Personal information and privacy protection policy

Table of contents:

1.How we collect your information

2.If you use cookies and other similar tracking technologies

3.How we entrust you to process, share, transfer and publicly disclose your personal information

4.How to give you the right to manage your personal information

5.How to protect your personal information

6.How your personal information is stored

7.How to protect minors’ personal information

8.How to update this policy

9.How to contact us

10.Supplementary Provisions

11.Keyword definition

BLINGABC (registered address: 5549 Brooks St. Montclair CA 91763 ) (hereinafter collectively referred to as "B LINGABC " ) attaches great importance to the personal information security and privacy protection of our users. We are providing users ( hereinafter referred to as "you" ) with convenient and fast While providing products and services ( for details, please refer to Article 10 of the " Personal Information and Privacy Protection Policy " : Keyword Definitions ) , we are committed to improving the transparency of information processing, enhancing your convenience in information management, and ensuring the security of your information.

This privacy policy aims to explain to you, 1 ) the purpose, method and scope of our collection, use and sharing of your personal information and other related information in the process of providing products and services to you; 2) our information security protection measures ;3) Your rights to manage personal information and how to implement it. Please be sure to read it carefully.

When you provide us with your personal information or use our products and services, it means that you are aware of and agree to what we describe in this privacy policy. We will collect, store, use, share and protect your personal information in accordance with this privacy policy. Please be aware that after you agree to this privacy policy, the corresponding device permissions will not be enabled by default. When important or sensitive device permissions are involved, we will ask for your consent again by popping up a separate window when you use the corresponding business functions. Then turn on. After the permission is turned on, you can turn it off at any time through the device settings. If you do not agree to enable permissions, it will not affect the use of other business functions.

the key contents in bold text in the following description to draw your attention . During use, please carefully consider whether to provide us with this information . We will do our best to protect your personal information.

You should choose whether to agree to the contents of this policy and to use our products and services after carefully reading and fully understanding this policy. When you click " Agree " , it means that you have read and are willing to accept all the contents of the "Personal Information and Privacy Protection Policy". If you do not agree with the contents of this policy, we will be unable to provide you with products and services normally , or the products and services will not be able to achieve normal service effects and can only be browsed in guest mode. If you have any doubts or dissatisfaction with the contents of this User Agreement (especially the terms involving exemption or liability limitation), you can contact us at any time according to the contact information listed in this Agreement, and we will handle your request or complaint in a timely manner. and explain it to your needs.

This policy was last updated on November 17 , 2023 , and will officially take effect on November 21 , 2023 .

1. How to collect and use your personal information

1.1 We will collect and use your personal information based on the principles of fairness, minimum necessity, and transparency for the purposes stated in this policy. We do not collect personal information unrelated to providing services, nor will we refuse you to use our products and services because you do not agree to provide unnecessary personal information. If we use your personal information for other purposes not specified in this policy, or collect and use your personal information for other specific purposes, we will inform you in a reasonable manner and ask you again before collecting and using it. Your consent.

1.1.1 Register/log in account

(1) When you register an APP account , you need to provide us with your mobile phone number , and we will send a SMS verification code to your mobile phone number to verify that the mobile phone number you registered is valid. According to laws and regulations and for security purposes, if you do not provide your mobile phone number for verification, registration will fail and you will be unable to use the relevant functions of the product and service .

(2) When you log in to our website or APP as a user , you need to provide your mobile phone number when registering and log in after obtaining the verification code.

(3) You can also log in by setting a password and using the " mobile phone number + password" method. You need to set a password and submit it. The password you set will be encrypted and stored using standard encryption methods. No one else except you, including our employees, can know the password you set. However, the Internet is not absolutely secure. environment, we strongly recommend that you use complex passwords to help us ensure the security of your account .

(4) When you forget your password and need to retrieve it, you need to provide us with the mobile phone number you used when registering . We will send a verification code to the mobile phone number. After the verification is successful , you can re- enter the new password and re-enter the password. Log in.

( 6 ) You can learn about the international education products and services we provide you without logging in. When you access the products and services we provide, you can fill in your name (nickname ), Mobile phone number so that our staff can contact you to provide you with more targeted learning services.

