Shenmo Abacus User Privacy Protection Policy

Update date: November 10, 2021

Effective date: November 10, 2021

Beijing Shenmo Culture Communication Co., Ltd. (referred to as "Shenmo Culture"; together with its affiliated companies, "we") understands the importance of protecting personal information. For this reason, we have updated this Privacy Policy (hereinafter referred to as the "Policy") so that you can understand how we collect, use, save, share, transfer and publicly disclose your relevant information when you visit or use the website, mobile applications, third-party applications or portals (hereinafter referred to as the "Open Platform") of "Shenmo School" operated and managed by us in Chinese Mainland. Therefore, please read this Privacy Policy carefully

If you are under 18 years old, you must ask your parents or other legal guardians (collectively referred to as "guardians") to read this policy and use our services or provide us with your information with the consent of your guardians. If you are the guardian of a minor, you should guide and supervise them correctly when they register or use our products and/or services.

For the use and collection of personal information of minors with the consent of their guardians, we will only use, share, transfer or disclose this information as permitted by laws and regulations, with the explicit consent of the guardians, or as necessary to protect minors.

If you have any questions about this policy or matters related to this policy, you can contact us through the feedback channels listed in the "Contact Us" section of this policy, and we will provide you with answers as soon as possible.

For your convenience in reading and understanding the content of this policy, we have displayed the thematic content of each section in this policy as follows:

1. How do we collect and use your personal information

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

3. How do we store your personal information

4. How do you manage your personal information

5. How do we use cookies and similar technologies

6. Provide external access and links to other websites

7. Information unsubscribe

8. How do we protect your personal information

9. Update and Scope of Application of this Policy

10. Contact Us

Personal information refers to various types of information recorded electronically or in other ways, which can be used alone or in combination with other information to identify the identity of a specific natural person or reflect the activities of a specific natural person. When you use our products or services, you authorize us to collect and use personal information in the following two scenarios:

1. In order to provide you with the basic functions of our products or services, you must authorize us to collect and use necessary information. If you refuse to provide the corresponding information, you will not be able to use our products or services normally

To provide you with additional features of our products and/or services, you may choose to authorize us to collect and use the information. If you refuse to provide, you will not be able to use the relevant additional features or achieve the intended functional effects, but it will not affect your normal use of the basic functions of our products and/or services

Please note that information that alone or in combination with other information cannot identify your identity or establish direct contact with you is not considered personal information. In addition, information that has undergone desensitization processing (i.e., using technical means to process personal information so that the personal information subject cannot be identified and cannot be restored after processing) does not belong to personal information. We do not require your authorization or consent when collecting and using such information. When your information can be used alone or in combination with other information to identify your personal identity, during the period of combined use, this information will be treated and protected as your personal information in accordance with this policy

1.1 You must authorize us to collect and use your personal information. We will collect, store, and use the following information related to you based on legal, legitimate, and necessary principles to achieve the following functions. If you do not provide this relevant information, you will not be able to enjoy the products or services we provide to you. These features include:

1.1.1 Necessary Functions for Implementing Network Platform Services

(1) Create an account

To comply with the requirements of laws and regulations and to log in to our platform and use our services, you need to register as our user. When you register, you need to provide us with at least your phone number for creating your Shenmo account. If you do not provide this information, you may not be able to use our services

You can modify or supplement your member name, gender, and date of birth in the member center. You can choose not to provide this information, which will not affect the basic service functions of your use of the online platform

If you choose to authorize the use of a third-party account to log in, we will obtain your account information (including account nickname, avatar, region, and gender) from the third party and bind it to your Shenmo account for quick login

(2) Order and activity information

When you use our purchasing service, you need to provide at least the recipient's name, shipping address, and contact phone number

If you participate in our related activities, you need to provide at least your contact phone number

All the above information constitutes your order information. We will use order information for identity verification, transaction confirmation, payment settlement, delivery, order inquiry, customer service consultation, and after-sales service. We will also use it to determine if there are any abnormalities in your transaction to protect its security. If you do not provide the aforementioned information, you may not be able to use our services

