Privacy Policy

Update date: February 23, 2024

Effective date: February 23, 2024

introduction

PASS HSK (hereinafter referred to as " we " ) respects and protects the personal information and privacy security of all PASS HSK users. We are committed to maintaining your trust in us and abiding by 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 ensuring security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise that we will take corresponding security protection measures to protect your personal information in accordance with mature security standards in the industry.

This policy is closely related to your use of our products and/or services. When you download, install, launch, browse, register, log in, and use our products and/or services (hereinafter collectively referred to as " using our products and/or services") " ), we will process and protect your personal information in accordance with the provisions of this policy. We try our best to explain the technical terms involved in this policy to you in a concise way to facilitate your understanding. We have used bold fonts to distinguish the clauses in this policy that may have a significant relationship with your rights and interests, so please read them carefully.

PASS HSK specifically draws the attention of minors under the age of 18 (especially children under the age of fourteen) and their guardians. We have clarified the special section on the protection of minors (in bold), please read it carefully.

Please read and fully understand this policy before using/continuing to use our products and services, and make appropriate choices according to the guidelines of this policy when necessary. If you do not agree with the contents of this policy, it may cause our products and/or services to fail to operate properly, or fail to achieve the service effects we intend to achieve. You should immediately stop accessing/using our products and/or services. Your use or continued use of the products and/or services we provide indicates that you fully understand and agree to the entire content of this Privacy Policy (including updated versions).

About Us

The operator of PASS HSK is Hangzhou Kika Education Technology Co., Ltd.

The registered address is Room 503, Building 1, No. 606 Qiuyi Road, Changhe Street, Binjiang District, Hangzhou City, Zhejiang Province .

This policy will help you understand the following:

• 1) How we collect and use your personal information
• 2) How we share, transfer and publicly disclose your personal information
• 3) How we store and protect your personal information
• 4) How you manage your personal information
• 5) How do you cancel your account?
• 6) How we use cookies and other similar technologies
• 7) Protection of minors
• 8) How we update our privacy policy
• 9) How to contact us
• 10) other

• 1) How we collect and use your personal information

• 1. Become our registered user

PASS HSK supports email addresses and third-party login methods . If you choose the email address to register or log in , you need to provide us with your [ email address ] in order to provide you with verification code information . We collect this information to identify and verify your identity . When you choose Facebook , Apple When logging in with third-party accounts such as ID and WeChat, you agree that we will use Facebook , Apple ID , WeChat and other third parties obtain the information you authorize to share (including mobile phone number, nickname, avatar, friend list, etc.), and you agree to combine your third-party account with your PASS HSK product account binding allows you to log in directly through a third-party account and use PASS HSK products, and use this account to synchronize data between different devices . We will use the personal information you authorize us to share in accordance with our agreements with third parties and in compliance with relevant laws and regulations . If you refuse to agree to PASS HSK obtains the information you authorize sharing from third parties . You will not be able to share it through Facebook , Apple Register an account and log in through a third-party account such as ID or WeChat , and data synchronization cannot be achieved with the help of this third-party account . At the same time, in order to better experience our functions, you need to fill out the [Questionnaire] when entering the APP. The survey content includes [Nationality Information], [Target Exam Level] and [Registration Time], etc.

After completing the account registration , you can also choose to fill in or change your avatar, name, gender, age, and test date to complete your information according to your own needs. However, if you do not provide such information, it will not affect your use of this product and related services. .

The above information you provide will be used by us during your use of the services we provide. When you voluntarily cancel your account, we will delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations.

• 2. To provide you with our products and services

The functions of this product include "pre-exam study", " full simulation ", "exam focus", "personal center" and other main business functions.

We collect and use your information for the purposes described below based on the principles of lawfulness, legitimacy and necessity.

• 2.1. Device Information

We will accept and record information related to the device you use based on the specific permissions you grant during software installation and use, including : IP address , device name, device model, hardware serial number , device identification code, operating system and application. Version, language settings, mobile terminal random storage memory , mobile network information , network access methods , and network quality data . We will use your device information for identity verification, security prevention, archive backup, and customer security services to improve the security of products and services.

• 2.2. Log information

When you use all our business functions, the system will automatically collect certain information through cookies or other means and save it as relevant web logs. Such information includes: detailed usage when using this product or service, such as the address of the page you visit, browser type and settings , operator, language used, date and time of access, device crashes, system activity, accessed Web page records and user-triggered event statistics, etc. This type of information will help us statistically analyze users' safe online behavior.

