Release date: December 1, 2024
Effective Date: December 1, 2024
Update Date: December 1, 2024
Your personal information security is crucial to us. For a long time, the No. 1 Scholar Church Education has been
committed to providing each user with a more secure Internet environment. We will collect and use your personal
information in accordance with the Cybersecurity Law of the People's Republic of China, the Personal Information
Security Specification for Information Security Technology (GB/T 35273-2020), and other relevant laws, regulations,
and technical specifications to help us provide you with better quality products and/or services. We are committed
to maintaining your trust in us, adhering to the following principles, and protecting your personal information: the
principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of selective
consent, the principle of minimum necessity, the principle of ensuring security, the principle of subject
participation, and the principle of openness and transparency. The "VVClass Privacy Protection Guidelines"
(hereinafter referred to as "these guidelines") will present in a more transparent manner our collection and use of
your personal information, as well as your control over personal information. We promise to strictly keep your
personal information and other data confidential, and process your personal information strictly in accordance with
the content outlined in this guideline. We will collect, use, store, share, and transfer your personal information
based on your consent and other legal grounds for processing your personal information.
The following are the key points of this guide:
To assist you in registering and using our products or services, we may collect personal information related to
providing services, and you have the right to refuse or withdraw authorization;
2. You can access, correct, and delete your personal information. We provide you with a way to exercise these
rights by changing the scope of your authorization and cancelling your account.
3. We have taken standard technical measures and data security measures in the Internet industry to protect your
personal information security.
4. Unless we obtain your consent again, we will not use your personal information for purposes not specified in
this guideline.
5. If you have any questions about this guide, you can contact us further for consultation.
6. Please ensure that you are a person over 18 years old; If you are a minor under the age of 18, before using
our products and/or services, you should read this guide and the VVClass Children's Privacy Policy with the
accompaniment of your guardian, and ensure that you have obtained the consent of your guardian before using our
products.
To better protect your personal information, we recommend that you carefully and fully read and understand this
guide before using our products or services.
Catalog
1. Introduction
2. The legal basis for our processing of personal information
3. How do we collect and use your personal information
4. How do we share, transfer, and publicly disclose your personal information
5. How do we protect your personal information?
6. Your right to manage personal information
7. Notice We Issued
8. How do we use similar technologies such as cookies
9. Storage of your personal information
10. How do we handle the personal information of minors
11. How to update this guide
12. How to contact us
13. Dispute Resolution
14. Noun Explanation
15. Third party services
1. Introduction
This guide is only intended for Shenzhen kaoba education technology co., Ltd. and its affiliated companies
(hereinafter referred to as "us") that provide VVClass App products and services
【 Special Reminder 】
Please carefully read and fully understand this guide before using our products and/or services. We have
highlighted the key content in bold and hope you will pay special attention to it. Once you use or continue to
use the products/services of Zhuangyuantang Education, it means that you agree to us processing your relevant
information in accordance with these guidelines. If you have any questions about this guide, you can contact us
through the contact information provided in the "How to Contact Us" section of this guide.
In order to facilitate your understanding of the relevant concepts in this guide, we have underlined proprietary
names and provided detailed explanations in Section 15 "Noun Explanation" of this guide. The upper right corner
of the relevant terms in this guide is marked with "*", representing sensitive information related to the
collection of Zhuangyuantang education. We will provide you with an enhanced reminder.
We may revise this guideline from time to time. When there are changes to this guideline, we will display the
updated content to you in the form of notifications or pop ups after the version update.
Please note that we will only collect, use, process, and store your personal information in accordance with the
updated VVClass Privacy Protection Guidelines after you confirm your agreement to the changes; You can choose
not to agree, but this may prevent you from fully using VVClass App's products and services.
2. Legal Basis for VVClass to Process Personal Information
If you are a user in mainland China, we will collect and use your personal information in accordance with the
Cybersecurity Law of the People's Republic of China, the Personal Information Security Specification for Information
Security Technology (GB/T 35273-2020), and other relevant laws and regulations to provide you with VVClass App
products and services. We usually only collect your personal information with your consent. In some cases, we may
also collect personal information from you based on legal obligations or necessary contractual obligations, or may
require personal information to protect your important interests or the important interests of others.
3. How do we collect and use your personal information
We will follow the principles of legitimacy, legality, and necessity to collect and use personal information that
you voluntarily provide or generate due to the use of Zhuangyuantang education products and/or services during the
service process for the following purposes as described in this guideline. If we want to use your personal
information for purposes not specified in this guide, or for specific purposes, we will inform you in a reasonable
manner and obtain your consent again before use.
