AI Smart Classroom Privacy Policy

I. Introduction

Beijing Boya Hanrong Education Technology Co., Ltd. (hereinafter referred to as "we" or "our") respects and protects users' privacy. We have established this Privacy Agreement (hereinafter referred to as "this Agreement") to explain how we collect, use, store, share and protect your personal information when you use our AI Smart Classroom products and services (hereinafter referred to as "the Products and Services"). Please carefully read and understand all contents of this Agreement before using our Products and Services. If you disagree with any content of this Agreement, you should immediately stop using our Products and Services. If you use our Products and Services, it means you agree that we will process your personal information in accordance with this Agreement.

II. Information We Collect

We collect two types of information: information you actively provide and information we automatically collect.

2.1 Information You Actively Provide

• Account Information: When you register or log in to our Products and Services, we will require you to provide your name, phone number, email and other information to create an account, verify your identity, and send you important notifications.

• Learning Information: When you use our Products and Services for learning activities, we will record your learning progress, grades, wrong questions, notes, feedback and other information to provide you with personalized learning services and help improve your learning effectiveness.

• Communication Information: When you use our Products and Services to communicate with us or other users, we will collect your chat records, voice, video and other information to provide you with communication services and maintain and improve the quality of our Products and Services.

• Payment Information: When you make purchases through our Products and Services, we will collect your order information, payment method, payment status and other information to provide you with payment services, process your orders, and protect your legitimate rights and interests.

2.2 Information We Automatically Collect

• Device Information: When you use our Products and Services, we will automatically collect your device type, device identifier, operating system version, IP address, network type and other information to provide you with compatible products and services, ensure the secure and stable operation of our Products and Services, and optimize your user experience.

• Log Information: When you use our Products and Services, we will automatically record your operation logs, including access time, duration, pages visited, error messages, etc., to provide you with products and services, analyze and improve the quality of our Products and Services, and prevent and handle abnormal situations.

Cookies and Similar Technologies: We use cookies and similar technologies to collect information about your browser type, language settings, access sources, etc., to provide you with more convenient and personalized products and services, as well as for data analysis and statistics. You can refuse or manage cookies through browser settings, but please note that if you disable cookies, you may not be able to use some or all features of our Products and Services.

III. How We Use Information

We use the information we collect for the following purposes:

• To provide you with our Products and Services, including account registration, login, verification, learning, communication, payment and other functions, as well as continuously improving and optimizing the quality and performance of our Products and Services.

• To provide you with personalized products and services, including recommending suitable courses, content, activities based on your learning situation and preferences, and improving our products and services based on your feedback and suggestions.

• To provide customer support, including responding to your inquiries, complaints, suggestions, and handling your orders, refunds, disputes, etc.

• To protect your and our legitimate rights and interests, including maintaining the secure and stable operation of our Products and Services, preventing and handling fraud, illegal activities, infringement, and complying with and enforcing applicable laws, regulations, legal procedures or government requirements.

IV. Information We Share

We will not sell, transfer, or disclose the information we collect to any third party, except in the following circumstances:

• With your consent or authorization. We will share your information with third parties you specify or provide you with third-party products and services you request after obtaining your explicit consent or authorization.

• Sharing with affiliated companies. We may share your information with our affiliated companies to provide you with better products and services, but we will ensure they comply with this Agreement and take appropriate protective measures.

• Sharing with partners. We may share your information with our partners to provide you with better quality products and services, but we will only share necessary information, and we will sign strict confidentiality agreements with partners, requiring them to comply with this Agreement and take appropriate protective measures.

• Sharing based on legal regulations or legitimate interests. When necessary, we may share your information with relevant third parties based on compliance with and enforcement of applicable laws, regulations, legal procedures or government requirements, or to protect the legitimate interests of us or our users, partners, or the public.

V. How We Protect Information

We take your information security very seriously and have adopted various technical and administrative measures to protect your information from loss, leakage, misuse, unauthorized access, disclosure, alteration, or destruction. These measures include:

• Using encryption technology for transmitting and storing your information;

• Using firewalls, intrusion detection, and other technologies to prevent illegal access or attacks on your information;

• Limiting our employees' and partners' access to your information and requiring them to comply with strict confidentiality obligations;

• Regularly reviewing our collection, storage, and processing practices to prevent unauthorized access to or use of your information.

Although we have taken reasonable security measures, please understand that due to the open nature of the internet, we cannot guarantee 100% security of your information. Therefore, we recommend you take active measures to protect your information, such as regularly changing your password, not disclosing your account and password to others, and using secure network environments.

