This policy is only applicable to users of the LingoMate App released in Mainland China.

This policy is only applicable to LingoMate App related products and services.

Version Release Date: July 6, 2023

Effective Date: July 20, 2022

Your personal information security is of utmost importance to us. Feizhu Technology has always been committed to providing a safer internet environment for each user. We will collect and use your personal information in accordance with the "Cybersecurity Law of the People's Republic of China," "Personal Information Security Specification" (GB/T 35273-2020), and other relevant laws and technical standards, to help us provide you with better quality products and/or services. We are committed to maintaining your trust in us, adhering to the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimal necessity, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency. The "LingoMate Privacy Protection Guidelines" (hereinafter referred to as "this Guide") will present in a more transparent manner how we collect and use your personal information, as well as your control rights over personal information. We promise to keep your personal information and other data strictly confidential and handle your personal information strictly in accordance with the content described in this Guide. We will collect, use, store, share, and transfer your personal information based on your consent and other legal bases that allow us to process your personal information.

Here are the key points of this Guide:

To help you register and use our products or services, we may collect personal information related to the provision of services, and you have the right to refuse or withdraw authorization;

You can access, correct, and delete your personal information. Change the scope of your authorized consent, cancel your account, and we provide ways for you to exercise these rights.

We have adopted technical measures and data security measures that are standard in the internet industry to protect the security of your personal information.

Unless we obtain your consent again, we will not use your personal information for purposes not stated in this Guide.

If you have any questions about this Guide, you can further contact and consult with us.

Please ensure that you are over 18 years of age; if you are a minor under 18 years of age, you should read this Guide and the "LingoMate Children's Privacy Policy" in the company of a guardian before using our products and/or services, and ensure that you have obtained the consent of your guardian.

For better protection of your personal information, we recommend that you read and understand this Guide carefully and completely before using our products or services.

Contents

Introduction

Legal Basis for Our Processing of Personal Information

How We Collect and Use Your Personal Information

How We Share, Transfer, and Publicly Disclose Your Personal Information

How We Protect Your Personal Information

Your Rights to Manage Personal Information

Our Notifications

How We Use Cookies and Similar Technologies

Storage of Your Personal Information

How We Process Personal Information of Minors

How to Update This Guide

How to Contact Us

Dispute Resolution

Glossary

Introduction

This Guide is only for the use of LingoMate App products and services provided by Hangzhou Feizhu Technology Co., Ltd. and its affiliates (hereinafter referred to as "we"). Our address is: Room 908, Building 2, Jiangling Road 567, Xixing Street, Binjiang District, Hangzhou City, Zhejiang Province.

[Special Note]

Please read and fully understand this Guide before using our various products and/or services. We have highlighted key content in bold, and we hope you pay special attention to it. Once you use or continue to use Feizhu Technology products/services, it indicates that you agree to us processing your related information according to this Guide. If you have any questions about this Guide, you can contact us through the "How to Contact Us" section in this Guide.

To facilitate your understanding of the relevant concepts in this Guide, we have underlined proprietary names and provided a detailed introduction in section 15 "Glossary" of this Guide. The terms in this Guide marked with an "*" in the upper right corner represent sensitive information collected by Feizhu Technology, and we provide enhanced prompts to you.

We may revise this Guide from time to time. When changes are made to this Guide, we will display the updated content to you in the form of notifications or pop-ups after the version update.

Please note that only after you confirm your agreement to the changes will we collect, use, process, and store your personal information in accordance with the updated "LingoMate Privacy Protection Guidelines"; you may choose to disagree, but this may result in your inability to fully use the LingoMate App's products and services.

Legal Basis for LingoMate Processing Personal Information

If you are a user in Mainland China of the People's Republic of China, we will collect and use your personal information in accordance with the "Cybersecurity Law of the People's Republic of China," "Personal Information Security Specification" (GB/T 35273-2020), and other relevant laws and regulations to provide you with LingoMate App's products and services. We usually only collect your personal information with your consent. In some cases, we may collect personal information based on legal obligations or the necessity to fulfill contracts, or we may need personal information to protect your or other people's vital interests.