1.1.2 Your personal information we obtain from third parties

Third-party jump login

can use a third-party account to register and log in to the APP . You first need to register a third-party account (Apple, Google account) , and then bind your Sure Chinese account information to log in. During this process, in order to verify your account for login purposes, we will collect and store your account number, password, and mobile phone number for account registration and login in accordance with the "Personal Information and Privacy Protection Policy" . Please read the "Personal Information and Privacy Protection Policy" carefully before using the registration and login functions .

Personal information we actively collect during the process of providing products and services to you

Under the premise of complying with laws and regulations, in order to protect the security of your account, troubleshoot abnormalities, and provide you with better services, we will collect and use the following information generated during your use of products and services .

1.2.1Device information _

In order to conduct statistical analysis, troubleshoot abnormal information, provide you with consistent services and a better user experience , when you use this platform, we will collect your personal commonly used device information, including unique device identification codes (IDFA, IMEI, Android ID, IMSI), device type, device serial number, device manufacturer, device model, screen size, system version, application installation list, MAC address, device sensor, network information (IP address, WiFi information (SSID, BSSID)), mobile phone Operator, network type , and associate these device information.

We cannot prevent the connected third-party SDK from obtaining your device identifier (including IDFA, IMEI, Android ID, IMSI), MAC address, and device location. We can only restrict the third-party SDK to obtain your consent to the " Personal Information and Privacy Policy" 》 personal information can be collected only after. Regarding the third-party SDK's acquisition of your personal information, please see Appendix 1 of this policy " List of Personal Information Collection and Use by Third Parties of APP " for details .

1.2.2 Order information or transaction status

We will record your order information and transaction status. We collect the above information based on the requirements of laws and regulations and the need to protect the safety of your property and handle user disputes in accordance with the platform rules .

1.2.3Participate in activities

When you participate in our user marketing activities or promotion activities, we need you to provide certain information, which may include your name (nickname) and contact information . This information can help us announce the results of the event, conduct follow-up publicity of the event, contact you , recommend products, distribute gifts or provide services to you . If you refuse to provide such information, you may be unable to participate in corresponding activities and receive gifts, but it will not affect your use of the core business functions and services we provide . Your personal information may also be included or associated with you during course communication, interaction, and evaluation . Please be careful when disclosing sensitive personal information .

when we hold exhibitions or promotion activities with other organizations , you may be asked to provide or fill in your name (nickname) , mobile phone number, and address information . Our staff may use the information you provided after the event. Get in touch with you to understand your specific needs in order to provide you with more specific guidance and services. The information you provide may also be provided (shared) to partners. If the transfer of personal information is involved, please inquire in detail with the co-organizer of the event you are participating in.

1.2.4Feedback _ _ _

If you have any comments or suggestions while using our products and services, or you need to make complaints and feedback, you can fill in and describe your feedback and upload relevant picture information so that we can assist you in solving it quickly. Pending issues. You can choose to leave your contact information so that our customer service staff can contact you in time when they need to verify the information . Feedback information may include your name (nickname), mobile phone number, screenshots and description of the problem . If you do not provide the above information, although it will not affect your normal use of our products and services, we may not be able to provide you with the results of your complaint or consultation in a timely manner, or we may not be able to contact you to further verify your feedback or complaint. You acknowledge and agree that your calls with our customer service may be recorded. Since feedback information is provided by you on your own initiative, you are deemed to have consented to our obtaining and using such feedback information within the legal scope.

1.2.5 Questionnaire survey

In order to provide you with better services and network usage environment, we may launch questionnaire surveys to understand your usage preferences, relevant opinions, materials you are interested in, and courses you are interested in . You can choose whether to participate in the questionnaire survey, and the survey results will be used for statistical purposes only.

1.2.6 Call or exchange information

contact the customer service team through the call option of online customer service . We will record your call information, your opinions or suggestions, the name (nickname), and contact information you provided through call recording and manual entry for us to process . Disputes, resolve issues or provide you with feedback on results. If you refuse us to collect such information, it may cause the customer service team to be unable to feedback the processing results to you, but it will not affect your use of the APP's mid-level class inquiry, registration, and course learning business functions.

1.2.7 Log information _

1.2.7.1 When you use the products and services provided by the APP , the APP will collect relevant device information you use in order to provide you with continuous and stable service support, and at the same time help the APP continuously improve its products or services . , in order to provide you with the best experience when using APP products and services. We may collect your log information, including your hardware device model, screen width and height, software version information you are using, your operating system and version, your IP address, MAC address, mobile network information, your Device ID , system time, temperature sensor information.

