Privacy Policy

Terms of privacy

You are welcome to use the products and / or services provided by Guangzhou Guanyue Network Technology Co., Ltd. (hereinafter referred to as "Wingfox " or "we") on the Wingfox platform.Wingfox attaches great importance to the protection of users' privacy and personal information.When you use Wingfox products / or services, we may collect and use your relevant information. We hope to use the "Wingfox Privacy Policy" (hereinafter referred to as"the Privacy Policy") to explain to you how we collect, use, store, and share this information when you use our products and / or services, and how we protect this information . Your visit Wingfox website or log-related clients use Wingfox all goods and services provided, apply this Privacy Policy, please read carefully.

You know and confirm that you have read and fully understood all the contents of this privacy policy when registering. You are reminded that we use "blackened and italicized" writing to make special reminders for sensitive personal information. Before providing us with any personal sensitive information that belongs to you, please clearly consider that such provision is appropriate and agree that we can process your personal sensitive information in accordance with the purposes and methods described in this privacy policy. We will collect and use your personal sensitive information after obtaining your consent to implement the relevant services provided by this platform to you.

If you do not agree with any content of this privacy policy, you should stop using our products or services. Your use of our products or services means that you have read and agree to our collection, use, storage, sharing, and protection of your relevant information in accordance with this privacy policy. After this Privacy Policy is updated, we will pass it Wingfox network station, Wingfox issued an updated version and remind you to update the content before the commencement by site notice or by other appropriate manner on the mobile side, please also visit Wingfox in order to keep abreast of the latest Privacy policy. If you continue to use our products and / or services after we update this privacy policy , it means that you have agreed to the content of the updated privacy policy, and agreed that we collect, use, save and share in accordance with the updated privacy policy Information about you.

If you have any questions about this privacy policy or related matters, you can Wingfox website (the WWW. Wingfox .com )、E-mail(wingfoxcg@gmail.com contact us) or online consultation.

This privacy policy helps you understand the following:

1. How we collect and use your personal information

2. How do we use cookies and similar technologies

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

4. How do we store and protect personal information

5. How do you manage your personal information

6. About the protection of minors’ information

7. Application and revision of this privacy policy

8. Interpretation of terms

1. How we collect and use your personal information

(1) Active authorization from you

In some scenarios, you may actively provide us with personal information to obtain a more complete functional experience, and we will provide an entry for information submission in the corresponding function. If you do not provide such information, you can still use our related services normally, but some additional functions may not be available. Some functions require you to open the corresponding access permission to our application on your device. (If supported by your device / operating system) You can decide whether to enable or disable the above functions at any time. Please note that once you have opened the relevant permissions or submitted relevant information, you are deemed to have actively authorized us to collect and use the above information. If you turn off the relevant permissions, it means that you have cancelled these authorizations, and we will no longer continue to collect and use your personal information. Your decision to close the authority will not affect the previous processing of personal information based on your authorization.

(2) Necessary when we provide products and / or services to you

When you use our products and / or services, you should respond to the functions of the products or services, improve the functions of the products or services, and ensure the safety and compliance of the products or services. We may collect, store and use the following information related to you to achieve the above functions. If you do not provide relevant information, you will not be able to enjoy our products and / or services. These functions mainly include:

1. User registration

Before you use most of the products and / or services we provide , you need to register as our user. When you register as our user, you need to provide us at least your nickname, password, your own mobile phone number or your email address, and we will verify whether your identity is valid by sending SMS verification code or email verification .

2. Purchase payment

When you are ready to purchase the goods or services provided by us, or when you are ready to purchase the goods or services provided by our affiliates, partners / organizations, our system will generate your purchase order. This process may require you to fill in the consignee’s name, shipping address, and contact information. At the same time, the order will include your order number, purchased goods or services information, the amount to be paid, and the payment method. The foregoing information constitutes your order information. We will use your order information for identity verification, transaction confirmation, payment settlement, delivery, and after-sales consultation. We will also use order information to determine whether your transaction is abnormal to protect your transaction Safety.