We will obtain your personal information through the following channels:
3.1 Register Account
When you register and log in to a VVClass account, you need to provide us with the following information: account
name (if any), avatar (if any), and mobile phone number (for real name authentication). After providing the above
information and agreeing to this guideline, you can use VVClass's core business functions, including browsing
content within the app. If you choose not to provide the necessary information for implementing core business
functions or for using a certain type of function, it will result in us being unable to provide you with that
function.
3.1.2. When you register for a VVClass account, we recommend that you provide your phone number for real name
authentication. If you refuse to provide your phone number for real name authentication, it will result in the
inability to use core business functions.
3.1.3 We may indirectly obtain your personal information from third parties
A. When you log in to VVClass using a third-party account (WeChat, Apple), you can choose to authorize VVClass
to read and obtain the public information (including nickname, avatar) that you have registered, published, and
recorded on the third-party platform, subject to compliance with relevant laws and regulations.
B. VVClass requires your authorization to obtain the above information from third parties in order to remember
your login identity as a VVClass user and provide you with higher quality products and/or services. We will only
collect and use your personal information within the scope of your authorized consent. After you register or log
in with a third-party account, your third-party account will be bound to the VVClass account, and you can also
choose to close or cancel the account binding.
Please note that if you disclose your information in response to information uploaded or published by others in
a public area visible to other users in the VVClass service, the information may be collected and used by
others. When you discover that others are improperly collecting or using your information, you can contact us
through the feedback channels listed in "How to Contact Us" of this policy.
3.2 Provide you with the core business functions of products and/or services
To achieve the core business functions of VVClass, we may need to collect personal information from you.
You understand and agree that we hope to provide you with comprehensive products and services, so we will
continuously improve our products and services. This means that as our products and services iterate, expand,
and upgrade, we may frequently introduce new services or business functions or redefine functions, and may need
to collect new personal information or change the purpose or method of using personal information. Please note
that if we want to use your personal information for purposes not specified in this guide or collect additional
personal information not mentioned, we will obtain your consent through page prompts, interactive processes,
website announcements, or other means. Once you agree, this additional use will be considered part of this
guide, and this additional information will also be subject to this guide. If you have any questions during this
process, you can contact us through the feedback channels listed in "How to Contact Us".
3.2.1 Browsing and Functions.
Permission Function Description: Collect device information, device model, unique device identifier, operating
system, and telecom operator software and hardware information when using VVClass App.
Usage scenario and purpose: To provide you with the optimal solution for information display
In addition, during your use of the browsing and bookmarking functions, we will automatically collect detailed
information about your use of the VVClass App and save it as relevant network logs, including but not limited to the
search keyword information and clicked links you enter, the voice over works you browse and publish, the image
information you upload, your transaction information, the language you use, the date and time of visit, as well as
the video records you browse, operating system, software version number, and login IP information. During this
process, we will collect your browsing history.
3.2.2 Recording/microphone function.
Permission Function Description: Use microphone to record audio
Usage scenario and purpose: Used to assist you in completing video dubbing, reading, and feedback related functions.
3.2.3 Album function and camera function.
Permission Function Description: Set avatar, background image, and post images in chat.
Usage scenario and purpose: Used to replace your avatar, select the image to be replaced in your album. Adding album
pictures or camera photos in the problem feedback can provide more intuitive feedback on the issue.
3.2.4 Enable WLAN.
Usage instructions: Use WIFI data
Purpose of use scenario: When there is WIFI, you can choose to turn on the WLAN function and use this product under
WIFI to save your data.
3.2.5 Collect IMEI device MAC addresses.
Instructions for use: Use device information (unique device identifier (IMEI), device MAC address)
Purpose of use scenario: Installation list for identity verification and transaction risk assessment.
3.2.6 Installation List.
Instructions for use: The work can be shared to the WeChat mini program.
The purpose of the usage scenario is to determine whether WeChat has been installed before sharing. If it has not
been installed, it will prompt to install WeChat first. Share with other third-party applications as well.
3.2.7 Vector Sensor: (Specific Type Sensor)
Instructions for use: WebView will automatically call the sensor
Usage scenario: All web browsing within the app, including but not limited to privacy protection guidelines, usage
agreements and version statements, institutional registration, invited members, etc
3.2.8 Storage
Instructions for use: Read and write information
Purpose of use: Used for reading and writing content in video creation, work download, video recording, work
publishing, content sharing, avatar replacement, teacher authentication, and other scenarios
3.2.9 Obtaining Paste Board Information
Instructions for use: Copy and paste information
Purpose of use scenario: You can use the clipboard function when copying information from third-party platforms to
Qudub or pasting information from Qudub to third-party platforms. Read the paste board to match our fixed text
format, and after parsing, a pop-up will prompt whether to jump to the specified page. Enhance the functional
experience. If you disable the system access clipboard function, it will only affect the user experience, but it
will not affect the use of basic functions.