How We Collect and Use Your Personal Information

We will follow the principles of legality, legitimacy, and necessity, for the purposes stated in this Guide, to collect and use your personal information that you actively provide or generate during the use of Feizhu Technology products and/or services. If we want to use your personal information for other purposes not stated in this Guide, or use the personal information collected for specific purposes for other purposes, we will inform you in a reasonable manner and seek your consent again before using it.

We will obtain your personal information through the following channels:

3.1 Registering an Account

3.1.1 When you register and log in to a LingoMate account, you need to provide us with the following information: account name (if any), avatar (if any), and mobile phone number (for real-name authentication). After providing the above information and agreeing to this Guide, you can use LingoMate's core business functions, including browsing content within the App. If you choose not to provide the necessary information for core business functions or to use certain functions, we will not be able to provide you with those functions.

3.1.2 When you register a LingoMate account, we recommend you provide your mobile phone number for real-name authentication. If you refuse to provide your mobile phone number for real-name authentication, you will not be able to use core business functions.

3.1.3 We may indirectly obtain your personal information from third parties

A. When you use a third-party account (WeChat, Apple) to log in to LingoMate, you can choose to authorize LingoMate to read and obtain your public information (including nickname, avatar) registered, published, or recorded on the third-party platform, in compliance with relevant laws and regulations.

B. LingoMate needs your authorization to obtain the above information from third parties in order to remember your login identity as a LingoMate user and provide you with better quality products and/or services. We will only collect and use your personal information within the scope of your authorized consent. After you use a third-party account to register or log in, your third-party account will be bound to your LingoMate account. You can also choose to close and cancel the account binding.

Please note that if you upload or publish information in publicly visible areas of the LingoMate service, and you publicly disclose your information in response to other people's uploads or publications, that information may be collected and used by others. If you find that someone is improperly collecting or using your information, you can contact us through the feedback channels listed in the "How to Contact Us" section of this policy.

 

3.2 Core Business Functions for Providing Products and/or Services

To realize the core business functions of LingoMate, we may need to collect your personal information.

You understand and agree that we aim to offer you comprehensive products and services, which requires us to continuously improve them. This means that as our products and services evolve, expand, and upgrade, we may often introduce new services or business functions, or reclassify existing ones, and may need to collect new personal information or change the purpose or method of using personal information. Please note, if we intend to use your personal information for purposes not specified in this guide or collect additional personal information not mentioned herein, we will seek your consent again through page prompts, interactive processes, website announcements, or other methods. Once you consent, such additional uses will be considered part of this guide, and the additional information will be subject to this guide. If you have any questions during this process, you can contact us through the feedback channels listed in "How to Contact Us."

3.2.1 Browsing, Functionality.

Permission Function Description: Collection of device information, model, unique device identifier, operating system, telecom operator software and hardware information when you use the LingoMate App.

Usage Scenarios and Purposes: To provide the optimal display of information.

Moreover, during your use of browsing and bookmarking functions, we will automatically collect detailed information about your use of the LingoMate App and save it as network logs. This includes but is not limited to the search keywords you enter, links you click, voiceover works you browse and post, images you upload, transaction information, language used, date and time of access, and your browsing records of videos, operating system, software version, login IP information.

3.2.2 Recording/Microphone Function.

Permission Function Description: Audio recording using a microphone.

Usage Scenarios and Purposes: To assist in completing video dubbing, follow-ups, and feedback-related functions.

3.2.3 Album and Camera Functions.

Permission Function Description: Setting profile pictures, background images, and posting pictures in chats.

Usage Scenarios and Purposes: To change your profile picture, select images from your album to replace. Adding album pictures or camera photos in feedback can provide more direct problem reporting.

3.2.4 WLAN Activation.

Usage Function Description: Use of WIFI data.

Usage Scenarios and Purposes: You can choose to activate WLAN when WIFI is available to use the product under WIFI, saving your data usage.