1.2.7.2 The above information you provide and the above obtained information will continue to be authorized for us to use during the use of this service . When you cancel your account, we will stop using and anonymize the above information.

1.2.7.3 In order to improve the security of your use of the services we provide and more accurately prevent phishing website fraud and Trojan viruses, we may judge you by understanding some of your network usage habits and your commonly used software information. account risks and may record some links ( URLs) that we consider risky

1.2.8Permission information _ _ _ _

For important system permissions required in the APP (excluding permissions required by connected third parties), please click on the "APP Permission Call List " in Appendix 2 of this policy .

Please note that we will use your personal information in the following scenarios:

In order to provide you with services, improve our service quality and optimize your service experience, we will use your personal information in compliance with legal requirements or with your authorization, and mainly for the following purposes:

(1) Provide you with products and services : To provide language education services , maintain and improve these courses, and recommend and adapt relevant courses to you .

(2) We may use your personal information to verify your identity, prevent, discover, and investigate possible fraud, endanger security, illegal behavior, or violate agreements, policies or rules with us or affiliated parties, to protect you and other users. , our or our affiliates’ legitimate rights and interests.

( 3 ) When you wish to purchase sure When taking courses related to chinese , you may need to use the "payment function". You can choose the payment services provided by third-party payment institutions [ stripe, Apple Pay ] ( hereinafter collectively referred to as "payment institutions" ) that cooperate with B LINGABC. The payment function itself does not collect your personal information, but we need to share your order number and transaction amount information with these payment institutions in order for them to confirm your payment instructions and complete the payment.

( 4 ) We will collect statistics on the use of our services to show the overall usage trend of our products or services. However, these statistical information do not contain any of your personally identifiable information.

( 5 ) When you participate in a survey about our products and services , we may obtain the response information you sent to us when participating in the survey, as well as the relevant information provided when you interacted with our affiliates and partners, To optimize the quality and process of customer service.

( 6 ) When we display your personal information, we will desensitize your information using methods including content replacement and anonymization to protect the security of your information.

1.3 Other legal reasons other than consent

According to laws and regulations, your consent is not required for the collection and use of your personal information in the following situations:

（1） Necessary for the conclusion and performance of a contract to which an individual is a party, or necessary for the implementation of human resources management in accordance with labor regulations formulated in accordance with the law and collective contracts signed in accordance with the law ;

（2） Necessary to perform legal duties or legal obligations ;

（3） In response to public health emergencies, or when necessary to protect the life, health and property safety of natural persons ;

（4） To implement news reporting, public opinion supervision and other activities in the public interest, personal information shall be processed within a reasonable scope;

（5） Other situations stipulated by laws and administrative regulations.

two How to use cookies and other similar tracking technologies

2.1 What are Cookies

Cookies are small files that are stored in your computer, mobile phone or other smart terminal devices by the website server when you log in to the website or browse online content. They usually contain identifiers, site names, and some numbers and characters. When you visit the corresponding website again, the website can recognize your browser through the cookie. Cookies may store user preferences and other information.

2.2 How to use cookies

When you visit the website, we may collect your device model, operating system, device identifier, login IP address information through cookies or similar technologies, and cache your browsing information and click information to view your network environment. Through cookies, we can identify you when you visit the website , continuously optimize the user-friendliness of the website, and make adjustments to the website according to your needs. You can also change the settings of your browser so that your browser does not accept cookies from our website, but this may affect your use of some functions of the website.

With the help of cookies and other similar technologies, APP can identify whether you are one of our users every time you use our products and services , without having to log in and verify again on each page.

2.3 How to manage cookies

You can manage or delete certain categories of tracking technologies based on your preferences. Many web browsers have a “Do Not Track” function, which can issue a “Do Not Track” request to a website.

In addition to the controls we provide, you can choose to enable or disable cookies in your Internet browser. Most internet browsers also allow you to choose whether you want to disable all cookies or only third-party cookies. Most internet browsers accept cookies by default, but this can be changed. For more information, see the help menu in your Internet browser or the documentation that came with your device.