3.2.10 Acceleration Sensor
Instructions for use: Adjust the direction of video playback
Purpose of use scenario: When you play English dubbing videos, we will obtain permission for your device's
acceleration sensor. When the direction of your device changes, the direction of the video playback will also change
accordingly.
3.2.11 Monitoring Call Status
Instructions for use: Control video playback
Usage scenario purpose: When a user uses the listening content service and detects a system call, the video will
automatically stop playing
3.2.12 Monitoring Network Status
Instructions for use: Notify users of network status
Scenario purpose: When the network becomes unavailable, prompt the user that there is currently no network available
3.3 Maintain account security, ensure normal service operation, and optimize service experience.
In the process of using the service, in order to identify abnormal account status, link product compatibility,
provide you with basic services such as browsing and searching, ensure the normal operation of the service, optimize
the service experience, we may directly or indirectly collect and store information about the services you use and
how you use them, and associate this information, including:
(a) Log permission: When you use our services, we may automatically (including running in the background) collect
detailed usage information about our services as network logs, including your login account, search query content,
IP address, browser type, telecom operator, network environment, language used, access date and time, as well as
your browsing history, push open history, dwell time, refresh history, publishing history, follow, subscribe,
bookmark, and share.
(b) Device Permissions: Based on your software installation and specific permissions granted by you, we may accept
and record (including receiving records while running in the background) device related information you use: device
information, operating system and version, client version, device resolution, package name, device settings, device
identifier (IMEI/AndroidID/OPEN UDID/GUID/MAC OAID/IDFA/SIM card IMSI information), and device location related
information (IP address). In order to collect the personal device information mentioned above, we will apply for
access to your device related permissions, including device information permissions, location permissions, etc.
Please note that individual device information and log information cannot identify specific individual identity
information. If we combine this type of non personal information with other information to identify a specific
natural person's identity, or use it in conjunction with personal information, during the combined use period, this
type of non personal information will be considered personal information. Unless authorized by you or otherwise
provided by laws and regulations, we will anonymize or de identify this type of personal information. During the
period of combined use, this information will be processed and protected as your personal information in accordance
with this guideline.
3.4 Provide you with additional business functions for VVClass products and/or services
In order to provide you with better quality products and services, we may need to collect the following information.
If you refuse to provide the following information, it will not affect your normal use of core business functions,
but we cannot provide you with certain specific functions and services.
3.4.1 Customer Service.
When you file a complaint, appeal or consult with VVClass, in order to facilitate contact with you or help you solve
the problem, we may need you to provide personal information such as name, phone number, email and other contact
information. If you refuse to provide the above information, we may not be able to provide you with timely feedback
on the results of your complaint, appeal, or consultation.
3.4.2 Payment function.
You can purchase membership on VVClass. You may need to pay when using this function. During the payment process, we
will complete payment verification and payment through the SDK of your third-party payment account (such as Alipay
account, Apple Pay account, WeChat account and other information).
Your relevant information is used for tax payment on behalf of others.
3.5 Sensitive Information
Before providing any personal information that belongs to sensitive information to VVClass, please carefully
consider whether the provision is appropriate and agree that your personal sensitive information may be processed
for the purposes and in the manner described in this guideline. We will collect and use your sensitive information
with your consent to achieve functions related to VVClass business, and allow you to make different opinions on the
collection and use of this sensitive information. However, refusing to use this information will affect your use of
related functions.
3.6 Exceptions to Obtaining Authorization Consent
According to relevant laws and regulations, we may collect and use necessary personal information without your
authorization and consent in the following situations:
(a) Directly related to national security and defense security;
(b) Directly related to public safety, public health, and major public interests;
(c) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(d) For the purpose of safeguarding your or other individuals' significant legitimate rights and interests in life
and property, but it is difficult to obtain my consent;
(e) The personal information collected is disclosed by you to the public on your own;
(f) Collecting your personal information from legally disclosed information, such as from legitimate news reports
and government information disclosure channels;
(g) Necessary to sign and fulfill the contract according to your requirements;
(h) Necessary for maintaining the safe and stable operation of VVClass products and/or services, such as detecting
and handling product or service failures;
(i) Other circumstances stipulated by laws and regulations.
3.7 If you have any questions or need further information regarding the legal basis for our collection and use of
your personal information, please contact us through the contact information provided in the "How to Contact Us"
section.
4. How do we share, transfer, and publicly disclose your personal information
4.1 Sharing Your Personal Information
（1） Entrustment processing
Some specific sections or functions in this business function are provided by external suppliers. We will hire
service providers to assist us in providing customer support.
