Menke Privacy Policy

Last update date: November 16, 2022
Effective date: November 31, 2022

XINTUOYUN (BEIJING) TECHNOLOGY CO.,LTD. (registered address: No. 1-71, Innovation Center, Wang'anyuan, Xiji Town, Tongzhou District, Beijing, China, hereinafter referred to as "we") is the operator of the department .

Introduction

We attach great importance to protecting the personal information and privacy of our users (hereinafter referred to as "you"). When you use the course, we will collect, use, save, and share your relevant personal information. In order to show how we handle your personal information, we have formulated the "Menke Privacy Policy" (hereinafter referred to as "the Privacy Policy"), and we promise to handle your personal information in strict accordance with this Privacy Policy.

We remind you here:

1. Before you use the course, please be sure to read this privacy policy carefully and fully understand the content of each clause, including but not limited to terms that exempt or limit our liability. You know and confirm that when you click "Agree" to this privacy policy and use the course, you agree that we will process your personal information in accordance with this privacy policy.

2. In order to provide you with product features, based on your express authorization, we may call your camera, microphone, storage, address book, etc. permissions, and you have the right to refuse and close permissions.

3. In order to provide you with services such as online classrooms, we are also entrusted by institutions (schools or educational institutions) to collect and process part of your personal information in accordance with the agreement with the institution and the requirements of the institution.

4. You can access, correct, and delete your personal information in accordance with the methods described in this privacy policy, you can also withdraw your authorization and consent, make complaints and reports, and related privacy settings.

5. We have adopted security measures that comply with industry standards to protect your personal information.

You can read the corresponding chapters according to the following index to further understand the specific provisions of the policy:

1. How do we collect your personal information

2. How do we use your personal information

3. How do we save your personal information

4. How do we share, transfer, and publicly disclose your personal information

5. How do third-party products or services obtain your personal information

6. How do we use cookie technology

7. How do we protect your personal information

8. How do you manage your personal information

9. How do we deal with the personal information of minors

10. How to update this privacy policy

11. How to contact us

1. How do we collect your personal information

We divide the business functions of the course into basic business functions and extended business functions:

(1) Basic business functions are necessary for online teaching, including online classrooms.

(2) Expand business functions including cloud disk, chat, customer service, etc.

(1) Circumstances of collecting your personal information in basic business functions

1. Complete registration

In order to register as an individual user of the online school, so that we can provide you with basic class services, we will collect your mobile phone number so that you can register directly or register for the online school account for your guardian If you do not provide such information, we will use the account to create an account for you and provide you with services normally. Please be aware that with your consent, the institution can register your online school account for the course by submitting your mobile phone number to the course.

After registration, you can also choose to provide us with your nickname, profile picture and other personal information according to your own needs. If you choose not to provide the above information, it will not affect your normal use of our services.

2. Online classroom

Based on the agency’s commission, when we provide you with online classroom services for courses, we need to call your camera and microphone permissions so that you can use the video and voice functions to interact with teachers and classmates. You can choose to turn off the above permissions directly in the settings of the device, or you can turn off the above permissions in the "Privacy Settings" interface of the course; but if you turn off the above permissions, you will not be able to use the video or voice functions of the online classroom normally, which may cause You cannot teach others or actively participate in the class. Please be aware that if you agree to turn on the camera permission, we will only capture the range of the video you shot or selected when the camera is enabled; if you turn on the microphone permission, we will only capture the voice you provide when the microphone is enabled information.

Please note that institutions may record class videos based on teaching needs, and we will prompt you on the online classroom interface. If you do not want to be recorded in class videos, please contact your institution directly.

If you are a student, in order to record and manage courses and record online learning for you, we and institutional users will collect the following information: class time, class length, student behavior (speaking, camera on , Getting on and off stage, removal, reward, hand-raising situation), usage of teaching tools (authorization, answering device, clicker).

If you refuse to provide such information, we will not be able to provide you with online classroom services, but it will not affect your normal use of other functions of the course.

If you are a teaching teacher, we will collect your teaching data based on the agency’s entrustment, including: courseware usage, teacher behavior (banning, rewards, raising hands, authorization), use of teaching tools Situation (desktop sharing, timer, turntable, answerer, clicker, small whiteboard) for institutional users to understand your teaching situation. If you refuse to provide such information, we will not be able to provide you with online classroom services, but it will not affect your normal use of other functions of the course.