The following links provide instructions on how to control cookies in all major browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en:

IE: https://support.microsoft.com/en-us/help/260971/description-of-cookies :

Safari (desktop version): https://support.APPle.com/kb/PH5042?locale=en_US :

Safari (mobile version): https://support.APPle.com/en-us/HT201265 :

Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies :

Opera: https://www.opera.com/zh-cn/help

If you use another browser, please refer to the documentation provided by your browser manufacturer.

2.4 Use of network Beacon and similar technologies

In addition to Cookies , we also use network Beacon and other similar technologies on our website . Our web pages often contain some electronic images (called " single-pixel " GIF files or " web beacons" ).

we use network Beacon are:

2.4.1 By using network Beacon on the website , count the number of user visits, and identify registered users by accessing cookies.

2.4.2 Provide you with personalized services through the obtained Cookies information.

In the APP, you can delete the existing tracking technology by clearing the cache, or you can withdraw the authorization to use the storage permission of the APP through the phone's own settings to refuse the use of tracking technology.

Please be aware that if you refuse to use or clear existing tracking technologies, you will need to personally change your user settings every time you visit, and we may not be able to provide you with a better user experience, and some services may not function properly.

three How to entrust the processing, sharing, transfer and public disclosure of your personal information

3.1Share _ _

share it with companies, organizations and individuals other than service providers . Except for the following situations, we will not share your personal information with any third party without your consent:

（1） your explicit consent: After obtaining your explicit consent, we will share your personal information with other third parties ;

（2） In accordance with the provisions of laws and regulations or the requirements or authorization of competent authorities such as judicial agencies ;

（3） To fulfill the purposes described in the "Use of Personal Information" section, or to perform our obligations and exercise our rights in the User Agreement or this Privacy Policy, to our affiliates, partners or those who perform a function on our behalf. Third parties (for example : educational institution partners, communication service providers who send push notifications on our behalf , payment institutions that process bank cards, third-party verification agencies) share your personal information ; we will strictly require cooperation before sharing your personal information Partners bear information protection obligations and responsibilities. To this end, we will require partners to sign a data processing agreement before cooperation or list the terms related to data protection in the cooperation agreement signed by both parties. The agreement strictly stipulates the partner's confidentiality obligations for user information, including the storage, use and transfer of information, etc., which must meet our control requirements and accept our review, supervision and audit. In the event of any violation, we will require the other party to bear corresponding liabilities. legal liability.

about the SDK (shared) connected to the APP ,

Appendix 1 of this policy " List of Personal Information Collection and Use by Third Parties of APP " .

（4） In some cases, sharing your information is necessary to provide the services you need or to handle disputes or controversies between you and others ;

（5） We conduct joint marketing activities with third parties, and we may share with them the personal information generated during the activity and necessary to complete the activity, such as the number of users participating in the activity, the list of winners, and the contact information of the winners, so that the third party can promptly provide you with Give out prizes. Shared with authorized partners only to achieve the purposes stated in this policy, some of our services will be provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and we will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose.

personal information with any third party without your consent .

3.2Transfer _ _

In accordance with legal requirements and reasonable business practices, when we plan to merge with or be acquired by other companies or conduct other capital market activities, and when we need to accept due diligence from other entities under other circumstances, we will handle it in the manner required by law. , if we need to provide your information to necessary entities, we will require them to take reasonable confidentiality measures for your personal information by signing confidentiality agreements with these entities.

As our business develops, we and our affiliates may engage in mergers, acquisitions, asset transfers or similar transactions, and your personal information may be transferred as part of such transactions.

3.3 Public disclosure

We will only publicly disclose your personal information under the following circumstances and taking security measures that comply with industry standards:

( 1) Based on your needs, the personal information specified by you will be disclosed in the disclosure method you expressly agree to.

( 2 ) In order to safeguard the legitimate rights and interests of us and our affiliates or other users, when assisting in handling transaction disputes or controversies related to you , we provide your transaction counterparties or interested third parties with solutions to resolve transaction disputes or disputes. Required information .

( 3) According to legal provisions, we will provide necessary personal information obtained by criminal investigation agencies in accordance with legal procedures in order to investigate crimes; or necessary personal information obtained by administrative agencies and judicial agencies in accordance with legal procedures and with your authorization and consent. Provide your relevant information; we will not provide your personal information to any third party organization or individual without going through legal procedures or without your consent.