3.2.5 Collection of IMEI and MAC Address.

Usage Function Description: Use of device information (Unique Device Identifier (IMEI), device MAC address).

Usage Scenarios and Purposes: For identity verification, transaction risk judgment, installation list.

3.2.6 Installation List.

Usage Function Description: Works can be shared to WeChat Mini Programs.

Usage Scenarios and Purposes: Before sharing, it checks if WeChat is installed; if not, it prompts to install WeChat first. Similar prompts for sharing to other third-party applications.

3.3 Maintaining Account Security, Ensuring the Normal Operation of Services, and Optimizing Service Experience.

During your use of our services, to identify abnormal account states, link product compatibility, provide basic services such as browsing and searching, ensure the normal operation of services, and optimize the service experience, we may directly or indirectly collect, store information about your use of features and methods of use, and associate these pieces of information. These include:

(a) Log Permissions: When you use our services, we may automatically (including running in the background) collect detailed usage of our services, saved as network logs. This includes your login account, search queries, IP address, browser type, telecom operator, network environment, language used, date and time of access, your webpage browsing records, push notification opening records, duration of stay, refresh records, posting records, followings, subscriptions, bookmarks, and shares.

(b) Device Permissions: Based on the software you have installed and specific permissions you have explicitly granted, we accept and record (including in a background running state) information related to your device used: device information, operating system and version, client version, device resolution, package name, device settings, device identifiers (IMEI/AndroidID/OPEN UDID/GUID/MAC OAID/IDFA/SIM card IMSI information) and hardware feature information, device location-related information (IP address). To collect the above personal device information, we will request access to your device-related permissions, including device information permission, location permission, etc.

Please note, standalone device information and log information cannot identify specific natural persons. If we combine such non-personal information with other information to identify specific natural persons, or if we use it in combination with personal information, then during the combination period, this type of non-personal information will be regarded as personal information. Unless we obtain your authorization or there are other provisions by laws and regulations, we will anonymize and de-identify this type of personal information. During the combination period, this information will be processed and protected as your personal information in accordance with this guide.

3.4 Providing Additional Business Functions for LingoMate Products and/or Services

To provide you with higher quality products and services, we may need to collect the following information. If you refuse to provide the information below, it will not affect your normal use of core business functions, but we cannot provide you with certain specific functions and services.

3.4.1 Customer Service.

When you make complaints, appeals, or inquiries to LingoMate, to facilitate contact with you or help you resolve issues, we may need you to provide personal information such as your name, phone number, email address, and other contact details. If you refuse to provide the above information, we may not be able to provide timely feedback on the results of complaints, appeals, or inquiries.

3.4.2 Payment Function.

You can purchase memberships in LingoMate. During the use of this function, payment may be required. During the payment process, we will complete payment verification and payment through the SDK of your third-party payment account (such as Alipay account, Apple Pay account, and WeChat account, etc.).

Your relevant information is used for paying taxes on your behalf.

3.5 Sensitive Information

Before providing any personal information that constitutes sensitive information to LingoMate, please consider carefully whether such provision is appropriate and agree that your sensitive personal information can be processed in accordance with the purposes and methods described in this guide. We will collect and use your sensitive information to realize functions related to LingoMate's business after obtaining your consent, and allow you to make different choices regarding the collection and use of these sensitive information. However, refusing to use this information will affect your use of related functions.

3.6 Exceptions to Obtaining Authorization Consent

According to the provisions of relevant laws and regulations, in the following circumstances, we may collect and use some necessary personal information without obtaining your authorization consent:

(a) Directly related to national security, national defense security;

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

(c) Directly related to criminal investigation, prosecution, trial, and judgment enforcement;

(d) For protecting major legal rights and interests such as life and property of you or others when it is difficult to obtain consent from the person;

(e) Personal information that you disclose to the public on your own;

(f) Collecting your personal information from legally publicly disclosed information, such as from legal news reports, government information disclosure channels;

(g) Necessary for signing and fulfilling contracts as required by you;

(h) Necessary for maintaining the safe and stable operation of LingoMate's products and/or services, such as discovering, dealing with faults of products or services;

(i) Other circumstances stipulated by laws and regulations.

