Updated: December 11, 2024
Effective December 11, 2024
Shenzhen Dayuyan Technology Co., Ltd. (hereinafter referred to as “We”) is well aware of the importance of personal information (the content contained in the “Personal Information” or “Personal Sensitive Information” referred to in this Policy is from the GB/T35273 Personal Information Security Specification) to you, and thank you for your trust in us. We will take corresponding security protection measures to protect your personal information as much as possible in accordance with the requirements of laws and regulations. Based on this, we have formulated this Privacy Policy. This policy is intended to explain to you what information we collect, what it is for, what rights you have, etc., and to affirm our commitment to protecting personal privacy. We may update or modify this policy in the future as information processing circumstances change. Please be aware of this policy and any supplementary policies before using the products (or services) we offer.
We will protect your personal information in accordance with the following principles: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum adequacy, the principle of openness and transparency, the principle of ensuring security, the principle of subject participation, etc. At the same time, we promise that we will take appropriate security measures to protect your personal information in accordance with the industry’s mature security standards. Before using any of the services we offer, please read and understand this policy in its entirety. Once you begin to use our products (or services), you fully understand and agree to this Policy.
If you have any questions, comments or suggestions regarding the contents of this policy, please contact us at the end of this document.
This privacy policy will help you understand the following:
1. Definition and scope of personal information
2. How we use and collect your personal information
3. How do we use cookies and similar technologies
4. How do we share, transfer, and publicly disclose your personal information
5. How We Protect Your Personal Information
6. Your Rights
7. How do we protect and process the personal information of minors
8. How Your Personal Information Transfers Globally
9. How to update this privacy policy
10. Dispute Settlement
11. How to Contact Us
Please read and understand this Privacy Policy carefully before using our products (or services).
I. Definition and scope of personal information
（1）Personal information: refers to information recorded electronically or in combination with other information that can identify the identity of a specific natural person or reflect the activities of a specific natural person.
(2) Personal sensitive information: including ID number, mobile phone number, personal biometric information, bank account number, property information, whereabouts tracks, transaction information, personal information of children under 14 years old (including), etc.
(3) The personal information and sensitive personal information involved in this Privacy Policy mainly include:
① Basic information: name, gender, personal phone number, and receiving address;
② Network identification information (including system account number (including third party), IP address and passwords related to the foregoing), nickname, avatar;
③ Use data (browsing and clicking records, software use records, content entered through microphone)
④ Personal common device information (hardware model, operating system type)
⑤ Equipment application and installation information;
⑥ Record of the flow of funds generated by using third-party services.
2. How we use and collect your personal information
Your personal information will only be collected and used for the following purposes as described in this policy:
(I) Help you become one of our users
In order to use the products (or services) we offer, you will need to provide a mobile phone number to register as our user.
In addition, if you provide the following additional information, it will help us to provide you with a better service and experience: avatar, nickname, gender, birthday, current residence, IELTS test objectives, etc. However, if you do not provide this information, it will not affect the basic functionality of the Service.
When uploading avatars, filling in current residence, etc., you need to authorize us to access photo albums, cameras, location information, etc.
The above information provided by you will be continuously licensed to us during your use of this Service. When you log out of your account, we will stop using and delete the above information.
At the same time, you can also create your account by logging in to WeChat. To this end, we will check whether your device has installed a WeChat application and obtain your encryption identification information through the official WeChat
（2）Provide you with products or services
Learning Data Records: When you use our products, behavioral data tied to your account will be generated, including but not limited to learning records (oral recordings, listening questions, reading questions, writing checks, word exercises, etc.), personal collections (tweets, oral topics, oral recordings, oral test records, written test records, etc.), interactive comment information (tweets, oral recall reviews, written recall reviews, etc.). The above content will be saved to our server.
Topic Activity Recording: In our products, you can complete the oral topic exercise by recording. In this process, we need you to authorize our products to use microphone permissions to record your exercises. At the same time, you can choose to save your recordings to our server for subsequent viewing. Saved recordings, you can choose whether to make them public to other users.
Oral Modelling Examination: You can use the oral modelling function in our product to quickly start oral language exercises. To use this feature, you need to authorize our products to use microphone permissions, and your recordings will be automatically saved to our server. Saved recordings, you can choose whether to make them public to other users.
