Privacy Policy

(Updated and Effective Date: November 3, 2026)

Fujian Qkids Primary and Secondary School Online Training Center (hereinafter referred to as "Qkids" or "we") provides you with related products and services through websites, our proprietary Qkids series software, as well as WeChat official accounts and mini-programs operated and managed by us.

When you browse, download, open, register, log in, and use Qkids-related products and services, we will collect and use your relevant information in accordance with relevant Chinese laws and regulations. Through this "Privacy Policy" (hereinafter referred to as "this Policy"), we aim to explain how we collect, use, store, share, and transfer this information when you accept our products and services, as well as the ways we provide you with access, update, control, and protect this information.

We deeply understand the importance of personal information to you and will do our utmost to protect the security of your personal information. We are committed to maintaining your trust in us and adhering to the following principles to protect your personal information: principle of responsibility consistency, principle of clear purpose, principle of consent and choice, principle of minimum necessity, principle of ensuring security, principle of subject participation, and principle of openness and transparency. We promise to take corresponding security protection measures in accordance with mature industry security standards to protect your personal information.

Please carefully read and understand this Policy before using our products and services, especially pay close attention to and understand the content marked in bold. Please start using our products and services only after confirming that you fully understand and agree. Your use of our products and services means that you agree to our collection, use, storage, sharing, disclosure, and protection of your personal information in accordance with this Policy. If you do not agree with any content of this Policy, we will not be able to provide products and services to you normally, and you should immediately stop using our products and services.

We attach great importance to the protection of minors' personal information. If you are a minor, we require you to ask your parents or legal guardians to carefully read this Privacy Policy together with you, especially the section "How we handle minors' and children's information," and use our services or provide information to us only after obtaining the consent of your parents or legal guardians. Without the consent of parents or legal guardians, we will prohibit minors from creating their own personal information subject accounts.

We will update this Policy from time to time and publish the latest version to you through channels such as the Qkids official website. If you have any questions about this Policy, you may contact us through the following means.

Office Address: No. 16-3, Wanghai Road, Software Park Phase II, Siming District, Xiamen City

Customer Service/Complaint Email: service@qkids.cn

Customer Service/Complaint Phone: 400-8558-297/295 (Beijing Time 9:30-21:30)

This Policy will help you understand the following:

1. Scope of this Policy and definitions of related terms

2. Purposes, methods, and scope of our collection and use of personal information

3. How we use Cookies and similar technologies

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

5. How we send commercial information to you

6. How we protect your personal information

7. Your rights

8. How we handle minors' and children's information

9. How your personal information is transferred globally

10. How this Policy is updated

11. How to contact us

I. Scope of this Policy and definitions of related terms

(I) Scope

This Policy applies to the “Qkids/QKIDS” learning platform and all of its current products and services, including the official website of the “Qkids English” learning platform (domain: qkids.com) and Qkids Class (Windows, Mac, iOS, and Android versions). Nevertheless, some of our products and services (for example, those intended for different customer groups) have specific privacy policies that explain in greater detail how we process personal information in those products and services. If this Policy is inconsistent with the privacy policy for a specific product or service, that specific privacy policy shall prevail.

This Policy only applies to information that we collect, store, use, share, and disclose. This Policy does not apply to (1) information collected by third-party services (including any third-party websites) accessed through our products and services; (2) information collected by other companies or institutions providing advertising services in our products and services. If you browse any third-party website other than ours or use third-party products and services and provide your personal information to that third party, your personal information shall be subject to that third party's privacy statement or similar policy. Whether you log in or browse the above websites or software, or use their products and services based on links or guidance from the Qkids platform, we assume no legal liability for any improper use or disclosure of information provided by you by any third party.

(II) Definitions of related terms

1. Personal Information

In this Policy, personal information refers to various types of information recorded electronically or by other means that can, alone or in combination with other information, identify a specific natural person or reflect the activities of a specific natural person.

Personal information covered by this Policy includes: basic information (including personal name, personal telephone number, and shipping address); network identity information (including App login account, IP address, and associated password); personal education and employment information (educational background and training records); personal financial information (transaction and spending records, and records of fund flows generated through third-party services); personal internet activity records (including software usage records, click records, and favorites records); commonly used device information (including hardware model, device MAC address, operating system type, software list, and unique device identifiers, including IMEI/android ID/IDFA/OPENUDID/GUID and SIM card IMSI information describing the basic characteristics of commonly used personal devices); and device sensor information (including device acceleration and magnetic field sensors).