• 2.3. System permission call

In order to provide services, we will call some of your system permissions. Below we list the business functions corresponding to the requested permissions, the purpose of the call and the timing of the request. You can choose to turn off all of the permissions in the system settings. After turning off, we will not be able to collect the corresponding personal information through these permissions. For the specific operation method of system permissions, please refer to the instructions provided by your device system developer.

1) System permissions : Network

Corresponding business : Internet access function

Functional scenario description : used for network downloading or synchronizing application data and updating application configurations

Whether it can be closed : Yes , after closing, the APP content cannot be read and updated in real time , and it cannot be used normally.

• 2）System permissions : Storage ( photo albums , media and other files )

Corresponding business : feedback , information caching

Functional scene description : a . When using the "Feedback" function , read the content of the album ; b. Log information recording and information caching

Whether it can be turned off : Yes , turning it off will only affect the corresponding functions and will not affect other functions of the APP.

• 3. Provide you with security services

We will use your information for identity verification, security, archival backup, and customer security services to improve the security of products and services. When our system fails, we will record and analyze the information generated when the system fails and optimize related services.

• 4. Circumstances in which third-party SDK collects information

Some of our additional business services or functions require the use of software service toolkits ( SDK for short ) provided by third-party service providers , or the third-party SDK directly provides related services. The SDK technical service provider will obtain the corresponding permissions and information based on the need to provide you with functions or services. Please read our following SDK list in detail to understand our specific integrated SDK name, SDK technical service provider, and SDK application scenarios (i.e. SDK Type) and the permissions and personal information types obtained by the SDK.

• 1）MobTech ShareSDK :

Operator: Shanghai Zhangzhitao Information Technology Co., Ltd.

Purpose of use: social sharing, third-party login

Usage scenario: Empowering apps with social sharing capabilities

Shared information name: system operation information, network status information, iOS advertising identifier ( IDFA ), International Mobile Equipment Identity ( IMEI ), anonymous device identifier (OAID) , International Mobile Subscriber Identity ( IMSI ), application list information, Base station information, social platform OpenID , geographical location

Sharing method: SDK native collection

Third party personal information processing rules: www.mob.com/about/policy1

• 2）Firebase Crashlytics:

Operator: Google LLC

Purpose of use: Collect crash and error logs of the app

Use case: When a crash or error occurs within the app

Shared information names:

RFC-4122 UUID (to facilitate removal of duplicate crash data)

Crashlytics Installation UUID

Firebase Installation ID (FID)

Firebase Session ID (random UUID generated by the system for marking session events)

Timestamp of the crash occurrence

Application's package identifier and full version number

Device's operating system name and version number

Boolean value indicating whether the device is jailbroken/rooted

Device's model name, CPU architecture, RAM, and disk space

uint64 instruction pointers for each frame of each thread currently running

Plain text method or function name containing each instruction pointer (if provided at runtime)

Plain text class name and message value of exceptions (if exceptions are thrown)

Name and integer code of fatal signals (if fatal signals are emitted)

Name, UUID, byte size, and uint64 base address in RAM when loaded for each binary image loaded into the app

Boolean value indicating whether the app was running in the background when it crashed

Integer value indicating the screen orientation at the time of the crash

Boolean value indicating whether the device's proximity sensor was triggered

Sharing method: Native SDK collection

Third party personal information processing rules: https://firebase.google.com/support/privacy 

The collection and processing of information by the above-mentioned service providers are subject to their own privacy terms and do not apply to this policy. However, we will also work hard to review the business access qualifications of the third party and strive to require the legal compliance and security of such service providers. In order to protect your information security to the greatest extent, we strongly recommend that you check the privacy terms of any third-party SDK services before using them. To protect your legitimate rights and interests, if you find that there are risks in this SDK or other similar applications, we recommend that you immediately terminate the relevant operations and contact us in a timely manner. When you click to agree to this privacy policy, you are deemed to have authorized and agreed to the SDK technical service provider to obtain and process your permissions and information in accordance with the above form. If you have any objections to this, you can give us feedback at service@tikajiaoyu.com.

• 5. Exceptions to prior authorization and consent

In accordance with relevant laws, regulations and national standards, we will collect and use your personal information in accordance with the law without your consent in the following situations:

• 1）Directly related to the National Security and Defense Security Administration;
• 2）Directly related to public safety, public health, and major public interests;
• 3）Directly related to criminal investigation, prosecution, trial and judgment execution;
• 4）To protect your or others' life, property and other major legitimate rights and interests but it is difficult to obtain your consent;
• 5）The personal information collected is disclosed to the public by you yourself;
• 6）Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
• 7）Necessary to enter into and perform a contract at your request;
• 8）Necessary to maintain the safe and stable operation of the services provided, such as: discovering and handling product or service failures;
• 9）Other situations specified by laws and regulations.