VVClass may access or link to social media or other services provided by third parties (including websites or other
forms of services). Including:
(a) You can use the "Share" button to share certain content in VVClass with third parties. Alternatively, you can
use third-party services to log in to VVClass. These features may collect your information (including your log
information) and may have cookies built into your device to enable the normal operation of the aforementioned
functions;
(b) Provide you with links through advertising or other means of our services, allowing you to access third-party
service websites;
(c) Other forms of third-party access.
（2） Share
We will not share your personal information with any company, organization, or individual outside of our company
unless we have obtained your explicit consent. At present, in order to achieve the purposes stated in this
guideline, we integrate third-party services or other similar applications (embedded code, plugin form) to provide
better customer service and customer experience. We will seek your authorization and consent to share personal
information in the following situations.
At present, our authorized partners include the following types:
(a) Used for advertising and analysis services, including display, advertising statistics, and monitoring;
(b) Used for message push function, including push notifications from mobile phone manufacturers and specific time
reminders;
(c) Used for payment related services, including order payment, transaction behavior verification, revenue
settlement, and payment information summary and statistics;
(d) Used to obtain device location permissions with your consent, collect device information and logs;
(e) Used for third-party authorization services, including third-party account login and sharing relevant content to
third-party products;
(f) Used to support product functions, including video playback, intelligent customer service, voice recognition,
content storage, and intelligent scoring;
(g) Used to optimize product performance, including improving hardware distribution capabilities, reducing server
costs, and performing functional hot repairs;
(h) Used for account security and product reinforcement related services, including network monitoring and domain
name resolution.
We will sign strict confidentiality agreements with the companies, organizations, and individuals we entrust to
process personal information. We will conduct strict security monitoring on the software development kits (SDKs) and
application programming interfaces (APIs) obtained by our partners to ensure data security. And require them to
process personal information in accordance with our requirements, this guideline, and any other relevant
confidentiality and security measures. Access to Third Party SDK Catalog "provides detailed information on the names
of third-party SDKs that VVClass accesses, the types of personal information collected, and user information.
Third party social media, third-party payments, or other third-party services are operated by the relevant third
parties. Your use of this third-party service (including any information you provide to the third party) is
subject to the third party's own terms of service and information protection statement (not this guide), and you
need to carefully read its terms. This guideline only applies to the personal information we collect and does
not apply to any third-party services or information usage rules provided by third parties. If you find that
these third-party services pose risks, we suggest that you terminate the relevant operations to protect your
legitimate rights and interests and contact us in a timely manner.
4.2 Transfer
We will not transfer your personal information to any company, organization, or individual unless we obtain your
explicit consent. If a merger, acquisition, or bankruptcy liquidation occurs, it may involve the transfer of
personal information, in which case we will require the new company or organization holding your personal
information to continue to be bound by this guideline. If there is any change in the collection and processing of
personal information as stipulated in this guideline, the company or organization will seek your authorization and
consent again.
4.3 Public Disclosure
We will not publicly disclose your personal information unless we obtain your explicit consent.
We may disclose your personal information to authorized authorities based on laws, legal procedures, lawsuits, or
mandatory requirements from government regulatory agencies. But we guarantee that in the event of the above
situation, we will require the disclosing party to provide corresponding valid legal documents and take security
measures that comply with laws and industry standards for the disclosed information.
(a) Obtaining your explicit authorization or consent in advance: After obtaining your explicit consent, we will
share your personal information with other parties;
(b) Sharing under legal circumstances: Your personal information needs to be shared in accordance with applicable
laws, regulations, legal procedures, government orders, or judicial rulings;
(c) Within the scope required or permitted by law, it is necessary to provide your personal information to third
parties in order to protect the interests, property, or safety of VVClass, its users, or the general public from
harm;
(d) Sharing with our affiliated companies: Your personal information may be shared between our affiliated companies.
We will only share necessary personal information, and this sharing is subject to the purposes stated in this
guideline. If affiliated companies want to change the purpose of processing personal information, they will seek
your authorization and consent again.
(e) Shared with authorized partners: In order to provide you with higher quality and more comprehensive products and
services, some of our services will be provided by authorized partners. We may share some of your personal
information with our partners to provide better customer service and user experience (such as when VVClass sends
gifts to you, VVClass needs to share your personal information with the logistics service provider to arrange
delivery). We will only share your personal information for legal, legitimate, necessary, specific, and clear
purposes, and will only share personal information necessary for providing services. At the same time, we will sign
strict confidentiality agreements with our partners, requiring them to handle your personal information in
accordance with our instructions, this guideline, and any other relevant confidentiality and security measures. Our
partners have no right to use the shared personal information for any other purpose. If you refuse our partners to
collect personal information necessary for providing services, it may result in you being unable to use the
third-party service in VVClass.
