Hula English Privacy Policy
Release Date: September 1 , 2025
Effective Date: September 1 , 2025
the Hula English products and/or services of Beijing Mengbao Technology Co., Ltd. (hereinafter referred to as “we”). The Hula English platform includes the Hula English mobile app and the Hula English mini-program. When you visit our platform and use our products and/or services, we may collect and use your information. We are fully aware of the importance of personal information to you, and therefore, we attach great importance to protecting your privacy and personal information. We will treat and handle the contents of this Hula English Privacy Policy (including Appendix 1, hereinafter referred to as “this Policy”) with the utmost care and diligence, and will adhere to the following principles to protect your personal information: consistency of rights and responsibilities, clear purpose, opt-in consent, minimum sufficiency, openness and transparency, ensuring security, subject participation, and openness and transparency. This Policy is closely related to your use of our products and/or services. When you download, install, launch, browse, register, log in, or use our products and/or services (collectively, “using our products and/or services” or “using products and/or services”), we will process and protect your personal information in accordance with this Policy. Therefore, we encourage you to carefully read and fully understand this Policy and, if necessary, make the choices you deem appropriate based on its guidance. You should carefully read and fully understand this ” Hula English Privacy Policy” before deciding whether to agree to its contents and use our products and/or services. Hula English has highlighted in bold or other reasonable means the clauses in the agreement that may be material to your rights and interests. If you disagree with this Policy, it may result in our products and/or services not functioning properly or failing to achieve the desired service results. You should immediately cease accessing/using our products and/or services. Your use or continued use of our products and/or services constitutes your full understanding and agreement to this ” Hula English Privacy Policy” (including any updated versions). To facilitate your understanding, this policy will be presented in a simple and easy-to-understand manner. For any technical terms involved, we have detailed these terms in Chapter 1, “Definitions and Glossary.” If you have any questions or other related issues while reading this ” Hula English Privacy Policy,” we provide you with multiple feedback channels. Please see Chapter 9, “How to Contact Us,” for details. We will respond to you as soon as possible. Please note that this Privacy Policy does not apply to services provided to you by other third parties (including any third-party applications, websites, products, services, etc., such as third-party payment channels). Personal information you provide to third parties is not subject to this Privacy Policy. Unless otherwise expressly provided by law, we assume no responsibility for any third party’s collection, storage, and use of your personal information. This Hula English Privacy Policy will help you understand the following: 1. Definitions and Glossary 2. How we collect and use your device information 3. How we use cookies and similar technologies 4. How we share, transfer, and publicly disclose your personal information 5. Your rights to control your personal information 6. How we store and protect your personal information 7. Protection of minors 8. Updates to this Hula English Privacy Policy 9. How to contact us 10. Other 1. Definitions and Glossary Personal information (from GB/T 35273-2017 “Information Security Technology Personal Information Security Specification”) refers to any information recorded electronically or otherwise that can, alone or in combination with other information, identify a specific natural person or reflect the activities of a specific natural person. The personal information referred to in this Privacy Policy includes basic personal information (including name, birthday, gender, address, telephone number, and email address). The specific types of personal information we collect are described below. Sensitive personal information (from GB/T 35273-2017 “Information Security Technology Personal Information Security Specification”) refers to personal information that, if leaked, illegally provided, or misused, could endanger personal and property safety, damage personal reputation, physical or mental health, or lead to discriminatory treatment. The sensitive personal information covered in this Privacy Policy includes your financial information (including bank account numbers, identification information (passwords), financial information (including fund amounts, earnings, and balances), transaction and spending records, transaction records, virtual currency (Mengguo), virtual transactions, redemption codes, and other virtual property information), personal biometric information (including fingerprints and facial features), personal identification information (including ID card information), online identification information (including system accounts, email addresses, and passwords, passcodes, password protection answers, and user digital certificates related to the foregoing), other information (including personal phone numbers, precise location information, delivery addresses, and web browsing history), and children’s personal information. You agree that your sensitive personal information will be processed for the purposes and in the manner described in this ” Hula English Privacy Policy.” The specific types of sensitive personal information we collect are described below. Sensitive personal information may have a greater impact on your personal rights and interests than other personal information. We kindly remind you to carefully consider before providing us with your sensitive personal information. Children: refers to minors under the age of fourteen. (From the “Regulations on the Online Protection of Children’s Personal Information”) Anonymization: refers to the process of technically processing personal information so that the subject of the personal information cannot be identified, and the processed information cannot be restored. (From GB/T35273-2017 “Information Security Technology Personal Information Security Specification”) De-identification: refers to the process of technically processing personal information so that the subject of the personal information cannot be identified without the aid of additional information. (From GB/T35273-2017 “Information Security Technology Personal Information Security Specification”) Deletion: refers to the act of removing personal information from systems involved in implementing daily business functions, rendering it inaccessible and unretrievable. (From GB/T35273-2017 “Information Security Technology Personal Information Security Specification”) 2. How We Collect and Use Your Device Information: When you use our products and/or services, we need/may need to collect and use some of your personal information. We collect and use three types of your personal information: First, information necessary for the core business functions of our products and services. This information is essential for the normal operation of our products and services, and you must authorize us to collect it. If you refuse to provide it, you will not be able to use our products and/or services properly. Second, information necessary for the additional business functions of our products and services. This information is required for non-core business functions, and you can choose whether to authorize us to collect it. If you refuse to provide it, the additional business functions will not be able to function or achieve the intended results, but it will not affect your normal use of the core business functions. Third, for purposes such as statistical analysis, our products and services may integrate third-party SDKs or other similar applications. To protect your information, we have entered into strict data security and confidentiality obligations with third-party SDK and other similar application service providers, and these companies will strictly abide by our data privacy and security requirements. You understand and agree that we want to provide you with perfect products and services, so we will continue to improve our products and services, including technology. This means that we may frequently launch new business features, which may require the collection of new personal information or changes in the purpose or method of using personal information. If a function or product/service that requires the collection of your personal information is not described in this ” Hula English Privacy Policy”, we will separately explain to you the purpose, content, use and scope of the information collection through updating this policy, page prompts, pop-ups, website announcements, etc., and provide you with a way to choose your consent independently, and collect the information only after obtaining your explicit consent. During this process, if you have any questions about related matters, you can contact us through the methods provided at the end of this article, and we will provide you with answers as soon as possible. Specific business function scenarios include: (1) User experience and functional consistency Our products and services provide you with video, audio display and playback services. In this process, in order to ensure the normal operation of the software and services, and to determine your unique identity, as well as to improve your user experience, we need to collect some of your information, including the following personal information: device model, device name, sensor information, accelerometer, running process information, browser type and settings, language settings, operating system and application version, method of accessing the network, network quality data, mobile network information (including operator name), product version number, log information (such as operation logs, service logs). At the same time, in order to collect the above basic personal device information, we will apply for permission to access your device information. We collect this information to confirm your identity so that we can provide you with consistent services. If you refuse to authorize the provision, you will not be able to enjoy consistent services, but it will not affect your normal use of other functions.