2. Personal Sensitive Information

In this Policy, personal sensitive information refers to personal information that, once leaked, illegally provided, or abused, may endanger personal and property safety and is very likely to cause personal reputation, physical and mental health damage or discriminatory treatment.

Personal sensitive information involved in this Policy includes: personal financial information (transaction and consumption records, fund flow records generated by using third-party services).

II. Purposes, Methods, and Scope of Collection and Use

(I) We will collect your personal information for the following purposes and methods in this Policy:

1. Collection and use rules for implementing basic business

During the process of registering for and obtaining a Qkids account, you need to provide us with an effective mobile phone number in order to receive a registration verification code and complete registration. If you do not provide the above information, you will not be able to register and use our products and services, but you can continue to browse and learn about our products and services.

When you register or log in to your Qkids account, we will request your authorization to access the mobile phone number information used by your mobile terminal. The purpose is to associate that mobile terminal with your Qkids account, enabling one-click login to your Qkids account using your mobile phone number, and allowing us to record how frequently you open/use Qkids and your activation rate. If you do not provide the above information, you will not be able to use the one-click login function and will need to enter your mobile phone number information each time you log in.

When you use Qkids products and services, we will request your authorization to obtain network access permissions. The purpose is to allow your device to permit Qkids products and services to access the network and use network traffic, ensuring normal operation of Qkids products and services. If you do not grant the above permissions, Qkids products and services will not be able to operate normally.

After registering a Qkids account, you may choose whether to complete your personal information, and you can upload and edit your personal avatar, name, gender, age, English nickname, WeChat ID, WeChat avatar, education history. We will request your authorization to read your mobile device network status, device information (including IMEI/IMSI, SIM card serial number/MAC address, Android ID), software installation list, access and open your device camera, and read/modify device (photo album/gallery) storage functions. The purpose is to facilitate your completion of your personal information. If you do not provide the above information, you can continue to use Qkids products and services.

When you pay to purchase Qkids products and services, you may choose to use payment services provided by third-party payment institutions that cooperate with us (including WeChat Pay and Alipay payment channels). We will not request, collect, or store your payment process information in any way, but we need to share your commonly used device information, order information and fund flow information with third-party payment institutions for the purpose of verifying and confirming whether specific payments are completed successfully. When making a payment, you may be redirected to the third-party payment provider's interface for payment operations based on the payment service provider's prompts. In such operations, the payment service provider will directly collect and process user payment process information, and the payment process and information processing will comply with the third-party payment service provider's privacy policy. If you do not provide the above information, we will not be able to confirm and verify whether you have completed the payment to purchase Qkids products and services.

When you use mailing product services, we will request you to provide recipient name, phone number, shipping address for the purpose of safely and accurately delivering the corresponding order products to you. If you do not provide the above information, we will not be able to complete the mailing product service.

When you schedule courses, we will request your authorization to edit and read the system calendar of your mobile terminal. The purpose is to record your scheduled course time in the system calendar to remind you to attend class at the scheduled time. If you do not grant the above permissions, we will not be able to complete the scheduled course reminder service.

When you use Qkids live streaming product services, we will request your authorization to access and open your device camera and microphone. The purpose is to allow live streaming course teachers to observe your class status from both visual and auditory dimensions to achieve interactive teaching with you. If you do not grant the above permissions, you will not be able to normally use Qkids live streaming product services.

When you use the Qkids course practice function, we will request your authorization to access and open your device camera, and use your device write/read storage functions. The purpose is to access, upload, and compare your corresponding practice results stored as photos or videos on your mobile device to receive teacher grading and evaluation. If you do not grant the above permissions, you will not be able to normally use the Qkids course practice function.

When you use the course voice practice function, we will request your authorization to access and open your device microphone. The purpose is to collect your voice through the microphone and identify whether your reading pronunciation is accurate so that the voice practice system can provide timely feedback. If you do not grant the above permissions, you will not be able to normally use the course voice practice function.

When you encounter questions or need our help during the use of Qkids products and services, we will request your authorization to obtain your device model information. The purpose is to enable us to more quickly identify problems with specific devices by matching device models and provide solutions in a timely manner.

When you contact our customer service staff and send voice, image, or video materials, we will request your authorization to access and open your device microphone, access and open your device camera, and read/modify device (photo album/gallery) storage functions. The purpose is to collect your voice through the microphone and access photo or video materials to facilitate feedback from our customer service. If you do not grant the above permissions, you will not be able to normally send voice, image, or video materials to us.

2. Collection and use rules for meeting expanded business

When you redeem learning tools and Qkids merchandise in the Coin Shop, we will request you to provide recipient name, phone number, shipping address for the purpose of safely and accurately delivering the corresponding redemption products to you. If you do not provide the above information, we will not be able to complete the mailing product service.