(3) Payment

When you place an order or recharge, you can choose the payment services provided by the third-party payment institutions (including Alipay and WeChat payment channels, collectively referred to as "payment institutions") that we cooperate with to pay. The payment function itself does not collect your personal information, but we need to share your order number and transaction amount with these payment institutions to confirm your payment instructions and assist you in completing the payment. If you do not provide the aforementioned information, you may not be able to use the relevant payment services

(4) Delivering products or services

After you place your order, the third-party delivery platform and company we cooperate with will complete the delivery of your order. You acknowledge and agree that these third-party platforms and companies will use your order information during the above process to ensure the safe delivery of your order

(4) Customer service

Our customer service will use your account information and order information to respond to your customer service needs. In addition, to ensure the security of your account, our customer service may use your account information, order information, name, contact phone number, and address to verify your identity with you. In addition, when communicating with our customer service personnel, we may require you to provide other reasonable and necessary information in addition to the above information to further respond to your needs or verify your identity

(5) Personal information that we may indirectly collect

To ensure the security of your account, confirm transaction status, and provide after-sales and dispute resolution services, with your authorization, we may obtain your personal information from third parties (such as collecting and processing your transaction, payment, booking, and other information related to the transaction progress through the third-party information system, payment institution, etc. directly involved in the transaction and the transaction you have selected, in order for us to process your order and ensure the smooth completion of the service, or better prevent malicious behaviors such as fraud and brushing orders). We will obtain your relevant information from our partners with your authorization in accordance with legal requirements and agreements with third parties, and use your information after confirming the legality of its source

1.1.2 Improve products and services and enhance user experience

During the use of the network platform, in order to process and analyze information and consumer behavior related to your access, purchase, and use of our products and/or services, and conduct user analysis, we may collect, record, and use your account information, location information, device information (such as device name, device model, device MAC address, unique device identifier, application version, mobile network information, login IP), log information (such as browser type, language used, operating system, access date and time, browsing, clicking, searching, webpage requests, publishing, and sharing information), and order information. We may also need to obtain other information from you (including the relevant information you provide when contacting customer service, the questionnaire response information you send us when participating in surveys, and the relevant information we obtain when interacting with our affiliates and partners) to achieve the above purposes. In addition, we may associate the information collected from your various devices so that we can provide you with consistent services

1.1.3 Security Management

During your use of the online platform, in order to ensure the security of your account and the normal operation of services, identify abnormal account status, and understand product compatibility, we may request or automatically collect and use your account information, log information, and device information

1.2 You can choose whether to authorize us to collect and use your personal information

1.2.1 Features to Enhance Service Experience

To make the services you enjoy more convenient and enhance your service experience on our platform, we may collect and use your personal information in the following additional features. If you do not provide this information, you may not be able to use the additional features that these can bring you or need to fill in some information repeatedly when purchasing certain products, but it does not affect your enjoyment of basic service functions, including but not limited to:

(1) Camera based additional features: You can use this additional feature to scan codes or participate in our related marketing and promotional activities

(2) Additional features based on album authorization: You can choose to enable the album authorization of the system, and authorize us to access your album by actively uploading pictures, videos, etc., so that you can publish content and participate in our related marketing and promotion activities by uploading photos or videos. We will collect the above information that you choose to upload and publish. You can disable this feature in your system permissions. Once disabled, you may not be able to participate in related marketing and promotional activities by uploading pictures, videos, etc., but it will not affect your use of our basic services/products

The above additional features may require you to grant us access to your camera, photo album, etc. on your device in order to collect and use the information involved in these features. We will obtain your confirmation before enabling this feature, and you can also check the activation status of the above permissions item by item through the settings function in your device system, and decide whether to enable or disable these permissions at any time. Please note that by granting these permissions, you authorize us to collect and use your personal information to achieve the aforementioned functions. By granting these permissions, you cancel them, and we will no longer continue to collect and use your personal information, nor will we be able to provide you with the functions corresponding to these authorizations. Your decision to close permissions will not affect the processing of personal information based on your authorization