Sensitive personal information (from GB/T 35273-2020 “Information Security Technology Personal Information Security Specification”) refers to personal information that, if leaked, illegally provided, or misused, could endanger personal and property safety, damage personal reputation, physical or mental health, or lead to discriminatory treatment. The sensitive personal information covered in this Privacy Policy includes your financial information (including bank account numbers, identification information (passwords), financial information (including fund amounts, income, and balances), transaction and spending records, transaction records, virtual currency (such as Dot Coin), virtual transactions, redemption codes, and other virtual property information), personal biometric information (including fingerprints and facial features), personal identification information (including ID card information), online identification information (including system accounts, email addresses, and passwords, passwords, password protection answers, and user digital certificates related to the aforementioned), other information (including contact information, personal phone numbers, delivery addresses, and web browsing history), and children’s personal information. You agree that your sensitive personal information will be processed for the purposes and in the manner described in this ” Hula English Privacy Policy.” The specific types of sensitive personal information we collect are described below. Compared with other personal information, personal sensitive information may have a greater impact on your personal rights and interests. We hereby kindly remind you to consider carefully before providing us with your personal sensitive information. Children: refers to minors under the age of fourteen. (From the “Regulations on the Protection of Children’s Personal Information on the Internet”) Anonymization: refers to the process of technically processing personal information so that the subject of personal information cannot be identified and the processed information cannot be restored. (From GB/T 35273-2020 “Information Security Technology Personal Information Security Specification”) De-identification: refers to the process of technically processing personal information so that the subject of personal information cannot be identified without the help of additional information. (From GB/T 35273-2020 “Information Security Technology Personal Information Security Specification”) Deletion: refers to the act of removing personal information from systems involved in implementing daily business functions, so that it remains in an inaccessible state. (From GB/T 35273-2020 “Information Security Technology Personal Information Security Specification”)
(2) Search Function: When you use the search function, we need to collect some of your information, including the following personal information: search terms (including voice information), browsing history and time, search duration, and number of interactions with them. We collect this information to provide you with the content you need and to improve our products and services. When you use business functions such as voice search, we will need to obtain your device microphone permission and collect your voice information and voice interaction information (personal information). Refusing to provide this permission will only prevent you from using this function and will not affect your normal use of other features of the products and/or services. Microphone permission is a setting on your device that can be managed through the device settings page. You can also enable/disable this permission at any time through the relevant function settings on the product. By enabling this permission, you authorize us to access, obtain, collect, and use your personal information. However, if you cancel this authorization, we will no longer collect this information and will no longer be able to provide you with the corresponding services mentioned above. However, unless you delete your personal information in accordance with legal requirements, your cancellation will not affect our processing and storage of personal information based on your previous authorization. (III) Registration and Membership Features 1. When you register an account on our platform, you will need to provide us with certain information that identifies you, either alone or in combination, including: mobile phone number, verification code matching results, nickname, baby’s gender, baby’s birthday, profile picture, etc., and create an account UID and password. We collect this information to complete the registration (membership) process, provide you with ongoing and stable registration (membership) services, and protect the security of your registered (membership) account. You should be aware that your mobile phone number and verification code matching results constitute sensitive personal information. We collect this information to comply with relevant laws and regulations. Refusal to provide this information may result in you being unable to use this feature. Please consider carefully before providing this information. 2. After successfully registering an account, you can use it to log in to our platform. When logging in, you will need to provide us with your account information. If you do not provide this information, you will not be able to log in. You may also fill in or supplement your gender, nickname, profile picture, birthday, and personal signature information during registration or subsequent use. Failure to fill in, or subsequent deletion or modification of this information will not affect the normal use of registration and membership features. 3. It should be noted that some of our platforms allow you to log in using a third-party platform account (e.g., WeChat). If you log in using a third-party platform account, we will obtain relevant information related to that third-party account (including username, nickname, and profile picture, subject to your authorization) and authentication information (personal sensitive information) based on your authorization. We collect this information to provide you with account login services, protect your account security, and mitigate security risks. If you refuse to authorize such information, you will not be able to log in to our platform using your third-party platform account, but this will not affect the normal use of other products and services we provide you. 4. You acknowledge and agree that, in the course of operations, we may send various notifications to one or more of the contact information (e.g., email address, phone number, fax number, address ) you provide during the use of our products and/or services, for purposes such as user notifications, identity verification, and security verification. Furthermore, we may also use the mobile phone number and email address collected during the aforementioned process to provide you with commercial information about business activities, such as through text messages, phone calls, or emails. However, please be assured that if you do not wish to receive such commercial information, you may unsubscribe using the unsubscribe methods provided in the text messages or emails, or you may contact Hula English directly to unsubscribe. (IV) Video Sharing Based on Device Album Permissions When you use the video sharing service, we will need to obtain your device album permissions and collect the image, text, and video content information (personal information) you provide. Refusal to provide this permission will only prevent you from using this feature, but will not affect your ability to use other features of the products and/or services. Album permissions are a setting on your device that you can manage through your device settings. You can also enable/disable this permission at any time through the relevant product settings. When you enable this permission, it is deemed that you authorize us to access, obtain, collect, and use your personal information; when you cancel this authorization, we will no longer collect this information and will no longer be able to provide you with the above-mentioned corresponding services; but unless you delete your personal information in accordance with the law, your cancellation will not affect our processing and storage of personal information based on your previous authorization. (V) Video sharing, authorized device login, and eye protection mode functions based on device camera permissions When you use video sharing and authorized device login business functions, we will need to obtain your device camera permissions and collect the pictures and video information (personal information) you provide. If you refuse to provide it, it will only prevent you from using this function, but it will not affect your normal use of other functions of the product and/or service. Camera permissions are a setting on your device, which you can manage through the device settings page. At the same time, you can also enable/cancel this permission at any time through the relevant function settings on the product. By enabling this permission, you authorize us to access, obtain, collect, and use your personal information. If you cancel this authorization, we will no longer collect this information and will no longer be able to provide you with the services described above. However, unless you delete your personal information in accordance with legal requirements, your cancellation will not affect our processing and storage of your personal information based on your prior authorization. It is important to note that to remind you to maintain good eye habits and protect your eyes when using our products, some of our products offer eye comfort mode. When you authorize eye comfort mode, it uses TrueDepth APIs to obtain information about the distance between your face and the device screen. This information will not be stored or shared with third parties and will only be used for the aforementioned distance detection and notifications (for example, if the distance between your face and the device screen is less than 40cm for more than 5 seconds, video playback will automatically pause and be masked, with text and voice prompts appearing). Declining eye comfort mode will only disable you from using this feature and will not affect your ability to use other features of the product and/or service. The eye protection mode is turned off by default when you first download and launch the product. You can actively authorize/cancel authorization through the product function settings page. (VI) Additional business functions based on device calendar permissions When you use business functions such as appointment videos and product launch reminders, we will need to obtain your device calendar permissions and collect your calendar information (personal information). If you refuse to provide it, you will only be unable to use the function, but it will not affect your normal use of other functions of the product and/or service. Calendar permissions are a setting on your device, which you can manage through the device settings page. At the same time, you can also turn on/cancel this permission at any time through the relevant function settings on the product. When you turn on this permission, it is deemed that you authorize us to access, obtain, collect, and use your personal information; but when you cancel this authorization, we will no longer collect this information and will no longer be able to provide you with the above-mentioned corresponding services; but unless you delete your personal information in accordance with the law, your cancellation will not affect our processing and storage of personal information based on your previous authorization. (VII) Ordering and Delivery: When you purchase goods or services from our products and/or services, you will need to provide some information necessary to place an order and complete the transaction, including: information about the goods or services being traded, recipient information (recipient’s name, delivery address, and contact number) (personal sensitive information). In addition, we may also collect other order-related information, including: order number, transaction amount, order time, order merchant, order number, order status, payment method, payment account, and payment status (personal