When we invite you to participate in offline meetup marketing events, we may request you to provide contact name, contact information based on event needs. The purpose is to enable us to contact you and arrange marketing event-related matters. If you do not provide the above information, it will not affect your use of our products and services.

When you contact us, we may save your communication or call records and content or the phone number you left to help you solve problems and record the handling solutions and results for related problems. Our customer service staff will use your account information (the mobile phone number you used when registering, as well as the personal avatar, name, gender, age, English nickname, WeChat ID, WeChat avatar, education history you uploaded yourself) to verify your identity with you. You may provide other information beyond the above information when communicating with our customer service staff. If you do not provide the above information, it will not affect your use of our products and services.

(II) How we use your personal information

We will use the collected personal information in the following ways in compliance with this Privacy Policy:

1. To achieve the normal functions of our products and services;

2. To ensure the stability and security of our products and services, we will use your personal information for account registration, identity verification, security measures, fraud monitoring, prevention or prohibition of illegal activities, risk reduction, archiving and backup purposes;

3. Report to relevant departments according to laws, regulations or regulatory requirements;

4、After collecting your personal information, we will process the above information using technical measures such as anonymization and de-identification to form non-personally identifiable information (i.e., after processing, the relevant information will not be able to identify or be associated with a specific subject and cannot be restored). Please understand and agree that in the above circumstances, we may conduct comprehensive statistics, analysis and processing of such information (which does not contain any of your identity information) for the purpose of improving and enhancing our products and services:

a) By statistics on the usage of our products and services, we will share these statistical information with the public or third parties to display the overall usage trends of our products and services;

b) By analyzing the above information, we can more quickly and accurately screen and recommend products and services from the Qkids product matrix that are more suitable for you, and through AI algorithms, optimize the product service content and methods presented to you in real time, providing you with personalized products and services more targeted to meet your needs at different stages and levels;

c) At the same time, the above information will also help us evaluate and improve services and operational activities, and identify traffic and consumption trends across sales channels, so that we can, independently or together with third-party partners, plan and carry out more attractive promotional and marketing activities.

Please note that all personal information you provide when using our products and services will continue to authorize us to use it during the period when you use our products and services, unless you delete it or refuse our collection through device system settings. After you cancel your Qkids account, we will, in accordance with legal and regulatory provisions, delete your personal information or subject it to irreversible anonymization and desensitization in a timely manner.

When we intend to use information collected for a specific purpose for other purposes, or use information for other uses not specified in this Policy, we will, in accordance with the requirements of laws, regulations and national standards, seek your consent in advance and individually again through separate confirmation agreements or text confirmation actions in specific scenarios.

(III) Exceptions to obtaining authorization and consent for collection and use of personal information

In accordance with relevant laws and regulations, we may lawfully process your personal information without obtaining your authorization and consent in the following circumstances:

1. Where necessary to perform statutory duties or obligations;

2. Where necessary to respond to public health emergencies, or to protect the life, health, or property of natural persons in an emergency;

3. Where personal information is processed within a reasonable scope for news reporting, public opinion supervision, or similar activities in the public interest;

4. Where personal information that you have disclosed yourself or that has otherwise been lawfully made public is processed within a reasonable scope in accordance with laws and regulations;

5. Other circumstances prescribed by laws and administrative regulations.

Except for the statutory circumstances described above, before collecting or using your personal information, we will inform you of the purposes, methods, and scope of collection and obtain your consent. In circumstances involving statutory exceptions, we will also explain the processing rules in this Privacy Policy.

(IV) Collection and use rules related to marketing products

1. Your network identity information helps you maintain normal software use and use security.

2. We will ask you through pop-ups whether you authorize corresponding permissions. Only after you choose to agree will we enable corresponding permissions for you and receive relevant personal information.

3. You can enable device microphone permissions for voice input (such as voice messages, voice search). During this process, we use your voice content and perform necessary processing to meet your software use needs.

4. We will, in the background, receive and record your commonly used device information and device identifiers (including MAC address, IMEI, IDFA, Android ID, OAID, OPENUDID, GUID, IMSI, DeviceID, SIM card serial number, SIM card ICCID, BSSID, SSID), software installation list, and device location-related information based on the specific permissions you grant during software installation and use: IP address, GPS location, and Wi-Fi access points, Bluetooth and other sensor information that can provide relevant information, to facilitate security assurance and related function use.