4.4 Exceptions to Authorization Consent for Sharing, Transfer, and Public Disclosure of Personal Information
According to relevant laws and regulations, we may share, transfer, and publicly disclose your personal information
without your authorization and consent in the following situations:
(a) Related to national security and defense security;
(b) Related to public safety, public health, and major public interests;
(c) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(d) For the purpose of safeguarding your or other individuals' significant legitimate rights and interests in life
and property, but it is difficult to obtain my consent;
(e) Personal information that you disclose to the public on your own;
(f) Personal information collected from legally disclosed information, such as legitimate news reports and
government information disclosure channels;
(g) Other circumstances stipulated by laws and regulations.
According to legal regulations, sharing and transferring personal information that has undergone de identification
processing, and ensuring that the data recipient cannot recover and re identify the personal information subject,
does not constitute external sharing, transfer, or public disclosure of personal information. The storage and
processing of such data will not require separate notification to you and your consent.
5. How do we protect your personal information
Your personal information security is crucial to us. We will strictly comply with relevant laws and regulations,
take reasonable and feasible measures recognized by the industry, protect your personal information, prevent
unauthorized access, disclosure, use, modification of information, and avoid information damage or loss.
5.1 Technical Measures and Data Security Measures
We strive to adopt various physical, electronic, and management security measures that comply with industry
standards to protect the security of your personal information. We actively establish a data classification and
grading system, data security management standards, and data security development standards to manage and regulate
the storage and use of personal information, ensuring that personal information unrelated to the services we provide
is not collected.
5.2 We only allow employees who need to know this information to access your information, and have established
strict access control, permission application mechanisms, and monitoring mechanisms for this purpose. We also
require all personnel who may have access to your information to fulfill corresponding confidentiality obligations.
If these obligations are not fulfilled, legal responsibility may be pursued or the cooperation relationship with
VVClass may be terminated.
5.3 The Internet is not 100% secure. We will try our best to ensure the security of any information you send us. We
conduct comprehensive security controls on data security by signing confidentiality agreements, monitoring and
auditing mechanisms with information contacts, to prevent unauthorized access, public disclosure, use, modification,
damage or loss of your personal information.
We have implemented industry standard security measures to protect the personal information you provide, preventing
unauthorized access, public disclosure, use, modification, damage, or loss of your personal information. We will
take all reasonable and feasible measures to protect your personal information (data exchanged between your mobile
phone and VVClass, such as bank account information, is encrypted and protected); And we will hold security and
privacy protection training courses to enhance employees' awareness of the importance of protecting personal
information.
According to the relevant provisions of the "Management Measures for Information Security Level Protection",
Zhuangyuantang Education has obtained a record certificate of information security level protection level three.
5.4 Security Incident Handling
We will try our best to ensure the security of any information you send us, but please understand that due
to technical restrictions and various malicious means that may exist in the Internet industry, it is impossible
to always guarantee the security of information 100%. You need to understand that the system and communication
network you use to access our services may encounter issues due to factors beyond our control.
To prevent safety accidents, we have established a proper warning mechanism and emergency plan. If a personal
information security incident unfortunately occurs, we will promptly inform you in accordance with the requirements
of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we
have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for
you, and immediately activate emergency plans to minimize losses. We will promptly inform you of the relevant
situation of the event through phone calls and notifications. If it is difficult to inform users one by one, we will
adopt a reasonable and effective way to publish announcements.
At the same time, we will proactively report the handling of personal information security incidents in accordance
with regulatory requirements and closely cooperate with government agencies.
6. Your right to manage personal information
We encourage you to update and modify your information to make it more accurate and effective. We will take
appropriate measures to set up, guide, or provide contact channels for submitting applications, to ensure that you
can access, update, and correct your own information or other information provided when using VVClass as much as
possible. If you want to query, modify or delete some of your information, please log in to VVClass for relevant
operations, or contact us through the contact information provided in this guide for processing.
6.1 Accessing and Correcting Your Personal Information
You can check and modify your profile picture, nickname, and other information through
[Me] - [Data
Modification]
6.2 Account Cancellation
We provide you with the function to cancel your account and delete your personal information. Subject to policy
agreements and relevant national laws and regulations, you can choose to delete the personal information you have
posted on the VVClass platform. You can go to the (Me Settings Cancel Account) page or call the
VVClass
email【 hr@xyedu.net 】Cancel your personal information
After submitting the cancellation application, if there are still funds in your account, you can contact customer
service to cancel the account within 15 days. If there are no funds in your account, please cancel it immediately.
We will stop using and delete or anonymize your personal information, and we will no longer be able to provide
services to you.
If you have any questions about the cancellation process, you can contact VVClass via email【 hr@xyedu.net 】Complaint
feedback, we will handle the relevant complaints within 15 working days.