Based on the agency’s entrustment, in order to assist the institution in course management, we will collect course supervision pictures, recording videos, course name, course name, course start time, course duration, number of people on stage, User entry time, user exit time and reason, class registration information, the above information may contain your personal information. In addition, in order to ensure that you use our online classroom services stably and help you solve possible technical problems in a timely manner, we will also collect your gateway data, camera information, microphone information, and speaker information together with the organization. If you refuse to provide the above information, we will not be able to provide you with online classroom services, but it will not affect your normal use of other functions of the course.

Please be aware that in order to complete course management, the institution will schedule your class by adding your mobile phone number to the list of students or teachers in the course. If you are mis-arranged, please contact the relevant institution in time.

3. Sharing function

When you use the sharing function, we will collect the information you share, including text, pictures, and electronic documents that you publicly share in the class. Please note that this may contain sensitive information such as your or others' personal identification information, personal property information, etc. If it involves other people's personal information, please obtain the authorization of others before sharing.

If the files, photos or shared videos uploaded or posted by other users contain your personal information, we will collect your personal information.

4. Ensure the basic security of network access and services

In order to ensure the basic security of network access and services, we and the organization will jointly collect your access date, operating system, device type, CPU, IP address, device identification code, network delay, and packet loss rate , Menke version number. The above information we collect from you is to ensure the security of network access and application operation. If you refuse to provide such information, you will not be able to use our services normally.

(2) The situation in which we collect your personal information in the expansion of business functions

1. Courseware library function

When you use the courseware library function, we need to store the information, documents, pictures and other electronic files you uploaded. Please be cautious when uploading electronic files containing your personal information. If you do not want us to store such information, you will not be able to use the courseware library function of the course, but this will not affect your normal use of other functions of the course.

2. Chat function

When you use the class chat tool, we will collect a list of your friends. At the same time, we will store the information submitted or generated when you use the service, including your chat information, files, pictures, In order to realize the transmission and interaction of information. If you do not want us to collect and store such information, you will not be able to use the course chat function, but this will not affect your normal use of other functions of the course.

3. Customer Service

If you submit a complaint, suggestion or feedback to us, in order to contact you, help you solve the problem as soon as possible, or record the solution and results of the related problem, we may collect Communication or call records, account information provided by you, contact information provided by you, information provided by you to prove relevant facts, program operation logs, device information, system version, device language and regional settings. We collect the above information to complete customer service. If you do not provide such information, your complaints, suggestions and feedback may not be handled in a timely and effective manner, but it will not affect your normal use of other functions of the course.

(3) Equipment authority call situation

When you use the course service, we may call your device permissions. Please refer to the following table for the various permissions of the class, the purpose of the calling permissions, and the situation inquiring you before calling the permissions:

(4) Other situations

1. According to relevant laws, regulations and national standards, in the following situations, we may collect and use your personal information without asking for your authorization:

(1) Related to personal information controllers fulfilling obligations stipulated by laws and regulations;

(2) Directly related to national security and national defense security;

(3) Directly related to public safety, public health, and major public interests;

(4) Directly related to criminal investigation, prosecution, approval, and execution of judgments;

(5) In order to protect the life and property of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;

(6) The personal information involved is disclosed by the subject of personal information to the public;

(7) Necessary for signing and fulfilling the contract according to the requirements of the personal information subject;

(8) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(9) Necessary to maintain the safe and stable operation of the products or services provided, such as discovering and disposing of product or service failures;

2. Please understand that in order to provide you with better services, we will continue to update and optimize our services; if a function or service is not described in this privacy policy but needs to be collected For your personal information, we will separately explain to you the collected information, scope and purpose through page prompts, interactive processes, system notifications, etc., and obtain your consent.

3. At present, except for institutional users who provide us with personal information for the purpose of registration and teaching management, we will not actively obtain your personal information from other third parties. If you need to obtain your personal information indirectly from a third party due to business development or other reasons in the future, we will explain it to you through a privacy policy or other means; we will also comply with relevant laws and regulations and require third parties to protect the legality of the information provided .

2. How do we use your personal information

1. In order to achieve the relevant business functions of the course, we will use the personal information we collect. The specific purpose of use and the types of personal information used are as follows:

2. In order to provide you with Menke online classroom services and assist organizations in completing online classroom teaching, we and the organization will use your personal information. The specific purpose of use and the types of personal information used are as follows:

3. In order to provide institutional users with online classroom technical services and realize related business functions, we will use the collected personal information based on the agency’s entrustment. The specific purpose of use and the types of personal information used are as follows:

3. How do we save your personal information

1. Where to store information

Currently, we store the personal information collected and generated within the territory of the People’s Republic of China. We will not transfer or store your personal information across borders. If cross-border transmission or storage is required in the future, we will inform you of the purpose of the data going abroad, the recipient, and relevant security measures, and obtain your authorization and consent.