5. After collecting your personal information, we will promptly anonymize the data through technical means. We will store anonymized data separately from information that can be used to re-identify individuals and ensure that individuals are not re-identified in subsequent personal information processing. Without leaking your personal information, we have the right to mine, analyze and utilize anonymized user databases (including commercial use).

6. If we use your personal information for purposes or scopes other than those listed in this Policy, or adopt transmission methods inconsistent with data collection, we will notify you and obtain your consent.

III. How we use Cookies and similar technologies

Based on the inherent attributes of the internet and mobile internet, when you use our products and services, we may collect your non-personally identifiable information through channels such as Cookies, including: browser log information, used device or software version information, usage duration, ISP access region, for the purpose of helping you reduce the frequency of information entry or assisting in judging the security status of your account.

(I) Cookies

To ensure the normal operation of the Qkids platform, we will store small data files named Cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of Cookies, websites can store your browsing preferences or information about products and services you have visited.

We will not use Cookies for any purpose other than those described in this Policy. You can manage or delete Cookies according to your preferences. For details, please visit AboutCookies.org. You can clear all Cookies saved on your computer, and most web browsers have the function to block Cookies. However, if you do this, you will need to change user settings yourself every time you visit our website. For detailed information on how to change browser settings, please visit the corresponding instructions or help page of the browser provider you are using.

(II) Web beacons and pixel tags

In addition to Cookies, we also use other similar technologies on websites such as web beacons and pixel tags (referred to as Web Beacons) to statistics access information including number of visits, duration of stay, visited page addresses, etc., helping us understand your product or service preferences and improve customer service, but these statistical information does not contain your personal information.

If you do not wish to be tracked in this way, you can perform "clear cache" or similar operations to cancel. However, if you choose to clear, you may need to change user settings yourself every time you access our products and services, which may have a certain impact on the security and convenience of the products and services you use, but will not affect your normal use of the products and services we provide.

(III) Do Not Track

Many web browsers have Do Not Track functionality, which can issue Do Not Track requests to websites. Currently, major internet standards organizations have not yet established relevant policies to regulate how websites should respond to such requests. However, if your browser has Do Not Track enabled, our website will respect your choice.

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

(I) How we share your personal information

We will not share your personal information with any company, organization or individual other than Qkids, unless we obtain your explicit consent. We will only share your personal information for legitimate, proper, necessary, specific, and clear purposes, and will only share personal information necessary to provide services. Our partners have no right to use shared personal information for any other purposes. For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures. For the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technology to better protect your personal information. If you have objections to third parties using your personal information or discover risks in applications developed by these third parties, we recommend that you terminate relevant operations to protect your legitimate rights and interests, and you can also negotiate solutions with the corresponding third parties, and we will provide assistance as much as possible. If we violate the provisions of laws and regulations in this process and cause losses to you, we will bear the corresponding responsibility arising therefrom.

Currently, we will seek your authorization and consent for sharing personal information in the following circumstances:

1. To provide you with more professional and secure basic business functions and additional business functions, for technical needs, Qkids website, self-developed QKIDS series software, WeChat official accounts and mini-programs operated and managed by Qkids (collectively referred to as "Qkids Platform") will embed third-party software development kits (SDKs). Currently, third-party SDKs embedded in the Qkids Platform and information collected by or shared with third parties are as follows:

1.1 Our products integrate the Sentry SDK to improve service stability, enable rapid collection of crash logs and reporting of exceptions after a relevant service crashes, and accurately locate problems. The information that needs to be collected includes your user ID, application version, and JS version.

1.2 Our products integrate Tencent's Bugly SDK to collect relevant crash logs, exceptions, and related log information (including: third-party developer custom logs, Logcat logs and APP crash stack information), device ID (including: androidid and idfa), IMSI, MAC address, network information, system name, system version and country code.

1.3 Our products integrate Alibaba Cloud Log Service, but do not integrate the Alibaba Cloud Log SDK. This service is mainly used to collect and analyze classroom data to understand users’ classroom learning and mastery of knowledge. It needs to collect device information, operation logs, and information about running processes. Classroom logs are packaged locally and uploaded via HTTP to OSS, and then transferred from OSS to Alibaba Cloud Log Service.

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2. In the background state, unique device identifiers (IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) will be obtained for App push and statistical analysis.

3. Based on the purpose of unified management and the principle of reasonableness and necessity, we will share your data information on using Qkids products and services with our affiliated companies to help us design new business models, evaluate and improve our services, and enhance user experience, etc. We will only share necessary personal information and will be bound by this Policy. If affiliated companies intend to change the processing purpose of personal information, they will again seek your authorization and consent in advance.

