We treat user information security and privacy protection as our highest priority ("lifeline"). We adhere to the principle of "everything based on user value" and are committed to improving the transparency of information processing, enhancing the convenience of information management, and ensuring your information and communication security.
1、Safe and Reliable: We will make every effort through reasonable and effective information security technologies and management processes to prevent your information from being disclosed, damaged, or lost.
2、Autonomous Choice: We provide convenient information management options for you to make appropriate choices in managing your personal information.
3、Protection of Communication Privacy: We strictly follow laws and regulations to protect your communication privacy and provide you with secure communication services.
4、Reasonable and Necessary: To provide you and other users with better services, we only collect the necessary information.
5、Clear and Transparent: We strive to use clear and understandable expressions to introduce the privacy policy to help you clearly understand our information processing methods.
6、Privacy Protection Integrated into Product Design: We integrate the concept of privacy protection into every stage of product or service development, considering factors such as laws, products, and design.
7、The Software integrates third-party SDKs (e.g., DCloud uni-app) to enhance functionality. For details on data processing by these SDKs, please refer to the 《DCloud User Service Terms》, and during app operation, we need to collect your device's unique identifier (IMEI/android ID/DEVICE_ID/IDFA, SIM card IMSI information) to provide statistical analysis services, as well as analyze performance and user experience by application startup data and abnormal error logs. For more details, please visit the "DCloud User Service Terms".
8、Push Notification Service Provider: We engage third-party providers (e.g., Getui by Daily Interactive Co., Ltd.) for push notifications. By using the Software, you consent to their processing of device identifiers and network data as described in the《Getui User Privacy Policy.》After you agree to this Privacy Policy, when your app is in a silent state or running in the background, we may provide your device platform, device manufacturer, device brand, device identifier, software installation list information, network information, and location-related information to Daily Interactive Co., Ltd. for the purpose of providing you with push notification technology services. We will not collect your personal information in the background before obtaining your consent. When sending messages to you, we may authorize Daily Interactive Co., Ltd. to perform link adjustments and reactivate the SDK push process that has been closed, ensuring that you can receive the messages we push to you in a timely manner. For more details, please visit the "Getui User Privacy Policy."
What information we collect;
The purposes for which we collect information;
The rights you have.
We collect only the information necessary to achieve the functionality of our products based on the principles of legality, legitimacy, and necessity.
1.1 Information You Provide Actively When Using Our Services
1.1.1 Information You Fill in When Registering an Account
For example, the account, nickname, email, and phone number you provide when registering an account. Collecting this information helps complete your account registration and protect your account's security. Phone numbers are considered sensitive information, and collecting such information is necessary to comply with relevant legal requirements for real-name registration. Failure to provide such information may result in restricted access to core functionalities of the Software. You can also choose to provide other information such as gender and location according to your needs.
1.1.2 Information You Upload While Using the Service
For example, the avatar you upload when using our services.
1.1.3 Information You Submit via Customer Service or Events We Host For example, the name, phone number, and home address that you may provide in a survey when participating in our online activities. Some of our services may require you to provide specific personal sensitive information to enable certain functions. If you choose not to provide this information, you may not be able to use certain features of the service, but it will not affect your use of other features. If you actively provide your personal sensitive information, it indicates that you agree to allow us to process your personal sensitive information in the manner and for the purposes described in this Policy.
1.2 Information We Collect When You Use the Service
1.2.1 Log Information
(1) Device Information: For example, device model, operating system version, unique device identifier, battery, signal strength, and other information.
(2) Software Information: For example, software version number, browser type. To ensure the security of the operating environment or to provide services, we will collect information about the mobile apps and other software you use.
(3) IP Address.
(4) Service Log Information: For example, the information you searched for, viewed, service failure information, referral URLs, etc., while using our services.
(5) Communication Log Information: For example, the accounts you communicated with, communication time, and duration during your use of our services.
2.1 Providing Services to You
2.2 Meeting Your Personalized Needs. For example, language settings, personalized help services.
2.3 Product Development and Service Optimization. For example, when our system encounters a failure, we will record and analyze the information generated during the failure to optimize our services.
2.4 Security Assurance. For example, we will use your information for identity verification, security prevention, anti-fraud monitoring, archiving backups, and customer security services. For instance, the security software you download or install may detect malicious programs or viruses, or identify fraudulent information for you.
2.5 Personalized advertising and content recommendations based on your usage patterns.
2.6 Evaluating and Improving the Effectiveness of Our Advertising and Other Promotional Activities.
2.7 Software Management. For example, software certification, software upgrades, etc.
2.8 Requesting voluntary participation in user experience research to improve service quality.
You can share your relevant information with friends, family, and other users through our services. For example, text and photos you publicly share in the S-Mandarin Chinese learning software. Please note that this may include your personal identity information, personal financial information, and other sensitive information. Please carefully consider disclosing your personal sensitive information.
You can control the scope of the information you share through the privacy settings in our services. You can also delete the information you publicly share through the service settings or guidelines we provide. However, please note that this information may still be independently retained by other users or third parties not under our control.
5.1 You can access, modify, and delete the registration information and other personal information you provide while using our services. You can also contact us according to the notification guidelines. The scope and method of accessing, modifying, and deleting personal information will depend on the specific services you use.