3.7 If you have any questions about the legal basis for our collection and use of your personal information, or if you need further information, please contact us using the contact information provided in the "How to Contact Us" section.

4. How We Share, Transfer, and Publicly Disclose Your Personal Information

4.1 Sharing Your Personal Information

(i) Delegated Processing

Some specific sections or functions of this business feature are provided by external suppliers. We will hire service providers to assist us in providing customer support.

LingoMate may access or link to social media or other services provided by third parties (including websites or other forms of service), which include:

(a) You can use the "Share" button to share certain content from LingoMate to third parties. Or, you can use third-party services to log into LingoMate. These features may collect your information (including your log information) and may install cookies on your device to enable the normal functioning of the above features;

(b) Providing links through advertisements or other methods in our service, enabling you to access third-party service websites;

(c) Other forms of third-party access.

(ii) Sharing

We will not share your personal information with any companies, organizations, or individuals outside of our company, unless we have obtained your explicit consent. Currently, to achieve the purposes declared in this guideline, we integrate third-party services or other similar applications (in the form of embedded codes or plugins) to provide better customer service and user experience. We will seek your consent for sharing personal information in the following situations.

Currently, our authorized partners include the following types:

(a) For advertising and analysis services, including display, advertising statistics, and monitoring;

(b) For message push functions, including mobile manufacturer PUSH notifications, specific time reminders;

(c) For payment-related services, including order payments, transaction behavior verification, income settlement, and summary statistics of payment information;

(d) For collecting device location permissions and device information and logs with your consent;

(e) For third-party authorization services, including third-party account login and sharing content to third-party products;

(f) To support product functions, including video playback, intelligent customer service, voice recognition, content storage, intelligent scoring;

(g) To optimize product performance, including improving hardware networking capabilities, reducing server costs, and hot-fixing functions;

(h) For account security and product reinforcement services, including network monitoring and domain resolution.

For companies, organizations, and individuals who are entrusted to process personal information on our behalf, we will sign strict confidentiality agreements with them and conduct strict security monitoring of their information software tools development kits (SDKs) and application programming interfaces (APIs) to ensure data security. They are required to process personal information according to our instructions, this guideline, and any other relevant confidentiality and security measures. For detailed information on the third-party SDKs that LingoMate integrates, the types of personal information collected, and user information, please visit [https://chataiadmin.qupeiyin.com/home/Protocols/detail/id/15].

Third-party social media, third-party payments, or other third-party services are operated by the relevant third parties. Your use of these third-party services (including any information you provide to these third parties) is subject to the service terms and information protection statements of the third parties (not this guideline). You need to carefully read their terms. This guideline only applies to the personal information we collect and does not apply to services provided by any third parties or their information usage rules. If you find risks in these third-party services, we recommend that you cease related operations to protect your legal rights and contact us promptly.

4.2 Transfer

We will not transfer your personal information to any company, organization, or individual unless we have obtained your explicit consent. In the event of a merger, acquisition, or bankruptcy liquidation that may involve the transfer of personal information, we will require the new entity holding your personal information to continue to be bound by this guideline. If there is any change in the collection and processing methods of personal information agreed upon in this guideline, the company or organization will re-seek your consent.

4.3 Public Disclosure

We will not publicly disclose your personal information unless we have obtained your explicit consent.

In cases of legal requirements, legal procedures, litigation, or mandatory requirements from government authorities, we may disclose your personal information to authorized agencies. We ensure that in such cases, we will require the requesting party to provide corresponding valid legal documents and adopt security protection measures for the disclosed information that comply with legal and industry standards.

