we will also make our best efforts to notify the parties that obtain your personal information from us to promptly delete your personal information unless they obtain your authorization to keep such information.
2. Disclosing and sharing your personal information
When using our services, you may share your personal information not only with users belonging to your social network, but also with all users of such services. Such personal information includes those you upload or post on XJTLU Learning Mall, the information you disclose in response to information uploaded or posted by other users, those you upload or publish via email or in sections accessible to all users of the Learning Mall, and the relevant location data and log information. Such information may remain public as long as you do not delete the personal information you’ve disclosed or shared. Even if you delete the shared personal information, such relevant information may still be independently cached, copied, stored or kept publicly by other users or third parties that are beyond our control. We shall not be held liable for any leakage of your personal information if you disclose or share your personal information through the aforementioned channels. Therefore, please think carefully before you disclose or share your personal information through the aforementioned channels.
3. Changing the scope of your authorization
You may choose whether or not to disclose your personal information. Some of your personal information is necessary to the usage of the Services of XJTLU Learning Mall, but the provision of most other personal information is at your sole discretion. You may change the scope of personal information that you authorize us to collect by deleting such information, turning off device functions, or revoking your authorization.
Once your authorization is revoked, we will not be able to continue providing you with the services for which that require your authorization, and we will not handle your personal information accordingly. However, your decision to revoke your authorization shall not affect our previous handling of your personal information based on your authorization.
The Services of XJTLU Learning Mall may contain links to social media or other services (including websites or other forms of services) provided by third parties, which may include the following cases:
1. You can click the “Share” button to share certain contents to third-party platforms, or you can use third-party services to log in to XJTLU Learning Mall. These operations may collect your personal information (including your log information) and may install COOKIES on your computer in order to function properly;
2. We provide you with links to third-party services or websites through advertisements or in other ways provided in the Services;
3. Other circumstances of accessing third-party services. For the purposes of this Policy, we may access the following software development kits (SDKs) or other similar applications provided by third-party service providers, and share certain information about you that we collect in accordance with this Policy with the third-party service providers in order to offer better customer services and user experience.
1) The IMEI and MAC of your cell phone need to be obtained by the SDKs of Alipay and WeChat when you use them for their payment-related services (including order payment, transaction behavior verification, etc.) and when they collect/analyze your payment information (including income settlement, payment information collection, etc.).
2) The IMEI and MAC of your cell phone need to be obtained by SDKs of WeChat, QQ, Weibo, Yeah.net, APPLE ID and Huawei for service authorization, including account login and information sharing.
The above services are operated by third parties. Your usage of such third-party services (including any personal information you provide to such third parties) shall be subject to the terms and conditions and personal information protection statements of such third parties; please read these terms and conditions and statements carefully before using their services. We only share your information for legitimate, necessary, and specific purposes. We will require such third parties to fulfil their confidentiality obligations and take appropriate security measures.
We may make service-related announcements when we deem necessary (for example, when we suspend a service due to system maintenance). You may not be able to unsubscribe to these announcements which are related to the Services you use and are non-promotional in nature.
Lastly, you shall be liable for keeping your account and password information confidential. Please make sure you keep your account and password information safe.
Address: Xi’an Jiaotong-Liverpool University, 111 Ren’ai Road, Suzhou Industrial Park, Suzhou 215123, Jiangsu Province, P. R. China.
We will respond to your questions, comments or suggestions within fifteen days from the date of reception.