sensitive information). We collect this information to help you successfully complete the transaction, ensure your transaction security, query order information, and provide customer service. After you successfully place an order, if the goods are provided by a third-party seller or require third-party delivery, in order to smoothly, safely, and accurately complete the delivery and delivery of the goods to you, the merchant and third-party delivery company will inevitably obtain your relevant delivery information (personal information) during the shipping and delivery process. We promise to you that we will make every effort to protect the security of your personal information. We will strictly require merchants and third-party delivery companies to keep your personal information confidential and to only obtain and use it for delivery purposes. It shall not be disclosed or used for any other purpose. (VIII) Customer Service and Other User Response Functions When you contact our customer service or use other user response functions (including: making after-sales requests for our products and/or services, exercising control over your relevant personal information, and other customer complaints and requests), for the security of your account and system, we may need you to provide account information first and match it with your previous personal information to verify your user identity. When you use customer service or other user response functions, we may also need to collect the following personal sensitive information: contact information (the phone number/email address you use when contacting us or other contact information you proactively provide to us), your communication information with us (including text/images/audio/video/call records), and other necessary information related to your needs. We collect this information to investigate the facts and help you solve problems. If you refuse to provide it, you may not be able to use our customer service and other user response mechanisms. (IX) Personalized Recommendation Function In order to provide you and/or your child with better quality and appropriate services and enable you and/or your child to have a better product experience, we have set up a personalized recommendation service in our products. Subject to compliance with relevant laws and regulations, we may associate your and/or your child’s usage behavior, usage time, browsing history and related personal information and conduct further data analysis. Based on the results of relevant data analysis, we recommend and display more suitable audio and video content and related information that you and/or your children may be more interested in, such as: recommending cartoons, audio picture books, children’s songs, etc. that you and/or your children may like. You can refuse targeted and accurate personalized content recommendation services by turning off “Personalized Recommendations” in “Settings-Privacy Permissions”. Turning off the personalized recommendation service will not affect your normal use of our products, but the relevance of the relevant content displayed will decrease. (X) Account security protection function We need to collect some of your information to ensure the security of your account and system when using our products and/or services, and to help improve the security and reliability of our products and/or services to prevent any behavior that harms users, Hula English , and society, including: your personal information as follows: account login location, personal commonly used device information, login IP address, product version number, language mode, browsing history, network usage habits, service failure information, sensor information, and personal sensitive information: transaction information, member real-name authentication information. We will use the above information to comprehensively judge your account, account and transaction risks, conduct identity authentication, customer service, detect and prevent security incidents, monitor fraud, archive and backup purposes, and take necessary recording, auditing, analysis and disposal measures in accordance with the law. Once we detect the existence or suspected existence of account security risks, we will use relevant information for security verification and risk elimination to ensure the security of the products and services we provide to you, so as to protect your rights and interests from being infringed. At the same time, when account or system security issues occur, we will collect this information to optimize our products and services. (11) Your personal information collected indirectly from external third parties You are aware that we cannot obtain the personal information you provide to external third parties ( excluding companies under Hula English ) or your personal information collected by external third parties, and we will not use unconventional methods (such as maliciously interfering with the other party’s series of APP data) to obtain your personal information through software programs without authorization. If it is necessary to indirectly collect (such as sharing) your personal information from a third party due to business development needs, and we directly or jointly provide you with products or services, we (or the third party) will clearly inform you of the source, type, purpose, method of use, business function used, and scope of authorized consent of your shared personal information before collection (if the method and scope of use exceed the scope of your original authorization with the third party, we will obtain your authorization and consent again). Such scenarios include when you directly log in to our products and/or services through a third-party account, and we obtain your account information (including avatar, nickname) that you authorize to share from the third party; when some of our products/services are provided by business partners or jointly provided by us and business partners, we indirectly collect some of your information from some business partners for the necessary/reasonable smooth development of our business; and information about you provided by other parties when using our products and/or services (including posted content related to you, including images, photos, and videos). In addition, before indirectly collecting your personal information, we will clearly require the third party to collect your personal information in written form (such as an agreement or commitment letter) only after obtaining your explicit consent and to inform you of the content of the shared information. Sensitive information will be subject to your reconfirmation before being provided to us for use. We will require the third party to make a commitment to the legality and compliance of the source of the personal information in the agreement and other aspects. If the third party violates this, we will clearly require them to bear the corresponding legal liability. At the same time, our professional security team will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will protect indirectly obtained personal information using means and measures that are no less protective than those we use for our own users’ personal information. (XII) Necessary to maintain/improve our products and/or services . We may collect information such as your search history, viewing history, favorites, viewing duration, order information, IP address, access date and time, and your preferred online behavior when using our products and/or services to help us better understand how you access and use our products and/or services, maintain and improve our products and/or services, or respond to you in other ways. At the same time, we may collect other information when you use our products and/or services for other reasonable purposes, including: questionnaire responses, relevant information we obtain when you interact with Hula English companies/our partners for research and development and improvement, comprehensive statistics, data analysis or processing, other purposes with your consent or authorization, compliance with legal provisions or other reasonable purposes, for example: the red envelopes you receive in specific marketing activities, the law requires us to fulfill the obligation to withhold and pay personal income tax, so we need to collect your name and ID card information (personal sensitive information) in accordance with the law. If we provide corresponding options in the relevant products and/or services, you can also actively request us to use the personal information you provide and store in the product and/or service for other services of ours or our partners. (13) For the security of your information, we have agreed to strict data security and confidentiality obligations with third-party SDK service providers, and these companies will strictly abide by our data privacy and security requirements. Unless we obtain your consent, we will not share your personal information with them. ( 14) Others As mentioned above, if a function or product/service that requires the collection of your personal information is not described in this ” Hula English Privacy Policy”, or we exceed the purpose stated when collecting your personal information and the scope that is directly or reasonably related, we will explain it to you separately before collecting and using your personal information by updating this ” Hula English Privacy Policy”, page prompts, pop-ups, message notifications, website announcements or other methods that are convenient for you to know, and provide you with a way to choose your consent. We will collect and use your personal information only after obtaining your explicit consent. (XV) Exceptions to Obtaining Authorization and Consent In addition, you fully understand and agree that we do not need your authorization and consent to collect and use your personal information in the following circumstances: 1. Related to national security and national defense security; 2. Related to public safety, public health, and major public interests; 3. Directly related to criminal investigation, prosecution, trial, and execution of judgments; 4. To protect your or other individuals’ life, property, and other major legitimate rights and interests, but it is difficult to obtain your consent; 5. The information collected is disclosed to the public by you or collected from legally public channels (such as legal news reports, government information disclosure, etc.); 6. Necessary for the signing and performance of relevant agreements or other written documents with you; 7. Necessary for maintaining the safe and stable operation of our products and/or services, such as discovering and handling product and/or service failures; 8. Other circumstances required by competent authorities, laws and regulations, etc. III. How We Use Cookies and Similar Technologies (I) About Cookies and Similar Technologies Cookies are small files containing a string of characters that are sent and stored on your computer, mobile device, or other device (usually encrypted) when you log in to and use a website or other online content. Cookie-like technologies are other technologies that can be used for similar purposes as cookies, such as web beacons, proxies, and embedded scripts. Currently, we primarily use cookies to collect your personal information. You acknowledge and agree that as technology develops and our products and services are further improved, we may also use cookie-like technologies. (II) How We Use Cookies and Similar Technologies When you use our products and/or services, we may use cookies and similar technologies to collect some of your personal information, including your website browsing habits, browsing information, and login information. Cookies and similar technologies collect this information to facilitate your use of our products and/or services, simplify repetitive operations (such as registration and login), facilitate your review of usage history (such as video viewing history), protect the security of your information and account, and improve our products and services. We commit to using cookies and similar technologies only for the purposes described in this Hula English Privacy Policy. You can manage or delete cookies and similar technologies according to your preferences: if your browser permits, you can manage or (partially/completely) reject cookies and/or similar technologies through your browser settings; or delete cookies and/or similar technologies that have been stored on your computer, mobile device or other device; or use the “clear cache” function in the APP settings to prevent us from tracking all or part of your personal information. If you need to know more about how to change your browser settings, please refer to the relevant settings page of the browser you are using. You understand and know that some of our products/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 and/or services normally or obtain the best service experience through our products and/or services, and it may also have a certain impact on the protection of your information and the security of your account. IV. How we share, transfer, and publicly disclose your personal information (I) Sharing We attach great importance to the protection of your personal information. Your personal information is an important basis and component for us to provide you with products and/or services. We will only collect and use your personal information within the purposes and scope stated in this ” Hula English Privacy Policy” or in accordance with the requirements of laws and regulations, and strictly keep it confidential. We will not share your personal information with third-party companies, organizations, and individuals outside of Hula English , unless one or more of the following circumstances exist: 1. You make a request on your own; 2. We have obtained your explicit authorization and consent in advance; 3. We may share your personal information externally in accordance with the provisions of laws and regulations, or at the mandatory requirements of government departments; 4. Necessary and reasonable sharing within Hula English : In order to facilitate our provision of consistent services to you based on Hula English’s unified account system, to ensure and improve the security and reliability of our services and systems, to protect the personal and property safety of Hula English , users, or the public from infringement, and to facilitate your unified management, You acknowledge and agree that your personal information may be shared as necessary within Hula English products (e.g., Hula English , Mengbao Children’s Songs, and Dot Dot English Children’s Songs). However, please rest assured that we will only share information when necessary and within a reasonable scope and process it only for the purposes stated above (e.g., when you use your Hula English account to log in to other products owned or operated by Beijing Mengbao Technology Co., Ltd. and its affiliates, we will share your necessary account information with them, and the relevant data records under that account may also be shared and linked). If we need to share your sensitive personal information or if an affiliate needs to change the purpose of use or processing of your personal information, we will seek your authorization and consent again. 5. Necessary Sharing with Certain Business Partners: You understand and agree that we may need to share some of your information with certain business partners for the necessary/reasonable purposes of smoothly operating our business, meeting your requirements, fulfilling our obligations under the relevant user agreements or this Privacy Policy, exercising our rights, or complying with legal requirements. However, we promise that we will only share your necessary personal information. If we share your sensitive personal information or change the purpose of use or processing of your personal information, we will seek your authorization and consent again. Our current business partners include: (1) service providers that provide functional support for our products and/or services, including payment institutions that provide payment services, operators that provide one-click login services, and other service providers. The purpose of sharing information is to enable the functions of our products and/or services so that you can use them normally; (2) third-party merchants on our platform: to meet your needs for purchasing products or services (including enjoying after-sales service), we will share your order information and transaction-related information with third-party merchants on our platform; (3) partners who provide data services (including online advertising monitoring, data statistics, and data analysis): to maintain/improve our products/services and provide you with better content, we may share your relevant information (including video playback records, advertising display records, terminal models, your city and other relevant information) with designated partners who provide such services. For the security of your information, we currently only cooperate with partners that have signed strict data security and confidentiality agreements, including Umeng, etc., and these companies must comply with our data privacy and security requirements. Unless we obtain your consent, we will not share your personally identifiable information with them; (4) Third-party SDK service providers: Our products may include third-party SDKs or other similar applications. If you use such services provided by third-party SDKs on our platform, you agree that they will directly collect and process your information (such as in the form of embedded code, plug-ins, etc.). The aforementioned service providers’ collection and processing of information shall comply with their own privacy terms and are not subject to this policy. However, we will also strive to review the business access qualifications of the third party and strive to require the legality, compliance and security of such service providers. In order to maximize the security of your information, we strongly recommend that you review the privacy terms before using any third-party SDK services. To protect your legal rights and interests, if you find that such SDKs or other similar applications are at risk, it is recommended that you immediately terminate the relevant operations and contact us in a timely manner;
The following is information about the main third-party SDK service providers we have accessed or will soon access:
1. Alibaba Cloud Player SDK
Purpose of use: For video playback
Information type: UUID, device model
Official website link: Alibaba Cloud Video Service Privacy Policy (S54)
2. AndroidVideoCache
Purpose: Play audio and video
Information Type:
Device information (including device attributes, connection and status information, such as device model, software and hardware characteristics)
Personal information collected: SD card directory
(5) Partners who entrust us to carry out information promotion and advertising: You authorize us to share the de-identified or anonymized analytical/ statistical information we use to form a collection of your relevant information with the partners who entrust us to carry out information promotion and advertising , so as to help them make advertising or decision-making recommendations, improve the effective reach of advertising, and further understand user needs. When the aforementioned partner is a financial institution (including banks,
lenders , insurance companies, fund securities companies, etc.) that provides you with lending, deposit and other services, we will obtain your authorization separately and, after your authorization
, synchronize your relevant information (including: name, ID card information, address book information, subject to your authorization content) to the partner to assist you in quickly completing identity verification, entering emergency contact information, risk control verification, etc. At the same time, you authorize us to share the
de-identified or anonymized analytical/statistical information we use to form a collection of your relevant information with the aforementioned financial institutions to help them judge your credit status, reduce bad debt rates, ensure business security and prevent fraud, etc. We promise that we will not share your personal information that can identify you with them without your consent;
(6) Partners who provide a service with us, for example, we carry out marketing activities with our partners. In order to provide you with normal services and meet your service needs, we will obtain your authorization separately and synchronize your relevant information (subject to your authorization content) to the partner after your authorization.
6. The information shared is de-identified, and the third party to whom the information is shared cannot re-identify the identity of the information subject;
7. Sharing with third parties in order to protect you, our other users or employees, Hula English or the public interest, property or safety (for example, fraud or credit risk, etc.) from damage;
8. In some cases, only by sharing your personal information can we realize the core functions of our products and/or services or provide the services you need, or handle disputes or disputes between you and others;
9. Sharing in accordance with the relevant agreements signed between you and us (for example, online agreements, platform rules, etc.) or legal documents;
10. Complying with the relevant agreements between you and other third parties;
11. Sharing based on reasonable business practices, for example, sharing information such as winners/winners in joint marketing activities with third parties so that they can distribute prizes/gifts to you in a timely manner; when we accept due diligence, etc.
12. Use for academic research, such as sharing de-identified or anonymized analytical/statistical information generated by our use of your relevant information with academic institutions for the purpose of academic research (we will not share your personally identifiable information with them without your consent); when academic research institutions conduct statistical or academic research based on the public interest and provide the results of academic research or descriptions to the public, the personal information contained in the results will be anonymized;
13. Other circumstances requiring sharing as required by competent authorities, litigation disputes, laws and regulations, etc.
You can share your personal information or other information with third parties (including unspecified objects) based on the Hula English platform, but the leakage or use of information caused by your sharing behavior has nothing to do with Hula English , and you will bear the corresponding legal liability.
We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share necessary personal information. When we share information with our business partners, we will protect your personal information in a variety of ways, including but not limited to: (1) If there are reasonable reasons as mentioned above and your authorization and consent is required, we will inform you of the purpose and type of the shared information before sharing (if it involves your personal sensitive information, we will also inform you of the content of the sensitive information involved) and share it only after obtaining your authorization and consent; (2)
At the cooperation agreement level, we will strictly require our partners to have information protection obligations and responsibilities. To this end, our legal department requires business partners to sign a data security protection agreement with
Hula English before cooperation. The agreement strictly stipulates the confidentiality obligations of business partners’ user information, including that the storage, use and circulation of information must meet our control requirements and be subject to our review and supervision. In the event of any violation, the business partners will bear the corresponding legal liability; (3) In addition, our security team will conduct security assessments and processing on the output form, circulation, use, etc. of information data . Please be aware that even if we have obtained your authorization and consent, we will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and try to
anonymize the personal information in the shared content .
You understand and acknowledge that anonymized information cannot be linked to or identified with you and is no longer considered personal information in the legal sense. Your authorization and consent are not required for its processing, use, sharing, or transfer.