2.1 Sharing

We attach great importance to the protection of your personal information. Your personal information is an important basis and component of the products or services we provide to you. We only collect and use your personal information for the purposes and scope described in this policy or as required by laws and regulations, and strictly keep it confidential. We will not share your personal information with any company, organization, or individual without your consent, except in the following circumstances:

(1) Obtain your consent or authorization in advance

(2) To achieve the purposes described in the section "How We Collect and Use Your Personal Information" of this policy

(3) To fulfill or realize our rights and obligations in this policy or relevant agreements with you;

(4) When it is necessary to share with third parties based on the relevant agreements (including electronic agreements, terms, or platform rules signed or confirmed online) or legal documents that you have signed with us;

(5) In accordance with relevant laws, regulations, legal procedures, administrative or judicial requirements;

(6) Within the scope permitted by laws and regulations, it is necessary to provide necessary information to safeguard the interests, property, or safety of us, our affiliates or partners, you or other users, or the general public from harm;

(7) Only by sharing your information can we provide you with the services you need;

According to your request, we will handle disputes or controversies between you and others;

(9) Used for academic research purposes (if applicable, but only for the purpose of achieving public interest);

(10) Used based on social public interests that comply with laws and regulations

When we share your personal information with third parties in accordance with the provisions of this policy, we will only share necessary personal information and be bound by the purposes stated in this policy. If you want to change the purpose of processing personal information, we will seek your authorization and consent again.

2.2 Transfer

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

(1) Transfer made with your explicit consent or authorization in advance

When it comes to mergers, acquisitions, asset transfers, or similar transactions involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy. Otherwise, we will require the company or organization to seek your authorization and consent again

2.3 Disclosure

We will not disclose your personal information except for necessary public disclosures such as displaying relevant desensitization information when announcing account winning or penalty notices, or obtaining your explicit consent. However, based on legal regulations, mandatory requirements from judicial or administrative authorities, we may disclose your personal information to authorized authorities. However, in the event of the above situation, we will require the disclosing party to provide corresponding valid legal documents and take necessary security measures for the disclosed information

2.4 Exceptions to obtaining prior authorization and consent for sharing, transferring, or publicly disclosing personal information

In the following situations, we may collect and use your personal information in accordance with the law without obtaining your authorization or consent:

(1) Related to national security and defense security

(2) Related to public safety, public health, and major public interests

(3) Related to criminal investigation, prosecution, trial, and execution of judgments

(4) For the purpose of safeguarding the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain their consent

(5) is necessary for legitimate news reporting

(6) The personal information collected is self disclosed by the personal information subject to the public

(7) Collecting your personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels

(8) Used to maintain the safe and stable operation of the provided products or services, such as discovering and handling product or service failures

(9) Other circumstances stipulated by laws and regulations

2.5 Third party services

In order to provide you with more comprehensive and high-quality products and services, we may authorize our partners to provide you with some services (specifically, we may access third-party application programming interfaces (APIs) and software tool development kits (SDKs) from these authorized partners). For this purpose, we may share some of your personal information with these partners to provide better customer service and user experience. Please note that 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. We will make reasonable commercial efforts to require these partners to fulfill their confidentiality and data security obligations. At present, we have access to the following types of third-party services:

(1) Used for the display, statistics, and monitoring of advertising and service information

(2) Used for message push, SMS sending, and event reminder functions

(3) Used for payment related functions, including order payment, transaction verification, settlement, payment information summary and statistics, etc

(4) Used to obtain and analyze device location information, device information, and log information with your authorization

(5) Used for third-party authorization services, including third-party account login, sharing relevant content to third-party products or platforms, etc

(6) Used to support product functional modules, including customer service support, content storage, and display, etc