Oral Notes: You can create and save your oral practice notes in our products in the form of text or pictures. If you choose to enter by saving pictures, you need to authorize our products to access photo albums and use the camera. The contents of your saved notes are for your personal access only and will not be made public to other third parties.
Share: You can share specific content in our products to third-party platforms. In order to allow you to use the sharing function normally, we will scan your device for whether the corresponding third-party platform products are installed.
Payment: You can purchase members or other services in our products. This process will involve third-party payment services. Your order number, payment flow and other information will be saved by us and third-party payment service providers.
Submit Feedback: When you submit feedback in the Dauyan service platform, to ensure that we can accurately understand and screen the problems you encounter, the information we may collect includes: Log file, device model, device identification information (MAC address, DEVICE_id, IMEI, device serial number), operating system version.
Mail: If you purchase services involving physical goods in our products, you need to provide us with the recipient’s name, mobile phone number, delivery address and other information so that we can deliver the physical goods safely and accurately.
(3) User Experience Improvement Plan
We will diagnose system problems and optimize the product experience based on your usage data of our products and statistics based on personal common device information.
We use tools (including third-party tools) to count the data information you generate when using our products, including application launches, page visits, key button clicks, configuration attributes for setup items, network service providers, IP addresses, system platforms, timestamps, application identifiers, application versions, application distribution channels, standalone device identifiers, iOS advertising identifiers (IDFAs), Android advertiser identifiers, network card (MAC) addresses, international mobile device identification codes (IMEI), international mobile device identification codes (IMEI), device models, terminal manufacturers, terminal device operating system versions, session startup/stop times, language locations, time zones, and network status (WiFi, etc.).
To enhance our service quality and user experience, our application will collect certain device information, including OAID (Open Anonymous Device Identifier) and Android ID. We aim to provide a detailed explanation of the purposes, methods, and scope of collecting this information. We utilize OAID for data analysis to help improve your experience. By collecting the Android ID, we can analyze user behavior to enhance our application’s performance and features. When you first use our app, we do not automatically collect OAID and Android ID information. Collection begins only after you agree to our privacy policy. We assure you that when handling this data, we adhere to data protection regulations and implement necessary security measures to protect your personal information. This information will be used solely for internal analysis and will never be sold or leased to third parties. Your personal information will only be used when necessary and will be appropriately deleted upon completion of its intended use.
As we upgrade subsequent versions of our products, the scope of our statistics will change and your behavior of downloading/installing/using subsequent versions of our products will be deemed to be your agreement to the relevant changes at that time.
Your consent will be sought in advance when we intend to use the information for other purposes not specified in this policy.
Your consent will be solicited in advance when we intend to use information gathered for a particular purpose for other purposes.
(4) Customer Service and After-Sales
Our customer service and after-sales functions will use your account information to provide you with consulting services. When we establish contact with you, we may keep a record and content of your communications or calls or the contact information you leave behind to help you resolve the issue or to document the resolution and results of the issue. Our customer service will use your account information with you to verify your identity. It is possible that you will provide additional information beyond the above information when communicating with our customer service staff.
（5）Exceptions to obtaining authorized consent
Depending on the relevant laws and regulations and national standards, we may collect and use your personal information in accordance with the law without your consent in the following cases:
Directly related to national security and national defense security;
It is directly related to public safety, public health and major public interests;
Directly related to criminal investigation, prosecution, trial and execution of judgments;
Out of protecting your or other personal life, property and other major legal rights and interests, but it is difficult to obtain your own consent;
The personal information collected is made public to the public by yourself;
Collecting personal information from legally disclosed information, such as: legal news reports, government information disclosure and other channels;
It is necessary to conclude and perform the contract according to your requirements;
necessary for maintaining the safe and stable operation of the products or services provided, such as finding or disposing of faults in the products or services;
3. How do we use cookies and similar technologies
（1）Cookie
To ensure the proper functioning of the website, we store a small data file called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and numbers and characters. With cookies, websites can store data such as your preferences or items in your basket.
We will not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer. Most web browsers have a feature that prevents cookies. But if you do this, you will need to change the user settings yourself every time you visit our website.