4. We may entrust third-party partners to process personal information on our behalf to authorize partners to provide you with certain services or perform functions on our behalf. However, we will only entrust them to process your personal information for legitimate, proper, necessary, and clear purposes, and authorized partners can only access personal information necessary to provide services or perform functions. We will require them through agreements not to use this information for any other purposes beyond the scope of entrustment. Unless you otherwise authorize and consent, our partners have no right to use your personal information for any other purposes we have not entrusted. Our entrusted partners include the following types:

(1) Suppliers, service providers and other partners. We may provide your personal information to third-party service providers and partners that support our service provision. These service providers and partners include institutions that provide infrastructure technical services, data processing, verification, loss assessment, credit review, risk control, quality inspection, short message services, voice call services, customer service, payment settlement services and express delivery services necessary to complete transactions, or conduct academic research and surveys, etc. However, we require these service providers and partners to use your information only for the purpose of providing services to us and not to use your information for their own interests. In this case, such third-party partners can only contact you through virtual numbers provided by us. In non-necessary circumstances, we will not provide your identity information or other information that can identify your personal identity to these partners to ensure your personal information security. We will strive to take reasonable measures such as "number protection" and "policy information de-identification" to do our utmost to protect your personal information security.

(2) Authorized advertising and analytics partners. With your authorization, we will share information with service providers offering advertising placement and promotion, statistical analysis service providers (such as application traffic monitoring providers), or other partners. However, we will only provide these partners with aggregated information, anonymized information, or other information that does not identify you personally. We will not share any of your identity information, account information, or other identifiable information.

5. We may share your personal information in accordance with laws and regulations or mandatory requirements of government authorities.

(II) Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

1. After obtaining your explicit consent, we will transfer your personal information to other parties;

2. Provide when required by applicable laws and regulations, requirements of legal procedures, or mandatory administrative or judicial requirements;

3. When involved in mergers, acquisitions, asset transfers or similar transactions, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require that company or organization to seek your authorization and consent again.

(III) Public Disclosure

According to relevant laws and regulations and national standards, we will only publicly disclose your personal information in the following circumstances:

1. With your explicit consent;

2. Required by law, legal proceedings, litigation or mandatory requirements of government regulatory authorities;

3. Complying with requirements of relevant government agencies involving direct relevance to national security, national defense security, public safety, public health, major public interests, criminal investigation, prosecution, trial and execution of judgments, etc.;

4. To comply with applicable laws and regulations, maintain social public interests, or protect major legitimate rights and interests such as life and property of you or other individuals but it is very difficult to obtain the consent of the person concerned.

V. How we send commercial information to you

We will provide you with commercial information such as services, functions or activities that may interest you through SMS and phone. However, please rest assured that if you do not wish to receive these messages, you can unsubscribe through the unsubscribe method provided in mobile SMS or contact us directly to unsubscribe.

VI. How we protect your personal information

(I) Lawful collection and use

We will take all reasonable and feasible measures to protect your personal information. Currently, the “Qkids English Learning Platform” has obtained Level 3 certification under the information system classified security protection scheme of the People’s Republic of China.

In accordance with relevant laws and regulations, we will store your personal information within the territory of the People's Republic of China through domestic third-party cloud service providers and use security protection measures that meet industry standards to prevent data from being accessed, disclosed, used, modified, damaged or lost without authorization.

We will only retain your personal information for the period necessary to achieve the purposes described in this Policy and/or provide corresponding products and services. For example, according to the "E-Commerce Law of the People's Republic of China", commodity and service information and transaction information must be retained for no less than three years from the completion of the transaction; the "Implementation Opinions of the Ministry of Education and Other Six Departments on Regulating Off-campus Online Training" stipulates that user behavior logs must be retained for more than one year, etc., unless you require extending the retention period or are allowed by laws and regulations. For the above information, especially relevant personal information involving your behavior logs, we will conduct anonymization and de-identification processing.

After your personal information exceeds the retention period, we will delete your personal information or subject it to anonymization in accordance with the requirements of applicable laws (if you are a minor, after your personal information exceeds the retention period, we will process your personal information in accordance with relevant laws and regulations). If we are unable to delete according to relevant requirements due to special circumstances, we will explain this part of the matter to you.

If we stop operating the Qkids platform, we will promptly stop activities to collect your personal information, notify you of the cessation of operations by means of individual delivery or public announcement, and delete or anonymize the personal information we hold.

(II) Setting complex passwords

Your account and password are important bases for Qkids to identify your identity, log in and use our products and services. Once leaked, it may produce adverse consequences for you. We strongly recommend that you set complex passwords, change passwords regularly, and keep passwords properly to assist us in ensuring your account and personal information security. If you discover that your account and password have been or may be leaked, please contact us immediately, and we will do our utmost to take corresponding measures to avoid or reduce related losses.