4. How to give you the right to manage your personal information

In accordance with applicable laws and regulations, we will take appropriate technical means to ensure your right to access, update, correct or delete your personal information. If we are unable to meet your request due to legal or regulatory requirements, we will provide you with a reasonable explanation. You have the following rights regarding your personal information:

4.1Access rights _

You have the right to access the information of your bound students in the APP and the course information, order information, and payment information associated with the bound students . When you log in to the APP , you can access the student information and order information we have bound to you under the "My" function page .

4.2Right of correction

You can modify your student information (name, nickname, mobile phone number, avatar, etc.) in the APP account . You also have the right to contact us through the methods described in Article 8 of this policy to request that we correct or update incorrect or incomplete information.

4.3Right of withdrawal

Please be aware that in order for you to use our products and services normally, you need to provide us with some basic personal information. If you wish to withdraw the relevant permissions that you previously agreed to open , we will protect your right to withdraw your consent in the following ways:

（1） You can use the device's settings function to revoke the previously agreed-on related device permissions by turning off the corresponding device permissions (including location, address book, photos, microphone, camera, notifications, etc. ) . Users can go to "Mobile Settings → Permissions" "Close the relevant privacy authorization, specifically:

Android phone: Settings → Application → Permissions → APP ;

IOS mobile phone: Settings → Privacy → Permissions →APP;

（2） To withdraw your consent to this policy and user agreement, you can revoke your authorization for the APP to collect your personal information by canceling your account.

In the APP, you can contact customer service to cancel your account through the method listed in " My → Settings → Cancel Account ".

If you are unable to manage the above personal information, you can contact our customer service at any time through the method described in Article 8 of this policy to solve the problem.

4.4 Right to deletion

When you no longer use our products or services , or we collect, use, or share your personal information with others in violation of laws and regulations or our agreement with you, you have the right to delete the information you provided . You can contact customer service through the method described in Article 8 of this policy to submit a deletion request. Subject to meeting the minimum retention period required by this policy, the user agreement, and laws and regulations, we will delete or anonymize your personal information, but this may result in us being unable to provide you with corresponding services.

When we decide to respond to your deletion request, we will delete your information from BLINGABC servers as quickly as possible . However, due to the requirements of regulatory agencies to combat crime and maintain national security, we will only record and save your communication information, but we will not make any use of it. Please be aware that we may not delete the information you need to delete from the backup system immediately, but we will delete it when the backup system is updated.

4.5Right of cancellation

Except for the following circumstances, you can delete personal information or cancel your account on your own:

( 1) In order to cooperate with the national security agencies in investigating criminal activities that occur when users use the application , and to better protect the lives and property of other users , your personal information and account will be saved .

( 2) To comply with laws, regulations, policies, etc. regarding the retention period of personal information .

( 3) You can contact our customer service to cancel the previously registered account through the method listed in "My → Settings → Cancel Account" in the APP . We will delete the account within the time prescribed by law . After choosing to cancel your account , all information in your account will be cleared and cannot be recovered. We will no longer collect, use or share personal information associated with this account .

4.6 Obtain a copy of your personal information

You can send your written request for us to provide a copy of your personal information to blingabc@xdf.cn , and we will provide you with a copy of the following types of personal information based on your written request: You provide your mobile phone number and account information when registering , course information, order information, payment information.

4.7 In response to your above request

delete your personal information through the above methods , or you need to access, correct or delete other personal information generated when you use our services, or you believe that we have violated any laws or regulations or are related to you. To agree on the collection or use of personal information, you can contact us through the customer service hotline: Please contact us through the contact information provided in Article 8 of this policy .

For security reasons, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will process it within fifteen working days. We do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the circumstances. For requests that are unreasonably repetitive, require excessive technical means ( requiring the development of new systems or fundamentally change existing practices ) , pose risks to the legitimate rights and interests of others, or are difficult to implement ( for example, involving information stored on backup tapes ) , we may will be rejected.

to respond to your request under the following circumstances :

( 1) Relevant to the personal information controller’s performance of obligations stipulated in laws and regulations;

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

( 3) Directly related to criminal investigation, prosecution, trial and execution of judgments;

( 4) The personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abused rights;

To protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals but it is difficult to obtain the consent of the individual;

( 5) Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;

( 6) Involving trade secrets.