(a) Prior explicit authorization or consent: After obtaining your explicit consent, we will share your personal information with others;

(b) Sharing under legal circumstances: Your personal information may be shared according to applicable laws and regulations, legal procedures, government mandates, or judicial rulings;

(c) In the extent permitted by law, it is necessary to provide your personal information to third parties to protect the interests, property, or safety of LingoMate, its users, or the public from harm;

(d) Sharing with our affiliated companies: Your personal information may be shared among our affiliated companies. We will only share necessary personal information, and such sharing is bound by the purposes declared in this guideline. If affiliated companies change the processing purpose of personal information, they will seek your authorization and consent again;

(e) Sharing with authorized partners: To provide you with higher quality and more comprehensive products and services, some of our services are provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience (for example, when LingoMate sends you gifts, we need to share your personal information with logistics service providers to arrange delivery). We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share personal information necessary for providing services. At the same time, we will sign strict confidentiality agreements with our partners, requiring them to process your personal information according to our instructions, this guideline, and any other relevant confidentiality and security measures. Our partners are not allowed to use the shared personal information for any other purposes. If you refuse our partners to collect personal information necessary for providing services, you may not be able to use the third-party service in LingoMate.

4.4 Exceptions to Authorization and Consent for Sharing, Transferring, and Publicly Disclosing Personal Information

According to relevant laws and regulations, in the following situations, we may share, transfer, or publicly disclose your personal information without seeking your authorization and consent:

(a) Related to national security and national defense security;

(b) Related to public safety, public health, and major public interests;

(c) Directly related to criminal investigation, prosecution, trial, and judgment execution;

(d) For protecting the significant lawful rights and interests of you or other individuals when it is difficult to obtain consent from the person concerned;

(e) The personal information that you have made public on your own;

(f) The personal information collected from legally publicly disclosed information, such as legal news reports and government information disclosure channels;

(g) Other circumstances stipulated by laws and regulations.

According to legal provisions, sharing or transferring de-identified personal information, ensuring that the data recipient cannot restore and re-identify the subject of personal information, does not constitute external sharing, transferring, or public disclosure of personal information. There is no need to notify you separately and obtain your consent for the storage and processing of such data.

5. How We Protect Your Personal Information

Your personal information security is of utmost importance to us. We strictly adhere to relevant laws and regulations and adopt industry-recognized reasonable and feasible measures to protect your personal information, preventing unauthorized access, disclosure, use, modification, damage, or loss of information.

5.1 Technical and Data Security Measures

We strive to implement various physical, electronic, and administrative security measures that meet industry standards to protect the security of your personal information. We actively establish data classification systems, data security management norms, and data security development standards to regulate the storage and use of personal information, ensuring that we do not collect personal information unrelated to the services we provide.

5.2 We only allow employees who need to know this information to access it and have established strict access control, application mechanisms, and monitoring systems for this purpose. We also require all personnel who may come into contact with your information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may lead to legal liability or termination of the cooperation relationship with LingoMate.

5.3 The Internet is not 100% secure, but we will do our utmost to ensure the security of any information you send to us. We implement comprehensive security control over data safety through confidentiality agreements with those who access the information, as well as monitoring and audit mechanisms, to prevent unauthorized access, public disclosure, use, modification, damage, or loss of your personal information.

We use industry-standard security measures to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonably practicable measures to protect your personal information (data exchanged between your mobile phone and LingoMate, such as bank account information, is encrypted). We also conduct safety and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

According to the provisions of the "Information Security Level Protection Management Measures," Fei Zhu Technology has obtained a level three information security level protection filing certificate.

5.4 Handling of Security Incidents

We will do our best to ensure the security of any information you send to us. However, please understand that due to technical limitations and various malicious methods that may exist in the Internet industry, it is not always possible to guarantee 100% security of information. You should be aware that the systems and communication networks used to access our services may have issues beyond our control.

To prevent the occurrence of security incidents, we have established proper early warning mechanisms and emergency plans. In the unfortunate event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security event, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you, and we will immediately initiate emergency plans to minimize losses. We will inform you of the event-related situation by phone or notification in a timely manner. If it is difficult to inform users individually, we will use reasonable and effective methods to make announcements.