(II) Transfer.
Transfer refers to the process of transferring control of personal information to another company, organization, or individual. In principle, we will not transfer your personal information, except in the following circumstances:
1. You make a request;
2. We have obtained your explicit authorization and consent in advance;
3. If we undergo a merger, acquisition, reorganization, division, bankruptcy, asset transfer, or similar transaction, and your personal information may be transferred as part of such transaction, we will require the new holder to continue to comply with and fulfill the entire provisions of this “
Hula English Privacy Policy” (including the purpose of use, usage rules, security measures, etc.). Otherwise, we will require them to obtain your explicit authorization and consent again;
4. Other circumstances required by laws and regulations.
If a transfer is necessary for the above reasons, we will inform you of the purpose and type of the information being transferred (if it involves your sensitive personal information, we will also inform you of the content of the sensitive information involved) before the transfer, and will obtain your authorization and consent before the transfer, except as otherwise provided by laws and regulations or as otherwise agreed upon in this Policy.
(3) Public Disclosure:
Public disclosure refers to the act of releasing information to the public or to an unspecified group of people. We will not publicly disclose your personal information
except for necessary disclosures such as obtaining your explicit consent, or for necessary matters such as issuing penalty announcements for illegal accounts, fraudulent activities, or displaying information in an unencrypted format when announcing prize winners . If there are legitimate grounds for public disclosure, we will
inform you of the purpose and type of information to be disclosed (if it involves your sensitive personal information, we will also inform you of the content of the sensitive information involved) before disclosure, and will only disclose it after obtaining your authorization and consent,
unless otherwise provided by laws and regulations or as otherwise provided in this Policy. We
may disclose your personal information to authorized authorities or the public based on the law, legal process, litigation, or mandatory requirements of government authorities, in order to protect national security, public safety, and the significant legitimate rights and interests of you and other individuals . However, we guarantee that in the event of such circumstances, we will require the party requesting disclosure to produce valid legal documents and implement security measures for the disclosed information that comply with laws and
industry standards.
We will fully consider the risks of publicly disclosing your personal information. Upon receiving a request for public disclosure, we will promptly and carefully review its legitimacy, reasonableness, and legality. We will also implement personal information security measures and methods to protect it at or after the public disclosure, no less stringent than those stipulated in this
Hula English Privacy Policy. Please be aware that even if we have obtained your authorization and consent, we will only disclose your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and will strive
to anonymize the personal information in the publicly disclosed content. You understand and acknowledge that de-identified or anonymized information cannot be linked to or identified with you and is no longer your personal information. Your authorization and consent are not required for its public disclosure.
(IV) Exceptions
According to laws and regulations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent in the following circumstances:
1. Directly related to national security and national defense security;
2. Directly related to public safety, public health, and major public interests;
3. Directly related to criminal investigation, prosecution, trial, and execution of judgments; or in accordance with the requirements of laws and regulations, administrative agencies, public security, procuratorates, and other competent authorities;
4. To protect the life, property, and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain your consent;
5. The personal information is disclosed to the public by you or collected from legally public channels (such as legal news reports, government information disclosure, etc.);
6. Other circumstances stipulated by laws and regulations.
(V) Responsibilities for Sharing, Transferring, and Public Disclosure
We will strictly follow the provisions of this Privacy Policy and the requirements of relevant laws and regulations to carry out the sharing, transfer, and public disclosure of personal information. If your legal rights and interests are damaged due to our fault, we are willing to bear the corresponding liability for damages to you within the scope of the law.
V. Your Rights to Control Your Personal Information
You have various rights to control your personal information in our products and/or services, including accessing, correcting/modifying, and deleting it, withdrawing your prior consent for your personal information, and canceling your Hula English account. To facilitate your exercise of these rights, we have provided instructions and settings on the relevant product pages. You can perform these operations on your own. If you have any questions or difficulties during operation, you can contact us through the methods at the end of this document and we will promptly address them. (I) Right of Access
You can query or access your relevant personal information in our products and/or services, including:
Account Information: You can log in to your personal account at any time through the relevant product page to access your personal information in your account, including: avatar, nickname, birthday, gender, personal signature, etc. For example, the access path for “avatar/nickname/birthday/gender/personal signature/baby gender/baby birthday, etc.” in the ” Hula English Mobile App” is: Cache – Settings;
Usage Information: You can access your usage information at any time through the relevant product page, including: cached search history, uploaded content, order information, points information, etc. For example, the access path for “viewing history” in the ” Hula English Mobile App” is: Cache;
Other Information: If you encounter any operational problems during this access process or need to obtain other personal information that cannot be obtained as mentioned above, you can contact us through the methods provided at the end of this document. We will provide you with it within a reasonable period of time after verifying your identity, except as otherwise provided by laws and regulations or otherwise agreed upon in this Policy.
(II) Right to Correct/Amend
You can correct/amend your relevant personal information in our products and/or services. To facilitate your exercise of the rights described above, we provide two options: online self-correction/amendment and submitting a correction/amendment request to us.
For some of your personal information, we provide instructions and settings on the relevant product pages, allowing you to directly make corrections/amendments. For example, the correction/amendment path for “nickname, baby’s gender, and baby’s birthday” in the ” Hula English Mobile App” is: Cache – Settings.
If you encounter difficulties in exercising the above rights, or if you may not be provided with online self-correction/amendment rights, you have the right to correct or amend erroneous or incomplete information after verifying your identity and provided that the correction does not affect the objectivity and accuracy of the information. In certain circumstances, especially when the data is incorrect, you may submit a correction/amendment request to us through our published feedback and error reporting procedures, requesting that we correct or amend your data, except as otherwise provided by laws and regulations. However, for security and identity verification purposes, you may not be able to modify certain initial registration information submitted during registration.
(3) Right to Deletion:
Generally speaking, we will only retain your personal information for the shortest period required by laws and regulations or as necessary. To facilitate your exercise of your right to delete as described above, we provide two options: online self-deletion and submitting a deletion request to us.
For some of your personal information, we provide instructions and settings on the relevant product pages, allowing you to delete it directly. For example, in the ” Hula English Mobile App,” the path to delete “viewing history” is: Cache > Clear Cache. Once you delete it, we will delete or anonymize such information, unless otherwise required by laws and regulations.
You may directly request deletion of your personal information in the following circumstances, unless the data has been anonymized or otherwise required by laws and regulations.
1. We collect or use your personal information in violation of laws and regulations;
2. We collect or use your personal information in violation of an agreement with you;
3. If we share or transfer your personal information to a third party in violation of laws and regulations or an agreement with you, we will immediately cease sharing or transferring the personal information and notify the third party to delete it promptly; 4. If
we disclose your personal information to a third party in violation of laws and regulations or an agreement with you, we will immediately disclose the disclosure and issue a notice requiring the relevant recipient to delete the information;
5. Other circumstances required by laws and regulations.
We will provide detailed information on our handling of your personal information in other dedicated sections of this document
after you no longer use our products and/or services and cancel your Hula English account, or after we terminate some or all of our products and/or services. You understand and agree that after you delete information from our products and/or services, we may not immediately delete the corresponding information from our backup systems, but will delete it when the backup is updated.
(IV) Right to Request:
If you require a copy of your personal data, you may contact us using the information provided at the end of this Hula English Privacy Policy. After verifying your identity, we will provide you with a copy of your personal information in our services (including basic information and identity information), except as otherwise required by laws and regulations or as otherwise provided in this Policy.
(V) Right to Withdraw Consent:
If you wish to change the authorization of relevant permissions (e.g., location, address book, camera, photo album, microphone, calendar), you can modify it through your hardware device or operate the relevant function settings interface of our products or services (for example, the path to withdraw consent for the “location” permission in the ” Hula English mobile app” is: My – Settings – Privacy – Privacy Settings). You can also permanently withdraw all authorizations for us to continue collecting your personal information by canceling your Hula English account. If you encounter any operational problems during this process, you can contact us through the methods provided at the end of this Hula English Privacy Policy.