• 6. Additional information

When we want to use information for other purposes not specified in this policy, we will ask for your consent in advance.

When we want to use the information collected for a specific purpose for other purposes, we will ask for your consent in advance.

• 2) How we share, transfer and publicly disclose your personal information

• 1. Sharing of information
  • 1.1. We will not share your personal information with companies, organizations and individuals outside of us, except in the following circumstances:

• 1）Obtain your express consent or authorization in advance;
• 2）Sharing is necessary in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements;
• 3）Sharing with authorized partners: Only to achieve the purposes stated in this policy, some of our services will be provided jointly by us and authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and we will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose. Currently, our authorized partners include the following types:

• ①　Authorized partners for advertising and analysis services. Unless you give us your permission, we will not use your personally identifiable information (information that can identify you, such as name or email address, through which you can be contacted or identified) to provide advertising and analysis services. shared by partners. We provide these partners with information about the reach and effectiveness of their advertising without providing your personally identifiable information, or we aggregate the information so that it does not identify you personally.
• ②　Suppliers, service providers and other partners. We send information globally to our vendors, service providers and other partners who support our business, including providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of our advertising and services, and providing customer Serve or conduct academic research and investigation.

We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, requiring them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

• 2. transfer of information

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

• 2.1. Transfer with explicit consent : After obtaining your explicit consent, we will transfer your personal information to designated other parties within the scope of authorization;
• 2.2. When we undergo an acquisition, merger, reorganization, etc. that results in a change of entity, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this privacy policy. Otherwise, we will require the company, organization, or organization that holds your personal information to continue to be bound by this privacy policy. The organization will ask you for authorization again.

• 3. Disclosure of Information

We will only publicly disclose your personal information under the following circumstances :

• 3.1. After obtaining your explicit consent, we may publicly disclose the personal information you specify;
• 3.2. Disclosure based on law : We may publicly disclose your personal information when required by law, legal proceedings, litigation or government authorities.

• 3) How we store and protect your personal information

• 1. How we store information
  • 1.1. Where information is stored

We comply with the provisions of laws and regulations, and the information and materials collected about you will be stored on our servers in the People's Republic of China. Except for the following circumstances:

• 1）Laws and regulations are clearly stipulated;
• 2）Obtain your express authorization;
• 3）You conduct cross-border transactions and other personal proactive behaviors through the Internet.
  • 1.2. How long the information is stored

Generally speaking, we only retain your personal information for the minimum period necessary to fulfill the purpose. Personal information that identifies you personally and reflects related activities will be retained until the user logs off the account , unless the law requires or allows the retention of this information for a longer period. However, in the following circumstances, we need to change the storage time of personal information in order to comply with legal requirements :

• 1）To comply with applicable laws, regulations and other relevant provisions;
• 2）To comply with a court judgment, ruling or other legal process;
• 3）To comply with the requirements of relevant government agencies or legally authorized organizations;
• 4）We have reason to believe that we need to comply with relevant laws and regulations;
• 5）Reasonably necessary purposes to implement relevant service agreements or this policy, safeguard social and public interests, and protect the personal and property safety or other legitimate rights and interests of our customers, our products, other users or employees.

After you terminate your use of our products, we will stop collecting and using your information, unless otherwise provided by laws, regulations or regulatory authorities.

When our related services cease operations , we will notify you by means of push notifications and announcements, and delete or anonymize your personal information retained in the server within a reasonable period.

• 2. Data security measures
  • 2.1. We will adopt security protection measures that comply with industry standards, including establishing reasonable system specifications and security technologies to prevent your personal information from unauthorized access, use, modification, and avoid data damage or loss. For example, our network services adopt encryption technologies such as Transport Layer Security Protocol and provide browsing services through https and other methods to ensure the security of user data during transmission ; we only allow those who need to know these through information contact confidentiality agreements and other methods. Information products and employees and partners of product affiliates access personal information, and have set up strict access control and monitoring mechanisms for this purpose, and require all people who come into contact with your personal information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or suspension of our partnership .
  • 2.2. We will take all reasonably practicable measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law.
  • 2.3. The Internet is not a completely secure environment, and email, instant messaging, and communications with other users are not encrypted, and we strongly recommend that you do not send personal information through these methods. Please use a complex password to help us keep your account secure.
  • 2.4. The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal liability.
  • 2.5. After an unfortunate personal information security incident occurs, we will promptly inform you in accordance with the requirements of laws and regulations : the basic situation and impact of the security incident, the disposal measures we have taken or will take, and suggestions for you to prevent and reduce risks on your own. , remedial measures for you, etc. We will promptly notify you of the incident-related information through emails, letters, phone calls, push notifications, etc. When it is difficult to inform the personal information subjects one by one, we will issue announcements in a reasonable and effective manner. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