6.3 In the following circumstances, you may request the deletion of personal information from us:
(a) If our handling of personal information violates laws and regulations;
(b) If we collect and use your personal information without your consent;
(c) If our handling of personal information violates our agreement with you;
(d) If you cancel your VVClass account;
(e) If we terminate our services and operations.
If you have any questions about deleting personal information, you can contact VVClass via email【 hr@xyedu.net
】Complaint feedback, we will handle the relevant complaints within 15 working days.
6.4 Change the scope of your authorized consent or revoke your authorization
You can delete the app or log out of the account by going to "Me Settings Cancel Account" or VVClass email in the
app【 hr@xyedu.net 】The customer service representative will revoke all authorization for us to collect your personal
information and privacy agreement authorization. After you cancel your account, we will immediately delete your
personal information or authorization permissions. When reopening, we will need to obtain your authorization again.
Please understand that each business function requires some basic personal information to be completed. When you
revoke your authorization, we will no longer be able to provide you with the services corresponding to the
revocation of authorization, nor will we process your corresponding information. But your decision to revoke
authorization will not affect the information processing previously carried out based on your authorization. Note:
Withdrawing consent to collect personal information means revoking authorization under the Privacy Policy.
You can contact customer service through【 hr@xyedu.net 】Contact us to assist you in canceling your account, changing
the scope of your authorization or revoking your authorization.
In the process of providing services, we may require you to grant some device permissions, such as notification,
storage, photo album, and microphone access permissions. You can also choose to disable some or all permissions in
the "Me Settings" section of the app to refuse us from collecting your corresponding personal information. Note: The
display and closing methods of permissions may vary among different devices. Please refer to the instructions or
guidelines provided by the device and system developers for specific details.
6.5 Obtain a copy of your personal information
You have the right to obtain a copy of your personal information. If you need to obtain a copy of the personal
information we have collected from you, you can contact our customer service for assistance【 hr@xyedu.net 】The human
customer service will verify your personal information, complete the confirmation of your name, phone number,
VVClass nickname, and VVClassID number as the subject of your personal information, and submit a copy of your
personal information to you via email. Subject to compliance with relevant legal regulations and technical
feasibility, we will provide you with a copy of your personal information upon your request.
6.6 Responding to your above request
Any questions, suggestions, opinions, or complaints you may have can be addressed by contacting customer service【
hr@xyedu.net 】Contact our customer service to submit. To ensure security, we will process the necessary identity
information after verification, and will provide a response within no more than 15 working days or within the legal
and regulatory deadline. We generally do not charge any fees for your reasonable requests. However, according to
relevant laws, regulations, and national standards, we may not be able to respond to your request in the following
situations:
(a) Directly related to national security and defense security;
(b) Related to public safety, public health, major public interests, etc;
(c) Related to criminal investigation, prosecution, trial, and execution of judgments;
(d) There is sufficient evidence to suggest that you have subjective malice or abuse of power;
(e) For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as
life and property, but it is difficult to obtain your consent;
(f) Responding to your request will result in serious harm to the legitimate rights and interests of other personal
information subjects or individuals or organizations;
(g) Involving trade secrets.
7. Notifications We Send
7.1 When you use VVClass services, we may use your personal information to send message notifications to your
device.
You can choose whether to accept our system messages through the 'Message' feature.
7.2 Service related announcements
We may issue some service related announcements to you from time to time when we deem it necessary (such as when we
suspend VVClass services for repairs). You are not allowed to cancel these service related announcements that are
not promotional in nature.
8. How do we use similar technologies such as cookies
Cookies, device information identification and other similar technologies are widely used in the Internet. When you
use VVClass and related services, we may use relevant technologies to send one or more cookies or anonymous
identifiers to your device to collect and identify information about your access and use of this product. We promise
not to use cookies for any purposes other than those described in this guide. We use cookies and similar
technologies mainly to achieve the following functions or services:
8.1 Ensure the safe and efficient operation of products and services
We may set authentication and security cookies or anonymous identifiers to confirm whether you have safely logged
into the service or encountered theft, fraud, and other illegal activities. These technologies will also help us
improve service efficiency, enhance login and response speed.
8.2 Help you achieve a more relaxed access experience
Using this type of technology can help you avoid the steps and processes of repeatedly filling in personal
information and entering search content (e.g. recording searches, filling out forms).
9. Storage of Your Personal Information
We will store the information obtained from within the territory of the People's Republic of China. If there is a
cross-border transmission of data, we will separately inform you of the purpose and recipient of the data export
through pop ups or emails, and obtain your authorization and consent. We will ensure that the data recipient has
sufficient data protection capabilities to protect your personal information.