At the same time, we will also proactively report the handling of personal information security events according to the requirements of regulatory authorities and closely cooperate with government agencies.

6. Your Rights to Manage Personal Information

We encourage you to update and modify your information to make it more accurate and effective. We will adopt appropriate operation settings, guidelines, or provide channels for submitting applications to ensure that you can access, update, and correct your information or other information provided when using LingoMate. If you wish to query, modify, or delete some of your information, please log in to LingoMate to perform relevant operations, or contact us using the contact information provided in this guideline.

6.1 Accessing and Correcting Your Personal Information

You can query and modify your avatar, nickname, etc., through "Me" - "Profile Modification".

6.2 Account Cancellation

We provide the function to cancel your account and delete your personal information. Under the conditions that comply with policy agreements and relevant national laws and regulations, you can choose to delete your personal information published on the LingoMate platform. You can cancel your personal information on the (Me - Settings - Account Cancellation) page or by calling the LingoMate 400 phone number [400-060-1966].

After submitting the cancellation request, if there are still funds in your account, you can contact customer service to cancel the account within 15 days. If there are no funds in your account, we will cancel the account immediately, stop using and delete or anonymize your personal information, and we will no longer be able to continue providing services to you.

If you have any questions about the cancellation process, you can make a complaint and provide feedback through the LingoMate 400 phone number [400-060-1966]. We will handle related complaints within 15 working days.

6.3 In the following situations, you can request us to delete your personal information:

(a) If our handling of personal information violates laws and regulations;

(b) If we collect and use your personal information without your consent;

(c) If our handling of personal information violates the agreement with you;

(d) If you have cancelled your LingoMate account;

(e) If we terminate services and operations.

If you have any questions about deleting personal information, you can make a complaint and provide feedback through the LingoMate 400 phone number [400-060-1966]. We will handle related complaints within 15 working days.

6.4 Changing the Scope of Your Authorization and Consent or Withdrawing Your Authorization

You can withdraw all authorizations for us to collect your personal information and the authorization of the privacy agreement by deleting the App or through "Me - Settings - Account Cancellation" in the App, or by contacting our manual customer service via the LingoMate 400 phone number [400-060-1966]. After you cancel your account, we will immediately delete your personal information or authorization permissions. When reopening, you will need to re-obtain your authorization. Please understand that each business function requires some basic personal information to be completed. When you withdraw your authorization, we will no longer be able to continue providing you with services corresponding to the withdrawn authorization, nor will we process your corresponding information. However, your decision to withdraw authorization will not affect information processing previously carried out based on your authorization. Note: Withdrawing consent to collect personal information is equivalent to withdrawing authorization of the "Privacy Policy".

You can contact us via the customer service phone number [400-060-1966] to assist you in cancelling your account, changing the scope of your authorization and consent, or withdrawing your authorization.

In the course of providing services, we may need you to enable certain device permissions, such as notifications, storage, album, and microphone access permissions. You can also choose to close part or all of these permissions in "Me - Settings" in the App, thereby refusing us to collect your corresponding personal information. Note: In different devices, the display and closing methods of permissions may vary, please refer to the explanations or guidelines of the device and system developers.

6.5 Obtaining a Copy of Your Personal Information

You have the right to obtain a copy of your personal information. If you need to obtain a copy of your personal information that we have collected, you can call our manual customer service hotline [400-060-1966]. The customer service will verify your personal information, and after confirming your personal information subject (name, phone number, LingoMate nickname, LingoMate ID number), they will submit a copy of your personal information to you via email. In compliance with relevant legal provisions and technical feasibility, we will provide you with a copy of your personal information upon your request.