3. Course learning

When you use courses, tutoring, and learning services provided by us or our affiliated partners / institutions, we may record your learning information, including: your basic knowledge information, learning time, question content, learning preferences, etc. We will use this part of the information to analyze your learning status and provide you with an optimized reference basis for our services.

4. Customer service after-sales

Our customer service staff or course consultants will get in touch with you through the email, mobile phone number or other communication methods reserved for your account .

5. Ensure safety

In order to improve the security of the system when you use our products and / or services, prevent phishing website fraud and protect account security more accurately, we may learn about your browsing information, order information, your commonly used software information, and device information , User behavior information and other means to determine the risk of your account, and may record some link addresses that are technically judged to be abnormal; we will also collect your device information for problem analysis, count traffic and troubleshoot possible risks.

(3) You are fully aware that we do not need your authorization and consent to collect and use personal information in the following situations:

1. Related to national security and national defense security;

2. Related to public safety, public health, and major public interests;

3. Related to criminal investigation, prosecution and trial;

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

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

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

7. The information subject takes the initiative to disclose to the public;

8. It is necessary to maintain the safe and stable operation of the products and / or services provided;

9. At the request of the competent authority of the state;

10. Other circumstances stipulated by laws and regulations.

(4) Personal information from third parties

We may obtain personal information that you have authorized to share from a third party (such as your avatar, third-party login account, nickname and other information brought in from a third-party login), and after you agree to this privacy policy, we will associate this part of the information with your account Binding. We will use your personal information on the premise of complying with relevant laws and regulations after confirming the legitimacy of the source of personal information in accordance with the agreement with the third party.

(5) Anonymized use of personal information

After collecting your personal information, we will use technical means to anonymize the data, and the anonymized information will not be able to identify the subject. Please understand and agree that in this case we have the right to use anonymized information; and without disclosing your personal information, we have the right to analyze the user database and make commercial use.

2. How do we use cookies and similar technologies

When you use our products and / or services, we may identify you through data files. The one or more data files sent to your device are unique and can only be read and used by our server.These data files may be Cookies/FlashCookie or other similar technologies. The purpose of sending you such data files is to simplify your login steps, store your related preferences, help judge your login status, and protect your account and data security.

You can manage or delete such data files by yourself according to your preferences or the settings of your browser and operating system. For example, you can clear the cookies saved on your computer , you can also set your browser to refuse to accept cookies, etc. Once you have implemented this "cleanup" operation, in some cases you may be repeatedly asked to verify your identity, or your safe access to our products and / or services may be affected .

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

(1) Sharing

1. We will not share your personal information with any company, organization or individual other than Wingfox , except in the following cases:

(1 ) Obtain your explicit consent or authorization in advance;

(2 ) Provide in accordance with applicable laws and regulations, requirements of legal procedures, compulsory administrative or judicial requirements;

(3 ) Within the scope permitted by laws and regulations, it is necessary to provide for the protection of Wingfox , the affiliates or partners of the Wingfox website , you or other Wingfox users, or the public's interests, property or safety from damage;

(4 ) Only by sharing your personal information can we realize the core functions of our products and / or services or provide the services you need;

(5 ) Dealing with disputes or disputes between you and others according to your needs;

(6 ) Provided in accordance with the relevant agreement signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents;

(7 ) Use based on academic research;

(8 ) It is used based on the public interest in compliance with laws and regulations.

2. We may share your personal information with our affiliates. However, we will only share necessary personal information and are bound by the stated purpose in this privacy policy. If our affiliates want to change the purpose of processing personal information, they will again seek your authorization and consent.

3. We may share your order information, account information, device information, and location information with partners and other third parties to ensure the smooth completion of the services provided to you. However, we will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose. Our partners include the following types:

(1) Suppliers of goods or technical services. We may share your personal information with third parties who support our functions. These supports include providing infrastructure technical services, payment services, data processing, etc. to our business partners. The purpose of our sharing of this information is to realize the core functions of our products and / or services. For example, we must share your order information with course instructors or service providers to provide you with course after-sales service; or we need to combine your order number with The order amount is shared with the third-party payment institution to enable it to confirm your payment instructions and complete the payment, etc.