(7) Used to improve or optimize the functionality and performance of this application, repair features, and enhance or improve server operational efficiency

(8) Used for account, application, and service operation security, as well as for the reinforcement of this application

If relevant laws and regulations have clear provisions on the period for which we store your personal information, we will first comply with such provisions; Unless otherwise specified, we will keep your personal information until: (1) all the purposes for which we collect, use, and share your personal information are achieved

(2) You terminate the use of our products or services

(3) You explicitly request us to delete your personal information. After the expiration of personal information retention, we will adopt deletion, anonymization, or other processing methods stipulated by laws and regulations

We only store your personal information within the territory of the People's Republic of China. In certain special circumstances (such as disaster recovery backup, improving user connection experience), we may store your personal information outside the aforementioned area, provided that we comply with applicable laws. We ensure that when transferring your personal information to other regions, such personal information remains under our control, and local laws do not diminish the protection of your personal information. We will also take necessary measures to ensure the security of such personal information. If there are clear requirements under applicable laws, we will conduct regular security assessments for cross-border transmission of personal information and decide whether to continue cross-border transmission of your personal information based on the assessment results.

Shenmo Culture has always spared no effort in protecting privacy rights, especially for minors. If you are a minor, please obtain the consent of your guardian before using any online platforms or services provided by this platform.

For the collection of personal information of minors using the services of this platform with the consent of the guardian, this platform will only collect, use, store, share, and transfer the personal information of minors when permitted by laws and regulations or with the explicit consent or necessary protection of the guardian. If your guardian does not agree to your use of the platform services developed by Shenmo Culture in accordance with this policy or to provide your information to the platform developed by Shenmo Culture, please immediately terminate your use of the platform services developed by Shenmo Culture and notify us in a timely manner so that appropriate measures can be taken.

When you, as a guardian, choose to use our products or services for a minor under your guardianship, we may need to collect personal information from the minor under your guardianship for the purpose of providing you with necessary services. If we need to collect personal information of minors from you in specific services, we will obtain your authorization and consent in advance, and inform you of the purpose and purpose of the collection. If you do not provide the aforementioned information, you will not be able to enjoy the related products or services we provide. As a guardian, you should fulfill your guardianship responsibilities correctly and protect the personal information security of minors. If a minor needs to register or use our products and/or services, you should guide and supervise them correctly.

If you wish to access or change your personal information, you can usually log in to your platform member account and find your personal information and the entry to edit your personal information on the member account management page (the specific access path is subject to the website, application or network platform provided by this platform). If you are unable to access or change your personal information through the above methods, you can contact the platform developed by Shenmo Culture through "Contact Us" at the end of the article

If you wish to revoke your authorization for us to continue collecting and using your personal information, you can change the scope of your authorization for us to continue collecting personal information or revoke your authorization by deleting information, turning off device features, etc. (for example, you can turn off your authorization for mobile photo albums through "Settings Privacy Photos" on your iOS device). You can also revoke all authorization for us to continue collecting your personal information by canceling your account. However, please understand that some functions require basic personal information to be completed. When you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, nor will we process your corresponding personal information. But your decision to withdraw consent or authorization will not affect the personal information processing previously carried out based on your authorization

If you wish to cancel your membership account on this platform, you can find the cancellation portal in the "Account and Security" section of the "Member Center". You can also contact our platform through the "Contact Us" section at the end of the article, and please follow the instructions provided by the hotline to carry out relevant operations, provide relevant identity verification information, and pay attention to the relevant tips informed by the hotline. After verifying your identity and officially initiating the account cancellation process, we will cease to provide you with products or services, and delete, anonymize, or process your personal information in accordance with relevant laws and regulations

To ensure the security of personal information, we may conduct necessary identity verification when you request to access, modify, or delete your personal information. We will respond to your request within 15 days after receiving your feedback and verifying your identity. For your reasonable requests, we generally do not charge any fees, but for requests that are repeated multiple times or exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may refuse requests that are unnecessarily repetitive, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup disks)