We only retain your personal information for the shortest time necessary to achieve our purpose:
The Cybersecurity Law stipulates that log information shall not be less than 6 months;
The Electronic Commerce Law stipulates that transaction information shall not be less than three years from the date
of completion of the transaction;
The Measures for the Administration of Internet Information stipulates that the handling method shall not be less
than 60 days and overdue.
After exceeding the above-mentioned personal information retention period, personal information will be anonymized.
If we cease operations due to poor management or other reasons, we will immediately stop collecting your personal
information and delete the collected personal information. We will announce this situation on the app or communicate
it to each user through private messages and other reasonable means.
10. How do we handle the personal information of minors
10.1 VVClass's services cover both minors and adults. If you are a minor under the age of 14, you should read this
guide with your guardian before using our products and/or services, and ensure that you have obtained the consent of
your guardian before using our products and providing us with your information. We will focus on protecting the
information of minors in accordance with relevant national laws and regulations.
10.2 If your guardian disagrees with your use of our services or provision of information to us in accordance with
these guidelines, please immediately terminate your use of our services and notify us promptly.
10.3 In cases where personal information of minors is collected with the consent of parents or legal guardians, we
will only use or publicly disclose this information when permitted by law, with the explicit consent of parents or
guardians, or when necessary to protect minors.
10.4 If you are the guardian of a minor, please contact us promptly if you have any questions about the use of our
services or the user information provided to us by the minor under your guardianship. We will protect the
confidentiality and security of underage user information in accordance with relevant national laws and regulations
and the provisions of this guideline. If we find that we have collected personal information of minors without
obtaining verifiable consent from their parents or legal guardians in advance, we will delete the relevant data as
soon as possible.
11. How to update and modify this guide
11.1VVClass reserves the right to update or modify this guideline from time to time.
11.2 Without your explicit consent, we will not reduce the rights you are entitled to under this guideline. We will
notify you through reasonable means such as app notifications, pop ups, etc., so that you can be informed of any
changes made to this guideline in a timely manner.
11.3 For significant changes, depending on the specific circumstances, we may provide more prominent notices
explaining the specific changes in this guideline. Major changes include but are not limited to:
(a) Our service model has undergone significant changes. Such as the purpose of processing personal information, the
type of personal information processed, and the way in which personal information is used;
(b) We have undergone significant changes in ownership structure and organizational structure. Changes in ownership
caused by business adjustments, bankruptcy mergers and acquisitions;
(c) The main objects of personal information sharing, transfer or public disclosure have changed;
(d) There has been a significant change in your right to participate in personal information processing and the way
you exercise it;
(e) Our responsible department, contact information, and complaint channels for handling personal information
security have changed;
(f) When there is a high risk in the personal information security impact assessment report.
11.4
If you do not agree with the revised privacy protection guidelines, you have the right and should
immediately stop using VVClass's services. If you continue to use VVClass's services, it will be deemed that you
accept the modifications made by VVClass to the relevant terms of this guideline.
12. How to contact us
12.1 If you have any questions about this guide, you can contact VVClass via email【 hr@xyedu.net 】Contact us. We
will reply to you as soon as possible.
If you have complaints, suggestions, or questions about personal information protection issues, you can also send
the questions via email【 hr@xyedu.net 】Contact us. Or mail to the following address:
Shenzhen kaoba education technology co., Ltd
Zhongjian, No. 66 and 68 Jiefang Road, Shigu District, Hengyang City, Hunan Province Legal Department (Reception),
Room 11008, Hengyang Commercial Complex.
We will review the issues involved as soon as possible.
12.3 Generally, we will respond to your questions, opinions, or suggestions within fifteen working days after
verifying your user identity. If you are not satisfied with our response and we still refuse to improve after you
provide us with feedback, you can also file a complaint with the consumer rights protection department or file a
lawsuit with a court with jurisdiction.
13. Dispute Resolution
13.1 In case of any disputes arising from this guideline or our handling of your personal information, you may
report to the relevant government departments.
13.2 If you believe that our personal information processing has harmed your legitimate rights and interests, you
may also report to the relevant government departments.
14. Noun Explanation
The nouns used in this guide have the following definitions in their usual meanings:
14.1 Personal Information: Personal information refers to various types of information recorded electronically or in
other ways that can be used alone or in combination with other information to identify the personal identity of a
natural person, including but not limited to the person's name, date of birth, address, and phone number.
14.2 Personal Sensitive Information: Personal sensitive information refers to personal information that, once
leaked, illegally provided, or abused, may endanger personal and property safety, and is highly likely to cause
damage to personal reputation, physical and mental health, or discriminatory treatment. Personal sensitive
information includes ID card number, bank account number, communication content, health and physiological
information.