6.6 Responding to Your Above Requests

You can submit any questions, suggestions, opinions, and complaints to our customer service by calling the hotline [400-060-1966]. For security, we will process them after necessary identity verification and will respond within no more than 15 working days or the time limit stipulated by laws and regulations. We generally do not charge fees for your reasonable requests. However, in accordance with relevant laws, regulations, and national standards, in the following situations, we may not be able to respond to your requests:

(a) Directly related to national security and national defense security;

(b) Related to public safety, public health, and major public interests;

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

(d) There is sufficient evidence to show that you have subjective malice or abuse of rights;

(e) It is difficult to obtain your consent for maintaining your or other individuals' significant lawful rights and interests;

(f) Responding to your request will cause serious harm to the lawful rights and interests of other personal information subjects or other individuals or organizations;

(g) Involving trade secrets.

7. Notifications We Issue

7.1 When you use LingoMate services, we may use your personal information to send message notifications to your device. You can choose whether to receive our system messages through the "Messages" option.

7.2 Announcements Related to Services

We may occasionally issue announcements related to services as necessary (for example, when we temporarily suspend LingoMate services for maintenance). You cannot cancel these service-related announcements that are not promotional in nature.

8. How We Use Cookies and Similar Technologies

Cookies and device identifier technologies are commonly used on the Internet. When you use LingoMate and related services, we may use these technologies to send one or more cookies or anonymous identifiers to your device to collect and identify information when you visit and use our product. We promise not to use cookies for any purposes other than those described in this guideline. We use cookies and similar technologies mainly for the following functions or services:

8.1 Ensuring the Security and Efficient Operation of Products and Services

We may set authentication and security cookies or anonymous identifiers to confirm whether you have safely logged into services or encountered theft, fraud, or other illegal activities. These technologies also help us improve service efficiency and enhance login and response speeds.

8.2 Helping You Gain a More Effortless Access Experience

Using these technologies can save you from repeatedly filling in personal information and inputting search content (example: recording searches, form filling).

9. Storage of Your Personal Information

We store information obtained within the territory of the People's Republic of China within the territory of the People's Republic of China. In the event of cross-border data transmission, we will inform you separately about the purpose and recipient of the data outflow through a pop-up or email and obtain your authorization and consent. We will ensure that the data recipient has sufficient data protection capabilities to protect your personal information.

We only retain your personal information for the shortest time necessary to achieve our purposes:

"Cybersecurity Law" stipulates that log information must be retained for no less than six months;

"E-commerce Law" stipulates that transaction information should be retained for no less than three years from the date of transaction completion;

"Internet Information Management Measures" stipulate retention for no less than 60 days and the method for handling beyond the period.

After exceeding the above personal information retention period, we will anonymize the personal information.

If we stop operations due to poor management or other reasons, we will immediately stop collecting your personal information and delete the collected personal information. We will announce this situation on the App or convey it to each user through private messages and other reasonable methods.

10. How We Handle the Personal Information of Minors

10.1 LingoMate's services cover both minors and adults. If you are a minor under the age of 14, you should read this guideline with your guardian and ensure that you use our products and provide us with your information only after obtaining your guardian's consent. We will protect minors' information in accordance with relevant national laws and regulations.

10.2 If your guardian disagrees with you using our services or providing us with information according to this guideline, please immediately stop using our services and inform us promptly.

10.3 For personal information of minors collected with the consent of parents or legal guardians, we will only use or disclose this information when it is legally permitted, explicitly consented to by parents or guardians, or necessary to protect minors.

10.4 If you are the guardian of a minor, and you have any questions about the minor's use of our services or the information they provide to us, please contact us in a timely manner. We will protect the confidentiality and security of minors' user information in accordance with relevant national laws and regulations and the provisions of this guideline. If we find that we have collected personal information of minors without verifiable consent from parents or legal guardians, we will delete the relevant data as soon as possible.

11. How to Update and Modify This Guideline

11.1 LingoMate reserves the right to update or modify this guideline from time to time.

11.2 Without your explicit consent, we will not reduce your rights according to this guideline. We will notify you through App notifications, pop-ups, or other reasonable means, so you can timely understand any changes made to this guideline.