VI. How We Store Information

We store your information in accordance with this Agreement and applicable laws and regulations. Generally, we will only store your information during the period we provide you with the Products and Services. If you deactivate or delete your account, or we terminate providing you with the Products and Services, we will delete or anonymize your information within a reasonable period, unless otherwise required by laws and regulations.

We currently store your information within the People's Republic of China. If we need to transfer your information across borders, we will comply with relevant laws and regulations and take appropriate protective measures, such as signing data transfer agreements, to ensure the security of your information.

VII. How You Manage Your Information

We respect your rights regarding your information and provide you with the following ways to manage your information:

• Access and update. You can access and update your account information, learning information, communication information, etc., through the relevant functions of our Products and Services. If you cannot access or update your information through these functions, you can contact our customer service, and we will assist you with access or updates within a reasonable period.

Deletion and deactivation. You can delete or deactivate your account and delete some or all of your information through the relevant functions of our Products and Services. If you cannot delete or deactivate your account or delete your information through these functions, you can contact our customer service, and we will assist you with deletion or deactivation within a reasonable period. Please note that if you delete or deactivate your account or delete your information, you may not be able to continue using our Products and Services or enjoy some or all features. Additionally, due to the technical nature of the internet, deleted or deactivated information may not be immediately cleared from our backup systems; we will complete the clearing work within a reasonable period.

Withdrawal of consent or authorization. You can withdraw your previous consent or authorization through the relevant functions of our Products and Services or by contacting our customer service to stop us from continuing to collect, use, or share your information. Please note that if you withdraw your consent or authorization, you may not be able to continue using our Products and Services or enjoy some or all features.

• Objections or complaints. If you have any objections or complaints about how we handle your information, you can contact our customer service, and we will respond to your objections or complaints and try to resolve your issues within a reasonable period. You can also raise your objections or complaints to relevant regulatory authorities or courts in your jurisdiction.

VIII. Changes to This Agreement

We may modify and update this Agreement based on our business development and changes in laws and regulations. If we make any substantial changes to this Agreement, we will notify you of the changes through prominent placement in our Products and Services or through SMS, email, or other means, and ask you to read and confirm the Agreement again. If you disagree with the modified Agreement, you should immediately stop using our Products and Services. If you continue to use our Products and Services, it means you agree to the modified Agreement.

IX. Protection of Minors

We take the protection of minors' personal information very seriously.

According to relevant laws and regulations, if you are under 18 years old, you should obtain consent from your parents or legal guardians before use.

We have products or services specifically designed for children under 14 years old, product or service sections specifically targeting children, or products or services that require users to input birthday, age, or other information that can identify user age.

According to relevant laws and regulations, if you are a child under 14 years old, you should obtain consent from your parents or legal guardians before using related products or services, and have your parents or legal guardians help you complete the product or service registration process to use our products or services.

If you are a child's guardian, when helping the child complete product or service registration and use, you should carefully read this policy and decide whether to agree to this policy and help the child register and use, so that the child can use our products or services.

If you have any questions or rights requests regarding the personal information protection of the child under your guardianship, please contact us through the contact information disclosed in Section X. We will process and respond to you within a reasonable time.

X. Artificial Intelligence

In our products and services, we utilize the powerful capabilities of artificial intelligence (AI), including integrated generative AI functions. Our use of AI is governed by AI principles and responsible AI standards, and the collection and use of personal data when deploying AI functions is consistent with the commitments outlined in this Privacy Statement.

XI. Contact Us

If you have any questions, comments, or suggestions about this Agreement or how we handle your information, you can contact us through the following means:

• Customer Service Phone: 13520965293

• Customer Service Email: service@edu-by.com

• Mailing Address: Building B, No. 18 Zhongguancun Street, Haidian District, Beijing, Beijing Boya Hanrong Education Technology Co., Ltd.

We will respond and process your inquiry as soon as possible after receiving your contact.

XII. Other

The establishment, effectiveness, performance, interpretation, and dispute resolution of this Agreement shall be governed by the laws of the People's Republic of China. If any provision of this Agreement is deemed invalid or unenforceable, that provision shall be deemed severable and shall not affect the validity of other provisions.

The headings in this Agreement are for convenience of reading only and do not affect the meaning or interpretation of this Agreement.

The copyright of this Agreement belongs to Beijing Boya Hanrong Education Technology Co., Ltd. Without our written permission, no one may reproduce, distribute, or use the contents of this Agreement in any form.

This Agreement is effective from December 18, 2023.

Beijing Boya Hanrong Education Technology Co., Ltd.