If you wish to withdraw your authorization to share, transfer, or publicly disclose your personal information, you can also contact us through the methods provided at the end of this Hula English Privacy Policy. After verifying your identity, we will modify your relevant authorizations, except as otherwise provided by laws and regulations or as otherwise agreed upon in this Policy.
Once you cancel your authorization to collect relevant personal information, we will no longer collect that information and will no longer be able to provide you with the corresponding services described above. However, you acknowledge and agree that your decision to withdraw your consent will not affect our processing of personal information based on your previous consent.
(VI) Right to Cancel
We provide you with the right to cancel your Hula English account. You can cancel your account by applying online, contacting our customer service, or through other methods we publicly disclose (except as otherwise provided by laws and regulations or as otherwise agreed upon in this Policy). Once you cancel your account , you will no longer be able to use the services of our full range of user products and will be deemed to have automatically waived your existing rights and interests. Therefore, please proceed with caution.
Unless otherwise provided by laws and regulations , upon account cancellation, we will cease providing you with all of our products and services. All content, information, data, and records related to our products and services that you have used through that account will be deleted or anonymized
.
For more information on the Hula English account cancellation process, conditions, and precautions, please refer to the Hula English Account Cancellation Agreement. You can submit a cancellation request to us through the relevant function settings page of our products and/or services you use, or by following the instructions. For example, the cancellation path in the Hula English mobile app is: My – FAQ – Account Cancellation.
(VII) Advance Notification of Product and/or Service Termination
We will continue to provide you with high-quality services. If, for special reasons, we are forced to cease operations for some or all of our products and/or services, we will notify you in advance by posting a prominent notice, sending you a push message, or by other means, and will cease collecting your personal information. Furthermore, we will delete or anonymize your personal information held after the minimum period required by laws and regulations has expired.
(VIII) Restricting Automated Decision-Making by Information Systems
In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legal rights and interests, you have the right to request an explanation from us, and we will provide appropriate remedies.
(IX) Right to Feedback
We provide you with multiple channels for feedback; please see the “How to Contact Us” section of this Policy for details.
(X) Exceptions
Please understand and be aware that, in accordance with laws and regulations, we may not respond to your requests for access, correction/amendment, deletion, withdrawal of consent, cancellation, or request under the following circumstances:
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, trial, and enforcement of judgments;
4. We have sufficient evidence to demonstrate subjective malice or abuse of rights;
5. Responding to your request will cause serious damage to the legal rights and interests of you or other individuals or organizations;
6. Involving commercial secrets;
7. Other circumstances specified by laws and regulations.
VI. How We Store and Protect Your Personal Information (I) Storage
and Location of Personal Information: We store your personal information within the territory of the People’s Republic of China in accordance with laws and regulations. Currently, we do not store your personal information across borders or provide personal information overseas .
If cross-border storage or overseas transfer of personal information is necessary, we will separately and clearly inform you (including the purpose of the transfer, the recipient, the method and scope of use, the content of the use, security measures , and security risks), obtain your authorization and consent again, and strictly require the recipient
to process your personal information in accordance with this
Hula English Privacy Policy and other relevant requirements. Storage Period: We retain your personal information for the minimum period necessary to provide our products and services. For example, when you use our registration and membership features
, we need to collect your mobile phone number. After you provide it and while you use the feature, we need to continue to retain your mobile phone number to provide you with the features and protect your account and system security.
After the expiration of the above storage period, we will delete or anonymize your personal information, unless you exercise your right to delete, cancel your account, or if otherwise required by law (for example, the E-Commerce Law stipulates that product and service information and transaction information must be retained for no less than three years from the date of transaction completion).
Note: If you apply to cancel your Hula English account and have successfully submitted your cancellation application to us, we will provide a 15-day retention period (the “freeze period”) for your account .
During the freezing period, in order to facilitate your application to restore the account, we will not temporarily delete or anonymize the relevant information under the account. If we do not receive your
request to restore the account after the freezing period or there are no other reasons that prohibit cancellation, the account will be permanently cancelled and the relevant information under the account will be deleted or anonymized. (
2) Personal Information Protection Measures
We have always attached great importance to protecting the personal information security of users. To this end, we have adopted multi-level protection measures such as security technical measures that meet industry standards and supporting organizational structures and management systems to minimize the risk of your information being leaked, damaged, misused, unauthorized access, unauthorized disclosure and modification. Including:
1. Data security technical measures
(1)
In terms of data security collection, confirm the legality, legitimacy and necessity of data collection through personal information security impact assessment, identify and inform users in a clear and accurate manner to obtain consent, and log the user’s authorized consent collection behavior
; use sensitive identification tools to classify and grade the collected user data, and set different levels of security policies for different levels of data; use technical measures to identify the source of the collected or generated data to ensure the accuracy and non-repudiation of the data source; after collecting personal information, de-identify the personal information, and take technical and management measures to
store the de-identified data separately from the information that can be used to restore the identification of the individual, to ensure that the individual is not re-identified in the subsequent personal information processing;
(2) In terms of data security transmission, use a secure channel to transmit personal information, and use appropriate encryption algorithms for secure encryption and desensitization to ensure the confidentiality and integrity of personal information during data transmission;
(3) In terms of data security
storage, a data classification and grading management system is adopted, and different information storage strategies are adopted according to the data classification and grading results; a data classification and grading management system is adopted, and different information storage
strategies are adopted according to the data classification and grading results; personal sensitive information must be encrypted and stored to ensure that data security usage specifications can be implemented in place; strengthen permission control and security audits for databases storing personal information; regularly back up and restore
personal information to ensure the integrity of personal information during storage and use;
(4) In terms of data security processing, personal information is desensitized according to usage scenarios and security requirements, such as de-identifying personal information before displaying it through the interface; the use of real user information is strictly prohibited in development and testing environments; a strict data permission control mechanism is implemented, and technical measures such as multiple identity authentication and network/data isolation are adopted to ensure that the processing of personal information can be effectively monitored to prevent illegal access and unauthorized use of data; when using your personal information, the clear identity reference will be eliminated to avoid precise positioning of you, except for purposes necessary;
(5) In terms of data security destruction, we will set the minimum available storage period for personal information in accordance with the requirements of laws and regulations and actual business needs, and process expired data through secure deletion technology to ensure that the destroyed data cannot be recovered. Technical means include but are not limited to data complete erasure solutions, disk destruction, physical destruction, etc.;
(6) We will establish a complete audit mechanism to monitor and audit the entire process of the data life cycle to prevent your personal information from being damaged or lost due to unauthorized access, public disclosure, use, modification, human or accidental damage or loss;
(7) Other measures to achieve data security protection.
2. Data security organization and management measures
(1) Establish a dedicated department responsible for personal information protection, establish relevant internal control management processes, and adopt the principle of minimizing permissions for staff who may have access to your information;
(2) Establish a management system such as a data classification and grading system, business data security usage specifications, and data cooperation specifications to ensure that the collection, transmission, use, storage, transfer, and destruction of your information meet the relevant laws and regulations and security requirements; set up internal approval processes for important operations on personal information and the authority to process personal information;
(3) Regularly organize employees to participate in security and privacy protection related training and require them to complete the prescribed assessments to enhance employees’ awareness of the importance of protecting personal information;
(4) Pass the Ministry of Public Security’s Information Security Level Protection Level 3 certification, and establish a good coordination and linkage mechanism with regulatory agencies and third-party assessment agencies to promptly resist and deal with various information security threats and provide all-round protection for your information security;
(5) Other feasible security organization and management measures.