(III) Strict security measures

1. Management systems

We have formulated and implemented management systems including internal network information security management systems, data storage media management systems, information use and authorization management systems, emergency response management systems, etc., forming a relatively complete personal information security management system.

2. Mechanism guarantee

We have established an information security organization management mechanism and designated dedicated personnel responsible for personal information security management. Based on classification and grading results, we conduct permission restrictions in multiple aspects such as user permissions, usage scenario permissions, usage authorization permissions, and hierarchical approval mechanisms to prevent data from being accessed, disclosed, used, modified, damaged or lost without authorization.

3. Technical guarantee

We adopt irreversible encrypted storage and isolated storage during storage, adopt desensitization processing during information display and download, and adopt technical measures such as dedicated line transmission, encrypted transmission, and key and data medium isolated transmission during transmission to ensure your personal information security.

4. Regular inspections

We conduct internal security risk assessments and personal information security impact inspections and training on an irregular basis, conduct emergency response drills, master job responsibilities and emergency response procedures, and continuously improve our ability to protect personal information security.

(IV) Emergency remedial measures

Although we have taken the above reasonable measures and complied with the standards required by relevant legal provisions, please understand that due to technical limitations and possible various malicious means, in the internet industry, even if we do our best to strengthen security measures, we cannot always guarantee that your personal information is 100% secure. We will do our best to ensure the security of the personal information you provide to us. After the unfortunate occurrence of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, disposal measures we have taken or will take, suggestions for your independent prevention and risk reduction, remedial measures for you, etc. We will promptly inform you of the relevant circumstances of the incident through App push notifications, sending SMS/email, phone calls, etc. When it is difficult to inform personal information subjects one by one, we will issue announcements through reasonable and effective methods. At the same time, we will also actively report the handling of personal information security incidents in accordance with regulatory authority requirements. If our physical, technical, or management protection facilities are damaged, leading to information being accessed without authorization, publicly disclosed, tampered with, or destroyed, causing damage to your legitimate rights and interests, we will bear the corresponding legal liability.

(V) Principles for processing existing personal information

1. Your personal information will be stored for the shortest time necessary to achieve the necessary purposes of business functions. After exceeding such retention period, personal information will be deleted or subjected to anonymization. Personal information collected and generated during our operations within the territory of the People's Republic of China will, in principle, be stored within China and will not be transferred cross-border outside China. The following circumstances are exceptions:

(1) There are clear provisions in laws and regulations; (2) Your explicit authorization is obtained. For the above circumstances, we will also ensure that we provide security protection for your personal information in accordance with laws and regulations and this Policy.

2. We have used security protection measures that meet industry standards to protect the personal information you provide from being accessed, disclosed, used, modified, damaged or lost without authorization. We will take all reasonable and feasible measures to protect your personal information, including: using encryption technology to ensure data confidentiality; using trusted protection mechanisms to prevent data from being maliciously attacked; deploying access control mechanisms to ensure that only authorized personnel can access personal information; and holding security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.

3. When you send or receive information from your device or browser to our servers, we use Secure Sockets Layer (SSL) protocol and other algorithms to encrypt it.

4. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for three years necessary to achieve the purposes described in this Policy, unless it is necessary to extend the retention period or permitted by law. After the expiration, we will delete or de-identify your personal information.

5. All your personal information is stored on secure servers and protected in controlled facilities. We classify your data based on importance and sensitivity and ensure it has the highest security level. We guarantee that employees and third-party service providers who access this information to help provide products and services to you have strict contractual confidentiality obligations, and if they fail to fulfill these obligations, they will be subject to disciplinary action or termination of cooperation. We regularly review information collection, storage and processing practices, including physical security measures, to prevent any unauthorized access and use.

Although we have taken the above reasonable and effective measures and complied with the standards required by relevant legal provisions, please understand that due to technical limitations and possible various malicious means, in the internet industry, even if we do our best to strengthen security measures, we cannot always guarantee that information is 100% secure. You are aware and understand that the systems and communication networks you use to access our services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of personal information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account passwords and other personal information to others. If a personal information leakage event occurs, we will promptly notify relevant regulatory agencies in accordance with the law and notify you personally where required by applicable laws.

VII. Your rights

In accordance with relevant Chinese laws, regulations, and standards, as well as prevailing practices in other countries and regions, you have the right to exercise the following rights regarding your personal information:

(I) Access

You have the right to access your personal information, except in circumstances prescribed by laws and regulations. If you need to access your personal information, you can log in to your account and view, search for, or edit your personal information in "Mine → Settings". If you are unable to access this personal information through the above methods, you can contact us at any time through customer service phone.