How we store your personal information

( 1) In accordance with relevant laws and regulations, we will store your personal information collected and generated during operations in Alibaba Cloud servers. If the service involves cross-border business and we need to transfer relevant personal information collected within the country to overseas institutions, we will implement it in accordance with laws, regulations and relevant regulatory authorities , and explain to you the purpose of transferring personal information overseas and the type of personal information involved. With your consent, and through effective measures such as signing agreements and on-site inspections, we require overseas institutions to keep your personal information obtained confidential.

( 2) We will continue to save your personal information while you are using the products and services .

( 3) The information and materials we collect about you will be stored on our or our affiliates' servers. At the same time, your personal information will only be retained for the period necessary to achieve the purposes stated in this policy.

If we terminate our services or operations, we will notify you at least thirty days in advance and delete or anonymize your personal information after terminating the services or operations.

6. How we protect your personal information

We attach great importance to the security of personal information and take all reasonable and feasible measures to protect your personal information:

6.1Information security organization and management measures

6.1.1 In accordance with relevant regulatory requirements, we have appointed a person in charge of personal information protection and a personal information protection work organization. We have also established relevant internal control management processes, based on the principle of minimum authorization, strictly set information access permissions for staff who may have access to your personal information, and control the scope of knowledge of personal information.

6.1.2 Regarding the internal management system, we have established a data security and related security management system to ensure that the processing of your personal information meets the security requirements of laws and regulations in the collection, transmission, use, storage, transfer, destruction and other aspects.

6.1.3 We organize employees to participate in security and privacy protection-related training and require them to complete required assessments to enhance employees' awareness of the importance of protecting personal information.

6.1.4 We have formulated relevant emergency plans for information security incidents, and regularly organize relevant internal personnel to conduct emergency response training and emergency drills so that they can master their job responsibilities and emergency response strategies and procedures.

6.2 Data security technical measures

6.2.1 In terms of secure data transmission, we use SSL encrypted transmission technology to protect the security of data during its transmission, and use appropriate protection mechanisms to prevent data from being maliciously attacked; in addition, we will also take measures to protect sensitive information. Security protection measures such as AES encryption algorithm or SHA256 hash algorithm.

6.2.2 We have adopted a data classification and grading system based on the sensitivity of the data and the type of data , and based on the classification and grading results, we have implemented various permission restrictions such as user permissions, usage scenario permissions, use authorization permissions, and hierarchical approval mechanisms; for When the storage period of the stored personal information expires , we will delete your personal information.

6.2.2 In terms of security control of data access and use, we have implemented a strict data permission control mechanism, adopted multi-identity authentication technology, and monitored the behavior of processing your personal information to avoid illegal access and unauthorized data. use. We also monitor the entire process of the data life cycle to prevent your personal information from unauthorized access, public disclosure, use, modification, man-made or accidental damage or loss, etc.

6.2.3 For staff who need to access personal information, we will require them to be approved by the person in charge of personal information protection or their authorized managers, record the access situation, and take technical measures to avoid illegal access, modification, copying, and downloading of personal information. .

6.2.4 We also conduct regular information security audits. We use the audit mechanism to comprehensively verify and control the effectiveness of the privacy policy and related procedures as well as data security .

6.3 Handling of security incidents

6.3.1 If a personal information security incident unfortunately occurs, we will immediately activate the emergency plan, take remedial measures, record the content of the incident, and report it in a timely manner in accordance with the "Cybersecurity Incident Emergency Plan" and other relevant regulations. If it may cause serious damage to your legitimate rights and interests, such as the leakage of sensitive personal information, we will inform you of the basic situation of the security incident and its possible impact, the handling measures we have taken or will take, and what you can do. Selected suggestions for preventing and reducing risks, the remedial measures we provide you, and the contact information of the person in charge of personal information protection and the personal information protection agency, etc. We will promptly notify you of the above events by email, letter, phone call or push notification. If it is difficult to inform you one by one, we will issue warning announcements in a reasonable and effective manner.

6.3.2 Please know and understand that the Internet is not an absolutely secure environment. We strongly recommend that you use a safe method and use complex passwords to help us ensure the security of your account. If you find that your personal information has been leaked, especially your account or password, please contact us immediately according to the contact information provided in Article 8 of this policy so that we can take appropriate measures to protect the security of your information.