11.3 For significant changes, depending on the situation, we may also provide more prominent notices, explaining the specific changes to this guideline. Significant changes include, but are not limited to:

(a) Major changes in our service model, such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;

(b) Major changes in our ownership structure or organizational structure, such as business adjustments, bankruptcies, and acquisitions leading to changes in ownership;

(c) Major changes in the main objects of personal information sharing, transfer, or public disclosure;

(d) Significant changes in your rights to participate in personal information processing and how to exercise these rights;

(e) Changes in the department responsible for handling personal information security, contact methods, and complaint channels;

(f) When the personal information security impact assessment report indicates a high risk.

11.4 If you disagree with the modified privacy protection guideline, you have the right and should immediately stop using LingoMate's services. If you continue to use LingoMate's services, it is considered that you accept the modifications made by LingoMate to the terms of this guideline.

12. How to Contact Us

12.1 If you have any questions about this guideline, you can contact us through the LingoMate 400 phone number [400-060-1966] or via WeChat [qupeiyin999]. We will respond to you as soon as possible.

12.2 If you have complaints, suggestions, or questions about personal information protection, you can also contact the responsible person, Tan Hongping, at 18692041339. Or you can mail to the following address:

Hangzhou Fei Zhu Technology Co., Ltd.

Room 908, Building 2, No. 567 Jiangling Road, Xixing Street, Binjiang District, Hangzhou City, Zhejiang Province, Legal Department (Receiver).

We will review the issues involved as soon as possible.

12.3 Generally, we will reply within fifteen working days after receiving your questions, opinions, or suggestions and verifying your user identity. If you are not satisfied with our response and we still refuse to improve after your feedback, you can also complain to the consumer rights protection department or sue in a court with jurisdiction.

13. Dispute Resolution

13.1 Any disputes arising from this guideline or our handling of your personal information can be sued in the People's Court of Binjiang District, Hangzhou City.

13.2 If you believe that our handling of personal information has harmed your legal rights and interests, you may also reflect the issue to relevant government departments.

14. Definitions of Terms

The terms used in this guideline are defined in the general sense as follows:

14.1 Personal Information: Personal information refers to various types of information that can be recorded electronically or in other ways, capable of identifying the personal identity of a natural person alone or in combination with other information. This includes, but is not limited to, a natural person's name, date of birth, address, and telephone number.

14.2 Sensitive Personal Information: Sensitive personal information refers to personal information that, once leaked, illegally provided, or misused, may endanger personal and property safety, and is very likely to cause damage to personal reputation, physical and mental health, or discriminatory treatment. Sensitive personal information includes identity card numbers, bank account numbers, communication content, and health and physiological information.

14.3 Device: A device refers to an apparatus that can be used to access LingoMate products, such as a tablet computer or smartphone.

14.4 Unique Device Identifier: A unique device identifier (exclusive ID, IMEI number, or UUID) refers to a string of characters embedded in the device by the manufacturer, which can be used to uniquely identify the device.

14.5 IP Address: Every internet-connected device is assigned a number, known as an Internet Protocol (IP) address. These numbers are usually assigned based on geographic areas. IP addresses can typically be used to identify the location of a device when it connects to the internet.

14.6 SSL: SSL is a security protocol implemented on the Transmission Control Protocol/Internet Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all through the use of public key and symmetric key technologies to achieve confidentiality of information.

14.7 Affiliated Company: Refers to any company or institution that is now or in the future controlled by, under control of, or in common control with one party. "Control" refers to the ability to directly or indirectly influence the management of the mentioned company, whether through ownership, voting shares, contracts, or other legally recognized methods.

14.8 Non-Personal Identity Information: Recorded information related to users that cannot directly or indirectly identify your identity, including personal information provided through de-identification, anonymization, or under a pseudonym.

14.9 De-identification: Refers to the process of technically processing personal information so that it cannot identify the subject of personal information without the aid of additional information.

14.10 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.

14.11 Server Log: Like most websites, our servers automatically record the requests you make when accessing the App. These "server logs" typically include your network request, internet protocol address, browser type, browser language, date and time of request.