For other personal information generated during your use of our products and services that you need to query or access, you can also contact us through customer service phone, and we will provide it to you.

(II) Correction

When you discover that there are errors in our processing of your personal information, you have the right to require us to make corrections. You can also operate by yourself through the methods described in "(I) Access".

(III) Deletion

In addition to deleting your personal information through the methods described in "(I) Access", you can also submit a request to us to delete your personal information in the following circumstances:

1. If our processing of personal information violates laws and regulations;

2. If we collect or use your personal information without obtaining your consent;

3. If our processing of personal information violates our agreement with you;

4. If you no longer use our products or services, or you have cancelled your account;

5. If we no longer provide products or services to you.

If we decide to respond to your deletion request, we will also promptly notify entities that have obtained your personal information from us to require them to delete it in a timely manner, unless laws and regulations provide otherwise or these entities obtain your independent authorization.

After you delete information from our services, we may not immediately delete the corresponding information from backup systems, but will delete this information when backups are updated.

(IV) Changing authorization

Each business function involved in Qkids' different products and services requires some basic personal information to be completed. For our collection and use of your personal information, you may grant or withdraw your authorization and consent at any time. After you withdraw consent or authorization, we will no longer process the corresponding personal information and will not be able to continue to provide you with products and services corresponding to the withdrawn consent or authorization. However, your decision to withdraw consent or authorization will not affect personal information processing previously conducted based on your authorization.

For authorization content information you give us on your device, you can view and withdraw it in "Settings - Privacy - Permission Management" on your device. Please note that the path may vary in different devices. Please refer to the instructions and guides of your device and system developer for details.

(V) Account cancellation

When you meet the agreed cancellation conditions, you can cancel your personal account at any time through "Mine → Settings → Account & Security → Cancel Account, click Apply for Cancellation at the bottom". The Qkids system will conduct risk identification based on the current environment, confirm the cancellation operation through SMS verification code, freeze the account after confirmation, and automatically cancel it if there is no login operation within 30 days. If cancellation cannot be completed successfully for special reasons, you can also submit a cancellation application to manual customer service by calling the customer service phone.

After canceling your account, we will stop providing products or services to you and delete your personal information in accordance with your request, unless laws and regulations provide otherwise.

(VI) Obtaining 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 your personal information that we have collected, you can call the customer service phone. Manual customer service will verify your personal information, and after completing personal information subject confirmation, submit an application to the Qkids system to obtain a copy of your personal information. Under the premise of complying with relevant legal provisions and being technically feasible, we will provide you with a copy of your personal information in accordance with your request.

(VII) Constraining information system automated decision-making

In certain business functions, we may make decisions based solely on non-human automated decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to require us to provide explanations, and we will also provide appropriate relief methods.

(VIII) Responding to rights requests

Any questions, suggestions, opinions and complaints from you can be submitted by calling customer service phone to contact our customer service. To ensure security, you may need to provide a written request or prove user identity in other ways. Our customer service may first require users to provide corresponding identity proof materials to verify that you are the relevant account owner, and then process your request after verification. In general, we will respond and process within fifteen (15) working days.

For reasonable rights requests from you, we will not charge fees in principle, but we may charge certain costs for requests that are repeated multiple times or exceed reasonable limits. We may refuse requests that are unreasonably repeated, require excessive technical means (require developing new systems or fundamentally changing current practices), pose risks to legitimate rights and interests of other users, or are very impractical.

In the following circumstances, in accordance with legal and regulatory requirements, we will not be able to respond to your requests:

1. Directly related to national security and national defense security;

2. Directly related to public safety, public health, and major public interests;

3. Directly related to criminal investigation, prosecution, trial and execution of judgments, etc.;

4. There is sufficient evidence that you have subjective malice or abuse of rights;

5. Responding to your request will cause serious damage to legitimate rights and interests of you or other individuals or organizations.

6. Involving trade secrets.

VIII. How we handle minors' and children's information

Our products and services are primarily intended for minors, especially children. We attach great importance to protecting minors’ personal information and strictly comply with national laws and regulations concerning the protection of minors’ personal information.

(I) Guardian Consent

1. If you are a minor under the age of 14, please read this Privacy Policy in the company and under the guidance of your parents or other legal guardians, and obtain your guardian’s consent before using our products and services.

2. For the personal information of children under the age of 14, we will establish dedicated personal information processing rules in accordance with laws and regulations and obtain the consent of the children’s parents or other legal guardians.