2. Period of information storage

We store your personal information in accordance with the shortest time required to achieve the purpose of use and relevant laws and regulations. After the storage period has expired, we will anonymize or delete your personal information.

3. Circumstances where the product or service ceases to operate

When our products or services stop operating, we will notify you in the form of push notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period of time. Legal Except as otherwise provided by laws and regulations.

4. How do we share, transfer, and publicly disclose your personal information

1. We are entrusted by institutional users as processors. In order to realize the entrusted processing of online teaching by institutional users through courses, we collect your personal information. The institution will act as the controller to process your personal information with the institution. Personal information about the course.

2. We will not actively share or transfer your personal information unless we obtain your express consent or confirm that a third party has obtained your consent.

3. If we undergo changes such as acquisitions, mergers, reorganizations, bankruptcies, asset transfers, etc., such as the transfer of personal information, we will inform you of the situation and require the new controller to comply with this privacy Policies and related laws and regulations require the protection of your personal information; if the new controller changes the purpose of using personal information, we will require them to obtain your express consent again.

4. Please note that your teaching and class behavior information in the course may be disclosed to students and teachers in the same class and course. If an institution records a lesson, your behavioral information in the course of teaching, attending classes, etc., may be disclosed to students and teachers who will get the video of the lesson in the future.

5. We will analyze the collected information and form an online teaching report that does not contain any personal information. We may disclose to the public and share content without identification information after statistical processing with our partners, to understand how users use our services or to let the public understand the overall use of our services.

6. In addition, according to relevant laws, regulations and national standards, we may share, transfer, and publicly disclose personal information in the following situations without your prior authorization:

(1) Related to our fulfillment of obligations under laws and regulations;

(2) Directly related to national security and national defense security;

(3) Directly related to public safety, public health, and major public interests;

(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

(5) In order to protect the life and property of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;

(6) Personal information disclosed to the general public by the subject of personal information;

(7) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels.

5. How do third-party products or services obtain your personal information

In order to provide you with richer and complete functions, we will use the following third-party software development kits (SDK for short) to provide you with services. For the specific information collection and use of the SDK, please refer to the privacy policy or relevant statement of the SDK operator.

6. How do we use cookie technology

On the web page, we may collect your information by placing secure cookies and related technologies. The purpose is to provide you with a more personalized user experience and service. For details, please refer to the "Cookie Policy".

7. How do we protect your personal information

1. We attach great importance to the security of users’ personal information, and have adopted a variety of organizational and technical security protection measures to protect the security of users’ personal information and prevent the leakage, damage, loss, and tampering of personal information. Specifically:

(1) We have adopted industry-wide data protection technical measures, such as network isolation, data classification and classification, encryption technology (such as TLS, SSL), access control, identity authentication, malicious code prevention, and Identification and anonymization processing.

(2) We have established management systems, procedures and organizational arrangements for the protection of personal information, such as stipulating employee confidentiality obligations, clearly stipulating employee access rights, conducting regular employee training, and retaining personal information Process activity records and implement security audits on various measures.

2. We have formulated an emergency plan for personal information security incidents and conducted emergency drills. In the event of personal information leakage, damage, loss and other security incidents, we will promptly activate emergency plans and take disposal and remedial measures. In accordance with the requirements of laws and regulations, we will inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and suggestions that you can independently prevent and reduce risks by email, letter, telephone or push notification. , Remedial measures for you, etc.; if it is difficult to inform the subject of personal information one by one, we will notify you by way of an announcement. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

3. Please be aware that although we have taken reasonable measures to protect your personal information, no system or network is absolutely secure. We also remind you that you are using the products and Pay full attention to the protection of personal information during the service.

8. How do you manage your personal information

During your use of the course, you can access, correct, delete your personal information, and exercise the rights to change the scope of authorization and consent and cancel your account. Your comments will be processed in a timely manner.

1. Access your personal information

You have the right to access your personal information, except for exceptions provided by laws and regulations. If you want to exercise data access rights, you can take the following measures:

(1) If you need to access your personal account information, user information, and settings, you can access it on the "My" interface.

(2) If you need to access your chat information, you can access it on the "Class"-"Chat" interface.