5.2 We will collect and use your information only to achieve the functionality of our products or services as described in this Policy. If you find that we have violated the law, administrative regulations, or our agreement by collecting or using your personal information, you can request us to delete it. If you find that the personal information we collect or store is incorrect, you can request us to correct it. To exercise your rights under applicable data protection laws (e.g., access, correction, deletion), contact our Data Protection Officer at server@smandarin.com.
5.3 When you access, modify, or delete related information, we may require you to verify your identity to protect the security of your account.
5.4 Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all your requests, but we will respond to your request within a reasonable period.
We strictly limit the sharing of information in accordance with the provisions of laws and regulations, such as:
6.1 With your explicit prior consent, we may share your personal information with third parties.;
6.2 To fulfill specific service purposes, we engage authorized third-party partners (e.g., cloud service providers, analytics vendors, or advertising platforms) who may process your data under strict contractual obligations. These partners: Operate under our instructions and this Policy; Are prohibited from using data for unauthorized purposes; Implement technical safeguards (e.g., encryption, pseudonymization).
6.2.1 To Provide Our Services to You;
6.2.2 To Achieve the Purposes Described in the "How We Use the Collected Information" Section;
6.2.3 To Fulfill Our Obligations and Exercise Our Rights Under This Policy;
6.2.4 To Understand, Maintain, and Improve Our Services.
6.3 As our business continues to develop, if a merger, acquisition, asset transfer, or similar transaction occurs, resulting in the sharing of your personal information with a third party, we will inform you of the relevant circumstances through push notifications, announcements, etc. We will continue to protect your personal information according to legal requirements and standards no less than those required by this policy, or require the new manager to continue protecting your personal information.
6.4 We May Use the Information Collected for Big Data Analysis. For example, we may use the information collected to create city heatmaps or industry insight reports that do not contain any personal information. We may disclose and share this statistical, non-identifiable information with our partners to understand how users interact with our services or to inform the public about the overall usage trends of our services.
6.5 We May Disclose Your Personal Information for the Following Purposes:
6.5.1 To Comply with Applicable Laws, Regulations, and Other Legal Requirements;
6.5.2 To Comply with Court Judgments, Rulings, or Other Legal Procedures;
6.5.3 To Comply with Requests from Relevant Government Authorities or Other Statutory Organizations;
6.5.4 If We Have Reason to Believe Compliance with Legal Requirements Is Necessary;
6.5.5 To Enforce Service Agreements or This Policy, Safeguard Public Interests, or Protect the Personal Safety, Property Security, or Other Legal Rights of Our Clients, Us, Our Affiliates, Other Users, or Employees, as Reasonably and Necessarily Required.
7.1 Promotional Messages
You may receive transactional or promotional communications. To opt out:
Email: Unsubscribe via links in messages;
App: Adjust notification settings under Profile > Preferences.
7.2 Service-Related Announcements
We may send you service-related announcements when necessary (e.g., when a service is temporarily suspended due to system maintenance). You may not be able to cancel these announcements, which are not considered advertisements.
7.3 Third-Party Services
To provide you with more complete and high-quality products and services, we may integrate SDKs or other similar applications provided by third-party service providers. You can refer to the following details to understand the main third-party SDKs we use.
8.1 We Strictly Comply with Laws and Regulations to Protect Users' Communication Privacy.
8.2 We Use Various Security Protection Measures at Reasonable Security Levels to Safeguard the Security of Information. For example, we use encryption technologies (e.g., TLS, SSL), anonymization, and other methods to protect your personal information.
8.3 We Establish Dedicated Management Systems, Processes, and Organizations to Ensure Information Security. For example, we strictly limit access to information and require those with access to adhere to confidentiality obligations and undergo reviews.
8.4 In the Event of a Security Incident Such as Personal Information Leakage, We Will Activate Emergency Plans to Prevent the Incident from Expanding and Notify You via Push Notifications, Announcements, etc.
8.5 If Our Products or Services Are Discontinued, We Will Notify You through Push Notifications, Announcements, etc., and Delete or Anonymize Your Personal Information within a Reasonable Period.
We attach great importance to the protection of minors' personal information. According to relevant laws and regulations, if you are a minor under the age of 18, you should obtain consent from your parent or legal guardian before using the service. If you are the guardian of a minor and have questions about the minor's personal information, please contact us.
All of our services are subject to this Policy. However, some services have their own specific privacy guidelines/statements that more specifically describe how we handle your information in those services. If there is any inconsistency between this Policy and the specific privacy guidelines/statements for certain services, the specific privacy guidelines/statements shall prevail.
For data access, correction, or deletion requests:
- Email: privacy@smandarin.com
- Postal Address: [Insert Company Address] We respond to inquiries within 15 business days.
We may revise the contents of this Policy from time to time. If such changes will substantially reduce your rights under this Policy, we will notify you before the changes take effect through prominent notices on the page or via email. In such cases, if you continue to use our services, you will be deemed to agree to be bound by the revised Policy.
Operator: Yunnan Junruo International Technology Co., Ltd.
Last Revised: December 2, 2024
The final interpretation of this Policy belongs to Yunnan Junruo International Technology Co., Ltd.