(2) Information push technology service provider. We use the news push service provided by the Jiguang push platform JPuch platform to push class update reminders, reminders of message responses, etc., and you understand and agree that the partner provides us with relevant information push technology services and agree that the first partner is Jiguang Privacy The relevant agreement in the policy
https://www.jiguang.cn/license/privacy .
We may use your personal information and the indirect user information formed by the collection of your non-personal information to share with the partners who entrust us to promote ("the entrusting party") and the suppliers who provide related technical services, but we will only share them with these The entrusting party or / and the technical service provider provide information about the coverage and effectiveness of the promotion, but will not provide your personally identifiable information, or we will aggregate this information so that it will not identify you personally.

4. For organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them and require them to handle personal information in accordance with our instructions, this privacy policy and any other relevant confidentiality and security measures.

(2) Transfer

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

1. Obtain your explicit consent or authorization in advance;

2. Provide information in accordance with applicable laws and regulations, legal procedure requirements, mandatory administrative or judicial requirements;

3. Provided in accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding platform rules) or other legal documents;

(3) Public disclosure

We will only publicly disclose your personal information under the following circumstances and under the premise of adopting industry-standard safety protection measures:

1. According to your needs, disclose your designated personal information in a disclosure method that you explicitly agree to;

2. In cases where your personal information must be provided in accordance with the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information based on the required personal information types and disclosure methods. Under the premise of complying with laws and regulations, when we receive the above-mentioned request for information disclosure, we will require the corresponding legal documents, such as subpoenas or investigation letters, to be issued. We firmly believe that the information we are required to provide should be as transparent as possible to the extent permitted by law. We have carefully reviewed all requests to ensure that they have a legal basis and are limited to data obtained by law enforcement agencies for specific investigation purposes and have legal rights. As permitted by laws and regulations, the documents we disclose are protected by encryption keys.

4. How do we store and protect personal information

(1) Unless otherwise agreed or otherwise provided by law, the personal information we collect and generate within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China. We will store personal information collected and generated outside the People's Republic of China in accordance with laws, regulations, international rules or international practices recognized by the People's Republic of China.

(2) We promise you that we will use the following measures to achieve a reasonable level of information security protection:

1. Technical measures

We will adopt security protection measures that comply with industry standards, including the use of encryption technologies such as transport layer security protocols for network services, to ensure the safety of user data during transmission, and to isolate stored data through isolation technology. In some scenarios where your personal information is used (such as personal information display, personal information confirmation, etc.), we will use a variety of data desensitization technologies including content replacement, one-way hashing, etc. to enhance the use of your personal information safety. We have also adopted strict access control, multi-factor authentication and other technologies to protect your personal information and prevent data from being obtained in violation of regulations.

2. Access specification

We have established an information security system, data classification management specifications, security / development specifications and other system specifications to manage the storage, access and use of your personal information. We signed confidentiality agreements with information contacts, and applied access logs, behavior monitoring, and special audit measures to comprehensively control data.

3. Other protection methods

In terms of employee safety awareness training, we will regularly hold safety and privacy-related publicity training and examinations. We also only allow employees and partners of Guangzhou Guanyue Network Technology Co., Ltd. and Guangzhou Guanyue Network Technology Co., Ltd. affiliated companies who need to know this information to access and contact personal information, and apply all the technical measures and regulatory restrictions mentioned above. We require related personnel to perform related confidentiality obligations. If they fail to fulfill these obligations, they may be dismissed or their cooperative relationship with us may be suspended until they are investigated for legal responsibility.

(3) The Internet environment is not an absolutely safe environment, and you cannot be sure whether you have been properly protected by communicating with other users through various communication methods. We recommend that you protect your personal information when using other communication tools, do not disclose personal information or private information about your account, and enable complex passwords on related tools.