14.3 Equipment: Equipment refers to devices that can be used to access VVClass products, such as tablets or
smartphones.
14.4 Unique Device Identifier: A unique device identifier (unique ID, IMEI number, or UUID) refers to a string of
characters encoded into a device by the device manufacturer, which can be used to uniquely identify the device.
14.5 IP address: Each Internet device will be assigned a number, which is called Internet Protocol (IP) address.
These numbers are usually assigned based on geographic regions. IP addresses are often used to identify where a
device is connected to the Internet.
14.6 SSL: It is a secure protocol implemented over the Transmission Communication Protocol (TCP/IP). SSL supports
various types of networks and provides three basic security services, all of which achieve information
confidentiality through the use of public key and symmetric key technologies.
14.7 Affiliated Company: Refers to any company or institution that one party currently or in the future controls, is
controlled by, or is under common control with. 'Control' refers to the ability to directly or indirectly influence
the management of the mentioned company, whether through ownership, voting shares, contracts, or other legally
recognized means.
14.8 Non personally identifiable information: Information related to the user that is recorded but cannot directly
or indirectly identify your identity, including personal information provided through de identification,
anonymization, or pseudonymization.
14.9 De identification: refers to the process of using technical processing of personal information to make it
impossible to identify the subject of personal information without the need for additional information.
14.10 Anonymization: refers to the process of using technical processing of personal information to make the subject
of personal information unidentifiable and the processed information unrecoverable.
14.11 Server Log: Like most websites, our server automatically records the requests you make when accessing the app.
These "server logs" usually include your network request, Internet protocol address, browser type, browser language,
date and time of the request.
15. Third party services
1. To ensure the implementation of functions related to the Qiao VVClass APP and the safe and stable operation of
the application, we may integrate software development kits (SDKs) provided by third parties to achieve related
purposes.
2. We will conduct strict security monitoring on the software development kits (SDKs) used by our partners to obtain
information, in order to protect data security.
This app uses third-party SDKs that can collect personal information as follows:
SDK Name: APP Payment Client SDK
Developer: Alipay (Hangzhou) Information Technology Co., Ltd.
SDK Privacy Policy Link:
https://opendocs.alipay.com/open/54/01g6qm#%E6%94%AF%E4%BB%98%E5%AE%9D%20App%20%E6%94%AF%E4%BB%98%E5%AE%A2%E6%88%B7%E7%AB%AF%20SDK%20%E9%9A%90%E7%A7%81%E6%94%BF%E7%AD%96
Purpose: provide Alipay payment service
Collection method: automatic collection
Types/fields of personal information collected: device identification information (such as OAID, IMEI number, MAC
address, etc.) AndroidID、IDFA）、 Payment amount, progress list
SDK Name: WeChat OpenSDK Android
Developer: Shenzhen Tencent Computer Systems Co., Ltd
SDK Privacy Policy Link:
https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8
Purpose of use: To provide WeChat Pay services
Collection method: automatic collection
Types/fields of personal information collected: device identification information (such as OAID, IMEI number, MAC
address, etc.) AndroidID、IDFA）、 Payment amount, progress list
SDK Name: Baidu Statistics SDK
Developer: Beijing Baidu Netcom Technology Co., Ltd
SDK Privacy Policy Link:
https://tongji.baidu.com/web/help/article?id=330&type=0
Purpose of use: To statistically analyze user activity, frequency of feature usage, diagnose and fix crash issues,
anti cheating and security risk control
Collection method: automatic collection
Types of personal information collected: IMEI, Android ID, OAID, MAC address, hardware serial number, etc. (used to
uniquely identify the device), brand, model, operating system version, screen resolution, IP address, Wi Fi scan
results (such as WiFi list, MAC address, Wi Fi status, Wi Fi ssid, Wi Fi bsid, etc.), base station information,
network type, page access path, click event, crash log
SDK Name: Video and Audio SDK
Developer: Shanghai Soundnet Technology Co., Ltd
SDK Privacy Policy Link:
https://www.shengwang.cn/SDK-privacy-policy/
Purpose of use: To provide users with online audio and video call services
Collection method: automatic collection
Types of personal information collected: device identification information (such as OAID, IMEI number, MAC address,
etc.) AndroidID、IDFA）、 Dialogue audio and video, progress list
SDK Name: Interactive Whiteboard SDK, Fastboard SDK
Developer: Shanghai Soundnet Technology Co., Ltd
SDK Privacy Policy Link:
https://www.shengwang.cn/SDK-privacy-policy/
Purpose of use: To provide users with online interactive whiteboard teaching services
Collection method: automatic collection
Types of personal information collected: device identification information (such as OAID, IMEI number, MAC address,
etc.) AndroidID、IDFA）、 Process List