3. Guarantee of the terms of the cooperation agreement
(1)
Before we indirectly collect your personal information from a third party, we will clearly require the third party to collect and process (such as share, etc.) personal information after obtaining your explicit consent in written form (such as a cooperation agreement, a letter of commitment), and require the third party to make a commitment to the legality and compliance of the source of personal information at the level of the written agreement. If the third party violates the provisions, we will clearly require the third party to bear the corresponding legal liability;
(2) Before we share your personal information with our business partners, we will strictly require the partners to fulfill their information protection obligations and responsibilities, and require the business partners to sign a data security protection agreement before cooperation. If the business partners violate the agreement in any way, they will bear the corresponding legal liability;
(3) Other contents clearly stipulated in the cooperation agreement.
4. Handling of Security Incidents
(1) We have established
a reasonable, effective, scientific and sound security emergency response system and formulated a number of security management systems, including the “Cybersecurity Incident Emergency Response Plan”, “Emergency Security Incident Response Mechanism”, “Major Incident Emergency Plan”, “Data Security Incident Management Specification “, etc., which clearly define the classification and grading standards for cybersecurity incidents, the security emergency response organization and responsibilities, and formulate appropriate emergency response plans according to the different types and levels of security incidents, and clearly
define the reporting process and emergency response handling process for security incidents (including research and analysis, suppression, eradication, recovery, result announcement and experience summary). At the same time, we also have a professional security technology and operation team responsible for
maintenance, which facilitates timely and effective response and handling of various security vulnerabilities and emergencies, and cooperates with relevant departments to trace and combat security incidents;
(2) If a personal information security incident unfortunately occurs , we will promptly inform you of the basic situation and possible impact of the security incident, the handling measures we have taken or will take, your
suggestions for self-prevention and risk reduction, and your remedial measures in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant circumstances of the incident by one or more means such as email, phone, SMS, push notification, letter, etc. When it is difficult to inform the subject of personal information one by one, we will
take reasonable and effective measures to issue an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities;
(3) Please be aware
and understand that the Internet is not an absolutely safe environment. We strongly recommend that you use a safe method and complex password to help us ensure the security of your account. If you find that your personal information has been leaked, especially if your account
or password has been leaked, please contact us immediately according to the contact information provided at the end of this Privacy Policy so that we can take appropriate measures to protect your information security.
VII. Protection of Minors
Hula English has always attached great importance to the protection of minors and is committed to practicing our corporate social responsibility.
Minors should first obtain the consent of their guardians before using our products and/or services. If you are a minor, you should read this ” Hula English Privacy Agreement” under the supervision and guidance of your guardian before using our products and/or services, and should use our products and/or
services and submit personal information with the explicit consent and guidance of your guardian. We protect the personal information of minors in accordance with relevant national laws and regulations. We will only collect, use , or publicly disclose the personal information of minors when permitted by laws and regulations, with the explicit consent of their guardians, or as necessary to protect their rights and interests . If you are the guardian of a minor and have any questions regarding the personal information of the minor you supervise, please
contact us using the contact information in the “How to Contact Us” section. If we discover that we have collected the personal information of a minor without the prior, verifiable consent of their guardian, we will endeavor to delete the relevant data as soon as possible.
Hula English ‘s products and/or services are standalone children’s apps, primarily intended for children and providing exclusive content for children. For these products and/or
services, children must first obtain their guardian’s consent (including this Policy, especially Appendix 1 hereto) before using them, and use them only with their guardian’s consent and guidance. We will strictly fulfill our obligations and responsibilities as required by law to protect children’s personal information . We have established specific terms and conditions regarding our collection, use, storage, and protection of children’s personal information. Guardians are advised to carefully read Appendix 1 to this Policy, “
Hula English Children’s Personal
Information Protection Rules.”
8. Updates to this ” Hula English Privacy Policy” We encourage you to review our “
Hula English Privacy Policy”
every time you use our products or services . To provide you with better service, we may update the terms of this Hula English Privacy Policy based on product updates and relevant legal and regulatory requirements . Such updates shall constitute part of this Hula English Privacy Policy. If such updates result in a substantial reduction or significant change in your rights under this Hula English Privacy Policy
, we will notify you by prominently displaying a notice, sending you a push message, or by other means before this policy takes effect. Your continued use of our services will constitute your full reading , understanding, and agreement to be bound by the revised
Hula English Privacy Policy. To protect your legal rights, we recommend that you regularly review this policy on the settings page of our platform.
The aforementioned “significant changes” include, but are not limited to:
1. Significant changes to our service model, such as the purpose of processing personal information, the types of personal information processed, and how personal information is used;
2. Significant changes to our ownership structure, organizational structure, etc. Such as changes in ownership due to business adjustments, bankruptcy, mergers and acquisitions, etc.;
3. Changes in the primary recipients of personal information sharing, transfer, or public disclosure;
4. Major changes in your rights to participate in the processing of personal information and how they are exercised;
5. Changes in the responsible department, contact information, and complaint channels for handling personal information security;
6. When a personal information security impact assessment report indicates a high risk;
7. Other situations that are important or may seriously affect your personal rights and interests.
IX. How to contact us
(1) If you have any questions about the implementation of this ” Hula English Privacy Policy” or privacy protection-related matters encountered when using our services (including consultation, complaints, reports, etc.), we have provided you with a variety of feedback channels and hope to provide you with satisfactory solutions:
1. Online customer service/other online feedback channels: You can contact the online customer service on the product function page of our platform or submit feedback online;
2. Manual customer service channel: You can call any of our customer service numbers to contact us;
3. Dedicated email channel: In order to better protect your rights and interests, we have set up a special email address hi@mampod.com, and you can contact us through this email address;
(2) We will reply to you as soon as possible after receiving your opinions and suggestions and within 15 days after verifying your user identity or within the period prescribed by laws and regulations. Generally, we will not charge you a service fee for this. However, you understand and acknowledge that we will be unable to respond to your request in the following circumstances:
1. Requests related to national security or national defense security;
2. Requests related to public safety, public health, or major public interests;
3. Requests related to criminal investigation, prosecution, and trial;
4. Requests where there is sufficient evidence to demonstrate subjective malice or abuse of rights;
5. Requests where responding to your request will seriously damage the legitimate rights and interests of you, or other individuals or organizations;
6. Requests involving trade secrets;
7. Requests in other circumstances as provided for by laws and regulations.
(III) If you are dissatisfied with our response, or if our handling of your personal information infringes upon your legitimate rights and interests, and we refuse to improve after you provide us with feedback, you may file a complaint or report to regulatory authorities such as the Administration for Industry and Commerce or the Public Security Bureau.
X. Other
(I) The interpretation and dispute resolution of this ” Hula English Privacy Policy” shall be governed by the laws of mainland China. Any disputes arising from this ” Hula English Privacy Policy” shall be resolved amicably through negotiation between the parties. If a resolution cannot be reached through negotiation, you agree to submit the dispute to the Haidian District People’s Court of Beijing for litigation.
(2) The titles of this ” Hula English Privacy Policy” are for convenience and reading purposes only and do not affect the meaning or interpretation of any provisions contained therein.
Appendix 1: Hula English Children’s Personal Information Protection Rules
Hula English has always attached great importance to the protection of minors and is committed to fulfilling our corporate social responsibility. These ” Hula English Children’s Personal Information Protection Rules” (hereinafter referred to as “these Rules “) are intended to explain in more detail to guardians (hereinafter referred to as “you”) and children how we collect, use, store and process children’s personal information, as well as
the methods we provide for you and children to access, correct, delete and protect this information. If you are a guardian of a child user, please read carefully, fully understand and decide whether to agree to these Rules and whether to consent to you and the children under your guardianship using our products and/or services.