• 4) How you manage your personal information

In accordance with China's relevant laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights over your personal information. You can refer to the following steps to perform relevant operations :

• 1. Access your personal information

You can access basic information by following these steps:

Enter the App, click the [Personal Center] icon in the upper left corner of the homepage to enter the Personal Center , and then click [Avatar] to view personal information.

• 2. Change your personal information

You can change your basic information by following these steps :

Enter the App and click the [Personal Center] icon in the upper left corner of the homepage ;

Click [Avatar] to enter the editing page to edit personal information.

• 3. Delete your personal information

You can contact us by sending an email to service@tikajiaoyu.com to delete your personal information;

• 4. Change the scope of your authorization or consent or withdraw your authorization

to PASS HSK to continue collecting personal information or withdraw your authorization by deleting information, turning off device functions, and setting privacy settings on the website or software .

Each business function requires some basic personal information to be completed. You can give or withdraw your consent at any time for the collection and use of additional personal information. After you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawal of consent or authorization, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your authorization.

• 5. In response to your above request

We will take appropriate technical means to ensure that you can query, supplement, correct or delete your personal information, or apply for us to supplement, correct or delete relevant information through the feedback or complaint channels released by relevant products or services; we After receiving your application, it will be processed according to the process. To ensure safety, according to the process, you may be required to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. We will respond within 15 days. In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the situation. For those that are gratuitously repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices ) , pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes) request, we may deny it.

If you are unable to access, correct or delete your personal information, or you need to access, correct or delete other personal information generated when you use our products, or you believe that we have violated any laws or regulations or related to your personal information Regarding the collection or use agreement, you can contact us through our official feedback channels for related products or services announced to the outside world.

We will not be able to respond to your request under 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;
• 4）We have sufficient evidence to show that you have malicious intent or abused your rights;
• 5）Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
• 6）Involving trade secrets.

• 5) How do you cancel your account?

You can cancel your account by following these steps:

Enter the APP, you can cancel your account through [Personal Center - Settings - Account Management - Cancel Account] and select [Apply for Cancellation] if the conditions for account cancellation are met ; we will verify your cancellation application after receiving it. We will process it for you as soon as possible within 48 hours after confirming your user identity. After the account is canceled, your personal information will be removed from PASS HSK, except for the personal information that is clearly required to be retained by us by law (such as information related to your transactions in PASS HSK).

• 6) Protection of minors

We take the protection of personal information of minors very seriously . We protect the personal information of minors in accordance with relevant national laws and regulations. If you are a minor, please read this Privacy Policy carefully with the company and help of your parents or guardians, and use our services or provide information to us with the consent of your parents or guardians. For situations where we collect personal information from minors with the consent of their parents or legal guardians, we will only use or publicly disclose this information when permitted by law, with the express consent of parents or legal guardians, or when necessary to protect the minors.

If we discover that we have collected personal information from a minor without first obtaining verifiable parental consent, we will seek to delete the relevant data as quickly as possible. If you are the guardian of a minor, if you have any questions about the minor under your guardianship’s use of our services or the user information he or she has provided to us, please contact us in a timely manner according to the contact information provided in Article 9 of this policy. Contact us.

• 7) How we update our privacy policy

• 1. In order to provide you with better services, we will update the terms of this policy based on product updates and relevant requirements of laws and regulations, and these updates will form part of this policy. Without your explicit consent, we will not reduce your rights under this policy currently in effect.
• 2. If this policy is updated, we will notify you through push notifications on the APP client or other reasonable means so that you can keep abreast of the latest version of this policy.

• 8) How to contact us

If you have any complaints, suggestions, questions about personal information protection, or you have any questions about this policy, you can contact us through the following methods. We will review the issues involved as soon as possible and verify your user identity within 15 days. Reply within 1 working day : service@tikajiaoyu.com .

• 9) other

• 1. For any disputes arising from this policy and our handling of your personal information, you may file a lawsuit with the [court with jurisdiction where Hangzhou Kicka Education Technology Co., Ltd. is domiciled].
• 2. If you believe that our personal information processing has harmed your legitimate rights and interests, you can also report it to the relevant government departments.