To ensure the normal and efficient operation of the website or application, and to provide you with a more convenient access experience, we will use cookies and similar technologies on your device terminal or system. These technologies will assist you in accessing your information when visiting our website or application for a series of specific purposes, including simplifying the process of filling in personal information, providing you with preference settings for safe shopping, helping you optimize your selection and interaction with advertisements, protecting your data security, and more

If you refuse our use of cookies and similar technologies to collect and use your relevant information, you can manage, partially or completely refuse cookies or similar technologies through the settings of your device or browser, provided that the device or browser has this function; Or delete cookies or similar technology data files that have already been stored on your computer or device, so that we cannot fully or partially track your personal information. If you need detailed information on how to change browser settings, please refer to the relevant settings page of the browser you are using. However, please understand and be aware that some of our products or services can only be achieved through the use of cookies or similar technologies. If you refuse to use or delete them, you may not be able to use our related products or services normally or obtain the best service experience through our products or services. At the same time, it may also have a certain impact on your information protection and account security

Our website, applications, etc. may contain links to third-party websites, products, and services. Our services may also use or provide products or services from third-party platforms. These third parties may collect, use, and process your personal information, but may not necessarily comply with the provisions of this policy or may have provisions that are contrary to this policy. This policy does not apply to the collection, use, and processing of your personal information by these third parties. Therefore, please carefully read and understand the relevant terms of privacy protection of these third parties. If you find that the links to these third-party websites, products, and services are at risk, please terminate the relevant operations to avoid infringement of your rights.

After you register as a member of this platform, we may send you text messages containing the latest news or other market information about our platform's products, services, and promotional activities. Generally, if you do not wish to receive such text messages from us, you can reply with "TD" (or other unsubscribe instructions displayed) to cancel the receipt

We attach great importance to the security of your personal information. To this end, we are committed to adopting various security measures, including establishing reasonable information security management policies, implementing security technologies, etc., to minimize the risk of unauthorized access, use, modification, disclosure, damage, and deletion of your personal information. These measures include but are not limited to:

During the process of information transmission, we encrypt the information you input by using network security layer software (SSL) to minimize the risk of it being intercepted

2. When transmitting and storing sensitive personal information, we adopt various security measures such as encryption, permission control, and de identification to ensure the security of transmission and storage

3. We have implemented strict control over access permissions to our data center to prevent unauthorized access and use of your information

4. We have established a dedicated information security team to promote and safeguard personal information security, and have established policies and processes related to data classification and grading, data security management, data security development, emergency response, etc. to manage and regulate the storage and use of personal information

5. You can apply for account cancellation by providing relevant information through telephone (calling the Shenmo hotline at 010-58815008 (working hours: 9:00 am to 5:00 pm every day). Before you cancel your account, we will require you to undergo necessary identity verification, including personal identity, security status, device information, etc. You acknowledge and understand that the act of canceling your account is irreversible. After you cancel your account, we will cease to provide services to you and delete all information related to your account or anonymize it, except as otherwise provided by laws and regulations

It should be noted that there is no absolutely secure information environment in real life, especially in certain special situations where, despite taking various security measures, there is still a risk of personal information leakage or loss (such as hacker attacks, etc.). Therefore, in order to protect your personal or property safety, please do not provide your personal information to us or any third party providing services on our behalf in any unreliable information environment

After you terminate your use of our products and services, we will cease to collect and use your information (except as otherwise provided by laws, regulations, or regulatory authorities). If we cease operations, we will promptly cease the collection of your personal information, notify you of the cessation of operations through individual delivery, announcement or other appropriate means, and delete, anonymize or adopt other processing methods stipulated by relevant laws and regulations for the personal information we hold

If we become aware of any personal information security incidents that unfortunately occur, we will inform you through multiple channels as required by laws and regulations. If it is difficult to inform you one by one, we will take reasonable and feasible measures to publish an announcement. In addition, we will comply with the requirements of regulatory authorities and report the disposal of personal information security