I. Scope of Application
These ” Hula English Children’s Personal Information Protection Rules” (hereinafter referred to as “these Rules”) only apply to independent children’s apps that are primarily aimed at children and provide exclusive content for children (also referred to as “children’s apps” in these Rules).
The Hula English Privacy Policy sets forth Hula English ‘s general practices for collecting, using, processing, and protecting personal information. These rules are part of the Hula English Privacy Policy. In the event of any inconsistency between these rules and
the Hula English Privacy Policy regarding the protection of children’s personal information, these rules shall prevail. For matters not addressed in these rules, the Hula English Privacy Policy shall apply, depending on the specific product circumstances, or as otherwise provided by Hula English . Unless otherwise specified in these rules, the meanings of terms used in these rules shall be consistent with those in the Hula English Privacy Policy.
II. Our Rules for the Collection and Use of Children’s Personal Information:
We strictly fulfill the legal obligations and responsibilities for protecting children’s personal information. We collect and use children’s personal information in accordance with the principles of justification, necessity, informed consent, clear purpose, security, and lawful use. We will not collect children’s personal information unrelated to the products and/or services we provide, and we will not collect or use children’s personal information in violation of legal provisions or our agreements with you.
We collect and use two types of children’s personal information: First, information necessary for the core business functions of the Children’s App: This information is essential for the normal operation of the Children’s App, and you must authorize us to collect it. If you refuse to provide it, you and your child will not be able to use our products and/or services normally; the second type: information that may need to be collected for the additional business functions of the children’s APP: this information is required for non-core business functions, and you can choose whether to authorize us to collect it. If you refuse to provide it, the additional business functions will not be realized or the service effects we intend to achieve will not be achieved, but it will not affect the normal use of the core business functions by you and your child.
Specific business function scenarios include:
(1) “Children’s Virtual Sub-Account Creation” function
You can create and manage virtual sub-accounts for children in the “Settings” of the children’s APP. In
the process of creating a child’s virtual sub-account, we will collect the child’s personal information (including nickname, birthday, gender, and avatar) that you may provide to us. We collect this information to complete the child’s virtual sub-account creation process and
provide high-quality content that is more suitable for the children under your guardianship. We kindly recommend that you do not provide the child’s real name, portrait, contact information and other information unless necessary, and do not easily share the child’s personal
information with others or publish it publicly.
(2) “Settings – Playback Settings” Function
Our children’s app provides you with a “Playback Settings” function so that you can supervise the content, duration, sitting habits, etc. of your children’s use of the children’s app and cultivate good online habits for your children. Therefore, we will collect children’s viewing time information based on the settings you make and limit their usage time.
(3) Other
When children use the children’s app, we will collect online operation records (including video viewing records, search records, download records, collection records, and click records). We collect this information to disclose to you the daily usage of the children in your care, provide them with the content they need, and improve our products and services. In addition, please refer to Section 2 of the “
Hula English Privacy Policy” for the rules on other personal information of children that we may collect and use . This content will be applied/referenced depending on the actual situation of the children’s app. Due to business needs, if it is necessary to collect and use the personal information of the children in your care beyond the purpose and scope of the aforementioned agreement, we will obtain your consent again.
III. Our Rules for Sharing, Transferring, and Publicly Disclosing Children’s Personal Information
(I) Sharing
We will only share children’s personal information for the purposes and scope described in these Rules or as required by law, unless one or more of the following circumstances apply:
1. Sharing with you as a guardian;
2. We have obtained your prior explicit authorization and consent;
3. Necessary sharing with service providers that provide functional support for our children’s apps for necessary/reasonable business purposes, to meet your and your child’s needs, to fulfill our obligations under the relevant user agreements or these Rules, to exercise our rights, or to comply with legal requirements . However, we promise that we will only share necessary personal information about children. If we need to change the purpose of processing children’s personal information, we will seek your authorization and consent again. Please
rest assured that we will conduct security assessments on service providers and their service practices, sign agreements that clearly define responsibilities, matters to be handled, processing periods, nature and purposes of processing, and require that their processing activities do not exceed the scope of our authorization;
4. Other circumstances required by competent authorities, laws, and regulations.
(II) Transfer and Public Disclosure
We will strictly fulfill the legal obligations and responsibilities for protecting children’s personal information and transfer and disclose children’s personal information in accordance with the principles of justification, necessity, informed consent, clear purpose, security, and lawful use . If we need to transfer children’s personal information to a third party, we will conduct a security assessment ourselves or entrust a third-party organization to do so. We
will not disclose children’s personal information unless required to do so by law or administrative regulations or as agreed with you.
For more information, please refer to Section 4 of the Hula English Privacy Policy.
IV. Your and/or Children’s Control over Children’s Personal Information
We provide you and your children with a variety of functions for exercising control over children’s personal information in the Children’s App. You can use these functions to manage children’s personal information and their online lives, including:
(I) Right of Access
You or your children can query and access children’s personal information in the Children’s App, such as profile information, video viewing history, search history, download history, and favorites history.
(II) Right to Correct/Amend
You can correct/amend children’s personal information in the Children’s App, such as profile information; or you can contact us to resolve the issue. We will make corrections/amendments after verifying your identity and without affecting the objectivity and accuracy of the information. However, for security and identity reasons, you may not be able to modify certain initial registration information submitted during registration.
At the same time, if you or your child finds that the personal information of the child we collect, store, use, or disclose is incorrect, you can contact us to correct it. We will take timely measures to correct it after completing identity verification and verifying the problem.
(III) Right to Deletion
You and your child can delete the relevant personal information of the child in the child APP, such as video viewing history, search history, download history, and collection history. However, please note that if you and your child delete or request us to delete specific personal information of the child (such as a registered account), you may be unable to continue to use all or part of our products and/or services.
In the following circumstances, you or your child may directly request us to delete your child’s personal information. We will promptly take measures to delete your child’s personal information after completing identity verification and addressing any issues, including:
1. We collect, store, use, transfer, or disclose your child’s personal information in violation of laws and regulations or our agreement with you;
2. We collect, store, use, transfer, or disclose your child’s personal information beyond the scope of the purpose or the necessary period;
3. You withdraw your consent;
4. You or your child terminates your use of our children’s app by logging out of your account;
5. Other circumstances specified by laws and regulations.
(IV) Advance Notice of Product and/or Service Termination
We will continue to provide you with quality services. If, for special reasons, some or all of our products and/or services are forced to cease operations, we will notify you in advance by posting a prominent notice, sending you a push message, or by other means, and will cease collecting your child’s personal information and delete or anonymize your child’s personal information in our possession.
V. Our Rules for Storing and Protecting Children’s Personal Information
We store children’s personal information within the territory of the People’s Republic of China in accordance with laws and regulations. We retain children’s personal information only for the minimum period necessary to provide our products and services. After the above storage period, we will delete or anonymize the child’s personal information.
We have adopted multi-level protection measures such as security technical measures that meet industry standards (such as encryption) and supporting organizational structures and management systems to protect children’s personal information. At the same time, we follow
the principle of minimum authorization and set strict information access rights for staff to control the scope of knowledge of children’s personal information. We have also taken necessary technical measures to prevent illegal copying and downloading of children’s personal information. If you want to know more,
please refer to Chapter 6 of the ” Hula English Privacy Policy”.
VI. How to Contact Us
If you have any questions about the implementation of these rules or matters related to child privacy protection when using the children’s APP (including inquiries, complaints, reports, etc.), you can contact us at hi@mampod.com and we have dedicated personnel to handle the matter; you can also contact us through other feedback channels provided in Chapter 9 of the ” Hula English Privacy Policy”. We will do our best to provide you with a satisfactory solution.