(4) Please understand that due to technical limitations and various malicious methods that may exist, problems may occur due to factors beyond our control. According to the requirements of laws and regulations, after a personal information security incident unfortunately occurs, we will promptly inform you: the basic situation and possible impact of the security incident; the disposal measures we have taken or will take; suggestions that you can prevent and reduce risks independently ; Remedies for you, etc. At the same time, we will promptly inform you of the relevant situation of the event by email, letter, telephone, push notification, site news, etc. If it is difficult to inform the subjects of personal information one by one, we will adopt a reasonable and effective way to issue announcements, and proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

(5) We will save your transaction information within the period required by law, and will delete it or perform desensitization such as anonymization after the foregoing retention period expires.

5. How do you protect and manage your personal information

(1) We will do our best to protect your right to access, update, and correct your personal information. You have the right to exercise this right at any time, except in the circumstances stipulated by laws and regulations.

(2) In any of the following situations, you can request us to delete personal information:

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

2. If our handling of personal information violates our agreement with you;

3. If we terminate the service and operation.

(3) In some scenarios, you can actively authorize or revoke our authorization to obtain your personal information through the settings of the device or operating system. Please understand that when you withdraw your authorization or do not authorize us to obtain this part of your personal information, we cannot continue to provide you with the corresponding services that require this part of the information. However, your decision to withdraw the authorization will not affect the previous processing of personal information based on your authorization.

(4) In the following situations, we cannot respond to your request:

1. Related to national security and national defense security;

2. Related to public safety, public health, and major public interests;

3. Related to criminal investigation, prosecution and trial;

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

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

6. At the request of the competent authority of the state;

7. Other circumstances stipulated by laws and regulations.

6. About the protection of minors’ information

We attach great importance to the protection of minors’ personal information. If you are a minor under the age of 18 , you should ask your parents or guardians to read this privacy policy. Before obtaining your parent or guardian's explicit or written consent to the content of this privacy policy, you should stop using our products and / or services. If your parents or guardians do not agree to your use of our products and / or services or to provide us with information in accordance with this privacy policy , please immediately terminate the use of our products and / or services, and notify us in time so that we can take appropriate action Measures.

7. Application and revision of this privacy policy

This privacy policy is a privacy policy uniformly used by Guangzhou Guanyue Network Technology Co., Ltd. All products and / or services of Guangzhou Guanyue Network Technology Co., Ltd. are applicable to this privacy policy. Some other products and / or services of Guangzhou Guanyue Network Technology Co., Ltd. may have specific privacy policies for their products and / or services. These specific privacy policies will more specifically explain how we use your information in them. And these specific privacy policies are an integral part of this privacy policy; if there is any inconsistency between the specific privacy policies of these products and / or services and this privacy policy, the privacy policies of the specific products and / or services shall prevail .

With the development of the business of Guangzhou Guanyue Network Technology Co., Ltd., our products and / or services will be upgraded and adjusted. We may respond to this privacy in a timely manner based on changes in functions, changes in usage rules, changes in applicable laws and regulations, or changes in regulatory requirements. The policy is revised.

Once we revise this privacy policy, we will remind you of relevant content updates through our products and / or services. At the same time, please follow us to keep abreast of the latest privacy policy. If you continue to use our products and / or services after the revision of this privacy policy , it means that you have fully read, understood and accepted the revised privacy policy, and are willing to accept the constraints of the revised policy, otherwise you will not be able to continue to use us Products and / or services.

8. Interpretation of terms

(1) Guangzhou Guanyue Network Technology Co., Ltd. ("we") referred to in this privacy policy

(2) The personal information mentioned in this privacy policy mainly includes:

1.Basic personal information (including personal name, birthday, gender, address, telephone number, e-mail address);

2.personally identifiable information (identity card and other valid documents information);

3. Network identification information (including system account, IP address, email address, the aforementioned related passwords, passwords, secret information, etc.);

4.Personal property information ( virtual property information such as transaction records, consumption records, Wingfox coins, courses attended, etc.);

5.Personal Internet records (website browsing records, software usage records, click records, etc.);

6.Personal device information (including hardware model, device hardware parameters, operating system type and basic information, software unique device identification code, SIM card information, etc.);

(3) The anonymization of information mentioned in this privacy policy refers to:

Through the technical processing of personal information, the subject of personal information cannot be identified, and the processed information cannot be restored.