Hanwang Technology User Privacy Policy
Version: V2.1.1
Release Date: April 6, 2023
Effective Date of This Version: April 6, 2023
Hanwang Technology Co., Ltd. and its affiliates (hereinafter referred to as "Hanwang" or "we") have always been committed to protecting the privacy of users who use Hanwang's products and services. Before providing personal information to Hanwang, please read and understand this "Privacy Policy" (hereinafter referred to as "this Policy") to understand our principles and protective measures regarding your personal information.
We deeply understand the importance of personal information to you and will do our utmost to ensure the security and reliability of your personal information. We are committed to maintaining your trust in us, and we promise to adopt corresponding security protection measures to protect your personal information according to industry-accepted security standards.
This "Privacy Policy" applies to the product service provided by us: [PK Gun].
The purpose of establishing this policy is to help you understand the following:
How we collect and use your personal information
How we use Cookies and similar technologies
How we share, transfer, and disclose your personal information
How we store and protect your personal information
How we manage your personal information
Third-party services
Policy changes and notifications
How to contact us
How we collect and use your personal information
1.1 How we collect your personal information
Personal information refers to various information recorded electronically or by other means related to identified or identifiable natural persons, excluding anonymized information. When you use Hanwang's products and services or interact with us, we may collect your personal information. The specific types of data collected will vary based on the products and services you use and your interactions with us. You are not obligated to provide personal information to Hanwang, but in some cases, if you choose not to provide it, Hanwang may be unable to provide you with relevant products or services or address the issues you encounter. Hanwang only collects and uses your personal information for the purposes stated in this statement. The personal information we may collect includes:
1.1.1 Information obtained during your interactions with us or the use of our products and services
(1) Device and network information: We collect relevant information about your device when you use Hanwang products and services, such as device type, device name or model, device identifiers, operating system type and version, browser type and version, screen resolution, language settings, IP address, network service provider, and other technical information specific to the product.
(2) Interaction records information: This type of information will be directly submitted by you when using our website, products, or services and interacting with us. For example, information requests you provide to us, including queries you enter or questions or information you provide to obtain customer support. Communications records online, via phone, email, or participation in online/offline activities.
(3) Log information: When using Hanwang's products and services or viewing content provided by Hanwang, necessary log information, such as each visit's time, accessed page paths, client IP addresses, event information (such as errors, crashes, restarts, upgrades), etc., is automatically collected and stored.
1.1.2 Non-Personal Information
We may also collect other information that cannot directly or indirectly identify specific individuals and does not qualify as personal information under applicable local laws. This type of information is referred to as non-personal information. We may collect, use, transfer, and disclose non-personal information. Here are some examples of how we collect and aggregate non-personal information:
(1) Statistical data generated during your use of specific services: This may include anonymous device-related information, daily active events, page visit events, page visit duration events, and session events.
(2) Network monitoring data: Information such as request duration, requests, and error counts.
(3) Application crash events: Logs automatically generated after application crashes, for instance.
The purpose of collecting this information is to enhance the services we provide to you. The categories and quantity of information collected depend on how you use our products or services.
1.1.3 Exceptions to Obtaining Authorized Consent
According to relevant laws and regulations, the collection of your information is not required to obtain your authorized consent in the following circumstances:
(1) Related to national security and defense security;
(2) Related to public safety, public health, and significant public interests;
(3) Related to criminal investigation, prosecution, trial, and judgment execution;
(4) For the protection of significant legitimate rights and interests of the information subject or other individuals, but it is difficult to obtain your personal consent;
(5) Information collected that you have voluntarily made public to society;
(6) Information collected from legally disclosed sources, such as lawful news reports, government information disclosure, and similar channels;
(7) Necessary for signing contracts as per your request;
(8) Necessary to maintain the safe and stable operation of products, such as identifying and addressing faults in products or services;
(9) Necessary for lawful news reporting;
(10) When academic research institutions carry out necessary statistical or academic research based on public interest and provide the results of academic research or descriptions externally, they de-identify the information contained in the results;
(11) Other circumstances stipulated by laws and regulations.
1.2 Device Access Permissions Required for Implementing Product or Service Functions
When using Hanwang products and services or interacting with us, we may collect your personal information. The specific types of data collected may vary depending on the products or services you use and your interaction with us. While you are not obligated to provide personal information to Hanwang, in certain cases, if you choose not to, Hanwang may be unable to provide you with related products or services or address the issues you encounter. The following are the device access permissions that may need your authorization when providing relevant information to us:
|
Business Scenario |
Scenario Description |
Access and Usage Permissions |
|
Photo Recognition |
Use Hanwang Easy Learning - My Word Book to intelligently recognize English words by taking photos |
Access camera permission Access storage permission |
|
Scan Function |
Use phone camera for barcode/QR code scanning, requires location access to determine surrounding devices for device connection |
Access camera permission Access location permission Access storage permission |
|
Determine Location |
Determine the user's area to provide potentially more personalized regional characteristic services |
Access approximate location information Access precise location information |
|
Check Product Use Status |
View WLAN status information |
View WLAN status permission Check product use status Check device network connection, determine which network is connected |
|
Message Notifications |
Used for message push services, facilitating timely receipt of unread message notifications |
Self-start permission Foreground service permission |
|
SMS Functionality |
Synchronize received SMS content for in-app reminders |
Receive SMS permission |
|
Data Statistics |
SDK obtains the device serial number for data statistics |
READ_PHONE_STATE |
|
|
|
|
How We Share, Transfer, and Disclose Your Personal Information
3.1 Sharing
We will not sell any personal information to third parties.