6.4 Guarantees of Cooperation Agreement Terms

Before we indirectly collect your personal information from a third party, we will clearly require the third party in writing (such as a cooperation agreement, letter of commitment) to collect and process your personal information after obtaining your express consent, and require the third party to Commitment to the legality and compliance of the source of personal information shall be made in the form of a written agreement . If a third party violates the law, we will clearly require the other party to bear corresponding legal responsibilities.

seven How to update this policy

8.1 We reserve the right to update or modify this policy. We will post any changes to this policy on this page. However, we will not reduce your rights under this policy without your explicit consent. Such changes form part of this policy.

8.2 Please read the changed content of this policy carefully. If you do not agree with this policy, or have objections to the modified or updated content of this policy, you can choose to stop using our products and services or cancel your account. However, please be aware that your behaviors and activities before your account is canceled and before you stop using this service are still subject to this policy.

8.3 If there are major or substantive changes, we will notify you in a prominent manner based on the specific circumstances. Situations of major and substantive changes include but are not limited to the following situations:

8.3.1 Our service model has undergone significant changes. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;

8.3.2 There are significant changes in your rights to participate in the processing of personal information and how you exercise them;

8.3.3 We have undergone major changes in ownership structure, organizational structure and other aspects. Such as business adjustment , mergers and acquisitions , bankruptcy, cessation of operations, etc .;

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

8.3.5 When our responsible department, contact information and complaint channels for handling personal information security change;

8.3.6 When the personal information security impact assessment report indicates that there is a high risk.

8Contact us

Company name: BLINGABC

Registered address: 5549 Brooks St. Montclair CA 91763

1. If you have any questions, comments or suggestions about the content of this policy or find that personal information has been leaked, please contact our dedicated personal information protection department through the following methods.

l Email: service@blingo.vip

2. We will handle your questions, complaints and suggestions within up to fifteen days.

3. If you are not satisfied with our response, especially if you believe that our personal information processing behavior has harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with the court with jurisdiction over the defendant's domicile.

Nine Supplementary Provisions

10.1 If any provision of this Policy is held or adjudged by any court of competent jurisdiction to be invalid, that provision will be removed from this Policy, but the invalidity of such provision will not affect the validity of the remaining provisions of this Policy. The remaining provisions of this policy will continue to apply.

10.2 The titles of this Policy are designed for ease of reading only and do not affect the meaning or interpretation of any provision of this Policy.

ten Keyword definition

11.1 Our products and services: refer to the following products and services provided to you by B LINGABC: (1) Products and services provided through the APP ; ( 2 ) Other products and services we provide you from time to time.

11.2 APP : refers to " Sure Chinese " developed by B LINGABC and its various versions. Users can query educational information through the APP; search for courses and services provided by B LINGABC , register for classes , reschedule, and refund; purchase Take online courses.

11.3 Affiliated companies: refers to B LINGABC's subsidiaries or other affiliated enterprises, and the company/enterprise currently or in the future has a relationship with B LINGABC that controls, is controlled, or is under the common control of other enterprises.

11.5 User or you: refers to the user who uses B LINGABC products and services

11.6 Personal information: refers to various information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information. Personal information includes basic personal information, personal identity information, personal biometric information, online identity information, personal health and physiological information, personal education and work information, personal property information, personal communication information, contact information, personal online records, and personal common use Device information, personal location information, etc. For the avoidance of doubt, personal information includes, but is not limited to, sensitive personal information.

11.7 Sensitive personal information: refers to personal information that, once leaked or illegally used, may easily cause the dignity of a natural person to be infringed or the personal and property safety to be endangered, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts, etc. information.

11.8 De-identification: means the process by which personal information is processed so that it cannot be identified as a specific natural person without the aid of additional information.

11.9 Deletion: refers to the act of removing personal information from systems involved in realizing daily business functions, so that it remains in a state that cannot be retrieved or accessed.

11.10 Anonymization: refers to the process in which personal information is processed so that a specific natural person cannot be identified and cannot be recovered.

11.11 Device: refers to the device that can be used to access our products and services, such as desktop computers, laptops, tablets, smartphones, etc.

Attachment 1: List of third parties collecting and using personal information

We will conduct strict security monitoring of the SDK used by our partners to obtain personal information to protect the security of your information .

Attachment 2 : APP permission call list

The APP may call some of your device permissions. The following are the business functions corresponding to the permissions , the purpose of calling the permissions, and the information we ask you before calling the permissions.

（1） IOS system permission call

(2) Android system permission call

Attachment 3: List of personal information collected and used by APP