(3) If you need to access your cloud disk information, you can access it on the "Courseware Library Management" interface.

(4) If you need to access your course information, such as the course schedule and recorded lesson videos, you can access it on the "Backstage" interface.

2. Modify or correct your personal information

If you need to modify your user information, you can make changes according to the relevant prompts on the "My" interface. If you find that the personal information we have collected and stored is wrong, you can also contact us and ask us to make corrections.

3. Delete your personal information

In the following situations, you can contact us to request us to delete personal information, unless it has been anonymized or otherwise provided by laws and regulations:

(1) We collect and use personal information in violation of laws and regulations or the agreement with you;

(2) If we share or transfer your personal information with a third party in violation of laws and regulations or the agreement with you, we will immediately stop sharing and transfer, and notify the third party to delete it in time;

(3) If we publicly disclose your personal information in violation of laws and regulations or the agreement with you, we will immediately stop public disclosure and issue a notice requesting the relevant recipient to delete the corresponding information;

(4) You no longer use our products or services, or you cancel your account, or we terminate the service and operation. When you delete information from our service, we may not delete the corresponding information in the backup system immediately, but we will delete the information when the backup is updated.

4. Change the scope of your authorization

In the process of using our services, you can change the scope of your authorization and consent, and withdraw your authorization and consent at any time.

If you wish to withdraw the authorization of camera, photo album, microphone, and address book permissions, you can choose to disable some or all permissions in the device settings.

In addition to the personal information necessary for basic business functions, for the collection and use of additional personal information, you can contact us to change the scope of your authorization and consent.

After you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.

5. Cancel account

If you want to cancel your account, please contact us. When your account meets the following conditions, we will complete the verification and account cancellation within 15 working days:

(1) The account is in a normal state, does not involve any disputes (including complaints or reports), and has not been restricted by the competent authority;

(2) There are no unfinished courses in the account;

(3) There are no other outstanding rights and obligations or disputes arising from account cancellation;

(4) Other situations that may affect account cancellation.

Your cancellation of the above account is irreversible. We will stop providing you with products or services, no longer collect your personal information, and delete personal information related to your account or Make anonymization, except as otherwise provided by laws and regulations or otherwise required by regulatory authorities.

6. In response to your above request

If you are unable to exercise your rights in the above manner, you can contact us. To ensure safety, you may need to provide a written request, orTo prove your identity. We may ask you to verify your identity before processing your request.

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. We may reject requests that are unreasonably repeated, require excessive technical means, bring risks to the legitimate rights and interests of others, or are very unrealistic.

In the following situations, we may not be able to respond to your request:

(1) Related to our fulfillment of obligations under laws and regulations;

(2) Directly related to national security and national defense security;

(3) Directly related to public safety, public health, and major public interests;

(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

(5) We have sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;

(6) In order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the consent of the person;

(7) Responding to the personal information subject’s request will cause serious damage to the legal rights and interests of the personal information subject or other individuals or organizations;

(8) Involving trade secrets.

7. Complaints and reports

If you have any complaints or reports on the processing of your personal information, please contact us. We will respond to your complaints or reports within 15 working days.

9. How do we deal with the personal information of minors

We attach great importance to the protection of personal information of minors. According to relevant laws and regulations, the collection and use of personal information of minors under the age of 14 requires the authorization and consent of the guardian; the collection and use of personal information of minors under the age of 14 and 18 can be authorized and agreed by the guardian Or authorize and agree on your own.

If you are a minor (especially a minor under the age of 14), we ask you to ask your parents or other guardians to read this privacy policy carefully, and seek your guardian Use our services or provide us with information under the premise of authorization.

If you are the guardian of a minor, please pay attention to whether the minor under your guardianship uses our products or services after your authorization. If you have any questions about the personal information of minors under your guardianship, please contact us through the methods specified in this privacy policy.

10. How to update this privacy policy

We may revise this privacy policy in due course. If the content of the privacy policy changes, we will prompt you through pop-ups, red dots, pushes or other appropriate methods. Without your explicit consent, we will not reduce your rights in accordance with this privacy policy. Please read the content of the revised privacy policy carefully. If you continue to use the course, you agree that we will process your personal information in accordance with the updated privacy policy; if you do not agree, please stop using the course.

11. How to contact us

If you have any questions, comments or suggestions about this policy or personal information protection, please contact us in the following ways:

E-mail: mkt@Menke.com

Customer Service Tel: 400-881-9892

After receiving your questions, comments or suggestions, and verifying your user identity, we will reply within fifteen working days.