This policy is updated and effective on the update date indicated at the beginning of the document. This policy is a general privacy policy that we apply uniformly. However, certain specific services may be subject to specific privacy policies, which form a part of this policy. If there is any inconsistency between the privacy policy of any specific service and this policy, the privacy policy of that specific service shall apply

We will update this policy from time to time. We will not restrict your rights under this policy without your explicit consent. If we update this policy, we will publish the updated version on the designated link on our official website. If such updates result in a substantial reduction or significant change in your rights under this policy, we will notify you in a prominent location or by sending you push messages or other means before this policy takes effect. If you continue to use our services, it means that you have fully read, understood, and agreed to be bound by the revised policy. The circumstances of 'significant changes' include but are not limited to:

Our service model has undergone significant changes. Such as the purpose of processing personal information, the types of personal information processed, and the ways in which personal information is used

2. We have undergone significant changes in ownership structure, organizational structure, and other aspects. Changes in ownership caused by business adjustments, bankruptcy mergers and acquisitions, etc

3. The main recipients of personal information sharing, transfer, or public disclosure have changed

4. There have been significant changes in your right to participate in personal information processing and the way you exercise it

5. Our team responsible for handling personal information security, contact information, and complaint channels have changed

When the personal information security impact assessment report indicates a high risk

If you have any questions, opinions, or suggestions regarding this policy, you can contact us through the following methods:

Shenmo Hotline: 010-5881508 (Working hours: 9:00 AM to 5:00 PM daily)

Contact email: shenmojiaoyu@163.com

For your questions, opinions, or suggestions, we will generally respond to you within 30 days after verifying your user identity

1. WeChat Open Platform SDK

Type: Tool

Description: Device model, operating system, independent device identifier (IMEI, IDFA, Android ID, MAC, OAID, etc.), Android advertiser identifier, network card (MAC) address, International Mobile Device Identity (IMEI), login IP address, network access method, type, and status

Usage scenario: Share content to WeChat

Company: Shenzhen Tencent Computer System Co., Ltd

Official website link: https://wikinew.open.qq.com/

2. Aurora Push SDK

Type: Tool

Description: Device information: Device identifier (IMEI, Android ID, MAC, OAID related information), application information (application crash information, notification switch status, software list related information), device parameters and system information (device type, device type number, operating system and hardware related information)

Usage scenario: Used to implement message push function

Company: Shenzhen Hexun Huagu Information Technology Co., Ltd

Official website link: https://www.jiguang.cn/

3. Alipay Alipay; mPaaS; Alibaba ride code; Alibaba Sesame Credit real name authentication; Sesame certification

Type: Tool

Description: SN Personal Information: We will receive and record device related information (including device model, operating system version) based on your specific operations during software installation and use. Please note that individual device information and log information cannot identify the identity of a specific natural person. 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 non personal information will be considered personal information. Unless authorized by you or otherwise provided by laws and regulations, we will anonymize and de identify this type of information. Types of personal information collected: system language, system unique identifier, external storage status, network type, device model, device manufacturer, SIM card serial number, IMEI, MAC address, ANDROIDID, IP address, WiFi information, application installation list, OpenUDID

Usage scenario: used for Alipay payment

4. Baidu Speech Ability Engine (SPEECH) Service - Speech Synthesis

Type: Tool

Description: We will receive and record device related information (system language, system unique identifier, external storage status, network type, device model, device manufacturer, SIM card serial number, IMEI, MAC address, ANDROIDID, IP address, WiFi information, application installation list, OpenUDID) based on your specific operations during software installation and use. Please note that individual device information and log information cannot identify specific natural person identities. 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 non personal information will be considered personal information. Unless authorized by you or otherwise provided by laws and regulations, we will anonymize and de identify this type of information

Purpose of use: To achieve text to speech conversion function

Company: Beijing Baidu Netcom Technology Co., Ltd

Official website link: https://ai.baidu.com/tech/speech