3. If you are a minor aged 14 or older but under 18, please read this Privacy Policy under the guidance of your guardian and use our products and services in accordance with laws and regulations.

(II) Collection and Use of Minors’ Personal Information

We will collect and use minors’ personal information only to the extent necessary to provide our products and services, including:

1. Information necessary for account registration and identity verification;

2. Information necessary to provide courses, classroom interactions, and learning services;

3. Information necessary to record learning progress, practice results, and learning assessments;

4. Information necessary to safeguard account security, ensure normal product operation, and handle user service requests.

For children’s personal information, we will adopt stricter protective measures and strictly limit access permissions and the scope of use.

(III) Protection of Minors’ Personal Information

We will not use minors’ personal information for purposes unrelated to the provision of our products and services.

We will not provide minors’ personal information to unrelated third parties without lawful authorization from their guardians or permission under laws and regulations.

For children’s personal information, we will adopt security measures such as encryption, access controls, and permission management in accordance with the law to prevent unauthorized access, disclosure, alteration, or loss.

(IV) Guardians’ Rights

After we have verified a guardian’s identity, the guardian may contact us using the contact details provided in this Policy to request that we:

1. Allow inquiries about and access to the minor’s personal information;

2. Correct or supplement the minor’s personal information;

3. Delete the minor’s personal information;

4. Withdraw authorization and consent for processing the minor’s personal information;

5. Cancel the minor’s account;

6. Facilitate the exercise of other rights of personal information subjects prescribed by laws and regulations.

We will handle guardians’ requests within the time limits prescribed by laws and regulations.

(V) Handling Children’s Personal Information Collected Without Guardian Consent

If we discover that children’s personal information has been collected without guardian consent, we will promptly take remedial measures in accordance with laws and regulations, including stopping the relevant personal information processing activities and deleting the relevant information where required by applicable laws and regulations.

If you are a minor’s parent or other legal guardian and discover that we have improperly processed minors’ personal information, you may contact us using the contact details provided in this Policy.

IX. How your personal information is transferred globally

For personal information collected and generated during our operations within the territory of the People's Republic of China, we will, in accordance with laws and regulations, store it within China through servers of domestic third-party cloud service providers.

X. How this Policy is updated

We will update this Policy from time to time in accordance with relevant national laws, regulations, and regulatory policy provisions, combined with industry development and our operational actual situation.

Without your explicit consent, we will not reduce the rights you should enjoy according to this Policy. When major changes occur to this Policy, we will promptly notify you through pop-up reminders, message pushes, email notifications, or announcements on the official website. After we update this Policy, we will promptly publish the latest version on channels such as the Qkids official website. If you do not agree with the modified Policy, you have the right and should immediately stop using our products and services.

For major changes, we will also provide more prominent notifications (including for certain services, we will send notifications via email explaining the specific changes to the Policy). The "major changes" referred to above include but are not limited to:

1. Major changes to our service model. Including the purpose of processing personal information, the types of personal information processed, and the way personal information is used;

2. Major changes occur in our ownership structure, organizational structure, etc. Such as changes of ownership caused by business adjustments, bankruptcy mergers, etc.;

3. The main objects of personal information sharing, transfer, or public disclosure change;

4. Your rights in participating in personal information processing and the way they are exercised undergo major changes;

5. When the department responsible for handling personal information security, contact method, and complaint channel for which we are responsible change;

6. When the personal information security impact assessment report indicates high risks;

7. Other changes that may have a major impact on your personal information rights and interests.

To enable you to receive notifications in a timely manner, we recommend that you promptly notify us when your contact information is updated. If you continue to use our products and/or services after this Policy update takes effect, it indicates that you have fully read, understood, and accepted the updated Policy and are willing to be bound by the updated Policy.

Whenever the Privacy Policy is updated, we will notify you through in-platform messages, and you can choose to view or ignore. You can also view this Policy on the Qkids platform through "Mine → Settings → Privacy Policy" or "Mine → Settings → About Us → Privacy Policy".

XI. How to contact us

If you have any questions, suggestions, or complaints regarding this Policy or matters related to your personal information, please call customer service phone to contact us. We will always be committed to fully protecting your information and providing you with better quality experience and services.

In general, we will reply within fifteen (15) working days. If you are not satisfied with our reply, especially if our personal information processing behavior has damaged your legitimate rights and interests, you can also file complaints or reports with relevant regulatory authorities such as cyberspace, telecommunications, public security, and commerce and industry, or file a lawsuit in the people's court with jurisdiction over our place of registration.