We only disclose your information under the following circumstances and with security measures that comply with industry standards:
(1) Providing Goods or Services: Sharing your information with third parties is necessary to provide the core functions or services you require.
(2) Service Enhancement: Sharing your information with partners or third parties is essential to offer more targeted or improved services. For example, providing order information to logistics service providers.
(3) Obligations and Rights: Fulfilling our obligations outlined in this Privacy Policy or other agreements made with you, exercising our rights.
(4) Legal Compliance and Protection: Within legal boundaries, exchanging information to comply with the law, safeguard our and our affiliates' or partners', your, or other product users' interests, properties, or safety from harm. For instance, preventing fraudulent activities or minimizing credit risks. However, this does not involve selling, renting, sharing, or disclosing information for profit-making purposes against the commitments made in this Privacy Policy.
(5) Legal Assistance: Assisting in handling your legitimate requirements, disputes, or controversies with others.
(6) Guardian Requests: Providing your information upon lawful requests from your guardian.
(7) Service Agreements: Providing information based on service agreements signed with you (including electronically signed agreements and relevant platform rules) or other legal documents.
(8) Academic Research: Providing information for academic research purposes.
(9) Social Public Interests: Providing information based on social public interests in compliance with laws and regulations.
We only share your information for lawful, legitimate, necessary, specific, and explicit purposes. We sign strict confidentiality agreements with companies, organizations, and individuals with whom we share information, requiring them to handle the information as per our instructions, this Privacy Policy, and any relevant confidentiality and security measures.
3.2 Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
(1) Explicit Consent: Upon obtaining your explicit consent or authorization to transfer your information to others.
(2) Legal Obligations: When it is necessary to provide information based on applicable laws, regulations, legal procedures, or mandatory administrative or judicial requirements.
(3) Business Transactions: In the course of our continuous business development, we might engage in mergers, acquisitions, asset transfers, or similar transactions, where your information might be transferred as part of such transactions. We will require the new entity holding your information to continue to be bound by this Privacy Policy. Otherwise, we will request that the new entity re-seeks your authorized consent.
3.3 Disclosure
We only disclose your information under the following circumstances and with security measures complying with industry standards:
(1) Consent-based Disclosure: Disclosing the information you specifically designated in a manner you explicitly consented to, as per your requirements.
(2) Legal Requirements: When legally or regulatory required, compelled by law enforcement or judicial requests to provide your information, we may disclose your information according to the requested type and method of disclosure. Within the scope permitted by laws and regulations, when we receive requests for information disclosure as mentioned above, we will require the receiving party to provide corresponding legal documents such as subpoenas or investigation letters. We firmly believe that requests for information we provide should be as transparent as possible within the limits permitted by the law. All requests undergo careful scrutiny to ensure their lawful basis and are limited to data that law enforcement agencies are legitimately entitled to obtain for specific investigative purposes.
3.4 Exceptions to Obtaining Authorized Consent
Sharing, transferring, or disclosing your information does not require prior authorized consent in the following circumstances:
Related to National Security and Defense Security
Related to Public Safety, Public Health, and Significant Public Interests
Related to Criminal Investigation, Prosecution, Trial, and Judgment Execution
Necessary to Safeguard the Significant Legal Rights and Interests of the Data Subject or Other Individuals, Yet Difficult to Obtain Your Personal Consent
Information that You Voluntarily Disclose to the Public
Collecting Information from Legally Publicly Disclosed Sources, such as Legitimate News Reports, Government Information Disclosures, etc.
Necessary for Contractual Signing at Your Request
Necessary to Maintain the Safe and Stable Operation of Products, e.g., discovering and addressing faults in products or services.
Necessary for Legal News Reporting
Academic Research Institutions Conducting Statistical or Academic Research in the Public Interest, and When Providing Academic Research or Descriptive Results to External Entities, De-identifying the Information Contained in the Results
Other Circumstances as Specified by Laws and Regulations
4.1 Storage of Personal Information
Except when otherwise stipulated by laws and regulations or regulatory authorities, we only store your personal information for the necessary and shortest period required for the purposes outlined in this policy. If we cease to provide services or operate, we will promptly cease ongoing collection activities for your personal information. We will also comply with relevant legal requirements to inform you in advance of the termination of services or operations. Subsequently, we will either delete or anonymize your personal information after service termination or operation cessation, except as otherwise required by laws, regulations, or regulatory authorities.
4.2 Protection of Personal Information
We place great importance on information security and have established a dedicated security team. We take all reasonable and feasible measures to protect your personal information:
(1) Data Security Technology Measures: We employ security measures in line with industry standards. These include establishing reasonable institutional norms and security technologies to prevent unauthorized access, usage, or modifications of your information, thereby avoiding data damage or loss. Multiple encryption technologies are applied in our services. For instance, in certain services, we utilize encryption technologies like SSL to protect your personal information, encrypting and isolating your personal information using isolation techniques. When using personal information, such as information display or information correlation calculation, we employ various data desensitization techniques to enhance information security during use. Strict data access control and multi-factor authentication technologies are also used to protect information and prevent illegal usage.
(2) Additional Security Measures for Protecting Personal Information: We have an advanced data security management system centered around the data lifecycle. This includes multiple dimensions, such as organizational construction, system design, personnel management, and product technology, to enhance the overall system's security. We manage and regulate information storage and usage through data classification, hierarchical management, data security management norms, and data security development specifications. Comprehensive data control is conducted through information contact confidentiality agreements, monitoring, and auditing mechanisms. Additionally, we conduct security and privacy protection training courses to enhance staff security awareness and the understanding of information protection importance.
(3) Access Control and Monitoring: Only employees and partners who require access to this information are permitted, and strict access control and monitoring mechanisms are in place. All personnel who may come into contact with your personal information are obligated to fulfill the corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or suspension of cooperation with us.
(4) Limitations of Internet Security: The internet environment is not entirely secure, and communication methods like emails, instant messaging, social software, or other service software used to communicate with other users cannot guarantee complete encryption. We advise using complex passwords and ensuring the security of your information when using such tools. When communicating or purchasing services through this product's services with third parties, it may be inevitable to disclose your information, such as contact details or postal addresses, to the transactional or potential counterpart. We advise you to protect your information adequately and provide it to others only when necessary.
(5) Internet Environment and Security Guarantees: The internet environment is not completely secure. We will strive to ensure the security of the personal information you send to us. If our physical, technical, or managerial protection facilities are compromised, resulting in unauthorized access, disclosure, tampering, or destruction of personal information, causing damage to your legitimate rights and interests, we will assume corresponding legal responsibilities.
(6) Security Incident Response: To counter risks like personal information leaks, damage, or loss, we have instituted various systems, delineating the classification, grading standards, and corresponding processing procedures for security events and vulnerabilities. We have established dedicated emergency response teams for security incidents, implementing measures according to specified security incident handling standards. These measures include damage control, analysis, positioning, formulation of remedial measures, joint tracing, and combating with relevant departments for different security events.
In the event of an information security incident, we will promptly inform you in accordance with legal requirements. This notification will include essential information about the security incident, its potential impact, the measures we have taken or will take, recommendations for autonomous risk prevention and reduction, and remedial measures for you. We will inform you of the incident-related information through email, letters, phone calls, or push notifications. When it's challenging to inform individual data subjects one by one, we will reasonably and effectively issue public announcements. Furthermore, we will proactively report the handling of information security incidents as required by regulatory authorities.
Please understand that due to technical limitations and the scope of risk prevention, even though we have endeavored to strengthen security measures, we cannot guarantee the absolute security of information at all times. Please be aware that the systems and communication networks you use to access Hanvon services might experience problems beyond our control.
We recommend that any minors participating in online activities obtain prior consent from parents or other guardians ("Guardians") according to the relevant laws and regulations of the country to protect the related information of minors.
5. Policy Changes and Notifications
To enhance the quality of service provided to you, we may periodically modify the terms of this "Privacy Policy" based on updates to our products or services and legal requirements. Any changes made to this policy will be published on this page. For significant modifications, we will also provide more prominent notifications, such as website announcements, push notifications, pop-up prompts, or other means. If you disagree with these changes, you have the option to discontinue using Hanvon products or services.
Significant changes referred to in this policy may include but are not limited to:
(1) Significant changes in our service mode, such as the purpose of processing personal information, types of processed personal information, or methods of using personal information.
(2) Significant changes in our ownership structure, such as changes resulting from business adjustments, bankruptcy, mergers, and acquisitions.
(3) Major changes in the primary recipients of personal information sharing, transfer, or public disclosure.
(4) Significant changes in your participation in the processing of personal information and how you exercise your rights.
(5) Significant changes in the departments responsible for handling personal information security, contact methods, and complaint channels.
(6) Other important situations or potential circumstances that may significantly affect your personal rights and interests.
We prioritize your satisfaction with any modifications made. We encourage you to review our privacy policy each time you use our products.
6. How to Contact Us
If you have any complaints, reports, inquiries, opinions, or suggestions regarding personal information security or any matters related to this "Privacy Policy" or your information, please reach out to us using the following contact details. Generally, we will respond within five working days. In special circumstances, the maximum response time will not exceed seven days or the period stipulated by laws and regulations. If you are unsatisfied with our response, especially if our handling of personal information has harmed your legitimate rights and interests, you can communicate with us again or report to the relevant authorities.
Hanvon Technology Co., Ltd. Personal Privacy Security Center
Address: 3rd Floor, Building 5, No. 8 Northeast Wangxi Road, Haidian District, Beijing, China
Email: hwkj@hanwang.com.cn
Phone: 400-810-8816