(2) Website beacons and pixel tags
In addition to cookies, we also use other similar technologies such as website beacons and pixel tags on the website. For example, an email we send to you may contain a click-through URL that links to content on our website. If you click on this link, we will track this click to help us understand your product or service preferences and improve customer service. A Web site beacon is usually a transparent image that is embedded in a Web site or an e-mail message. With the help of pixel tags in the email, we can know if the email has been opened. If you do not wish your activities to be tracked in this way, you may unsubscribe from our mailing list at any time.
(3) Do Not Track (do not track)
Many web browsers have a Do Not Track feature that allows you to post a Do Not Track request to a Web site. At present, major Internet standards organizations have not established policies to specify how websites should respond to such requests. But if your browser has Do Not Track enabled, all of our websites will respect your choice.
4. How do we share, transfer, and publicly disclose your personal information
(I) Sharing
We do not share your personal information with any other company, organization, or individual except for the following:
1) Share with express consent: With your express consent, we will share your personal information with other parties.
2) We may share your personal information externally according to laws and regulations, or as required by the competent government department.
3) Share with Authorized Partners: Certain of our services will be provided by Authorized Partners only for the purposes stated in this Privacy Policy. We may share some of your personal information with partners to provide better customer service and user experience. For example, a company we hire to provide third-party data statistics and analysis services may need to collect and access personal data for data statistics and analysis. In this case, these companies must comply with our data privacy and security requirements. We will only share your personal information for legal, justified, necessary, specific and clear purposes, and will only share personal information necessary for the provision of services.
We enter into strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.
（2）Transfer
We do not transfer your personal information to any company, organization, or individual except for the following:
1） Transfer with express consent: After obtaining your express consent, we will transfer your personal information to other parties;
2）When it comes to merger, acquisition or bankruptcy liquidation, if it involves the transfer of personal information, we will ask the new company or organization holding your personal information to continue to be subject to this privacy policy, otherwise we will ask the company or organization to request your authorization consent again.
(3) Public Disclosure
We will disclose your personal information publicly only if:
1） After obtaining your explicit consent;
2）Disclosure Based on Law: We may publicly disclose your personal information under the circumstances of laws, legal procedures, lawsuits or mandatory requirements of government authorities.
5. How We Protect Your Personal Information
(I) We have used industry-standard security precautions to protect the personal information you provide from unauthorized access, public disclosure, use, modification, damage or loss of data. We take all reasonable steps to protect your personal information. For example, is protected by SSL encryption when exchanging data (such as credit card information) between your browser and the Service; We also provide https secure browsing methods for our website; We will use encryption technology to ensure the confidentiality of data; We use trusted protection to protect data from malicious attacks; We will deploy access control mechanisms to ensure that only authorized personnel can access personal information; And we will hold security and privacy protection training courses to strengthen employees’ awareness of the importance of protecting personal information.
(2) We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for as long as necessary to achieve the purposes set forth in this policy unless an extended retention period is required or permitted by law.
(3) The Internet is not an absolutely secure environment, and e-mail, instant messaging, and other communication methods with our users are not encrypted. We strongly recommend that you do not send personal information in this way. Please use a complex password to help us keep your account secure.
(4) The Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of any information you send us. If our physical, technological, or administrative 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 be liable accordingly.
(5) After an unfortunate personal information security incident, we will timely inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions that you can prevent and reduce risks independently, and remedial measures against you in accordance with the requirements of laws and regulations. We will inform you of the relevant events in a timely manner by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement.
At the same time, we will also actively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
6. Your Rights
In accordance with the relevant laws, regulations and standards of China, as well as the common practices of other countries and regions, we guarantee that you exercise the following rights over your personal information:
(1) Access your personal information
You have access to your personal information, except for legal and regulatory exceptions. If you want to exercise data access, you can access it yourself in the following ways:
If you wish to access or edit profile information in your account, change your password, add security information, or log out of your account, you can do so in the Personal Center.
If you wish to close your account, please email service\@dauyan.com to request such action, and we will respond to your request within 15 business days.
We will provide you with additional personal information generated by you in the course of using our products or services, as long as we do not require excessive investment. If you would like to exercise data access, please email service\@dauyan.com and we will respond to your request within 15 business days.
（2）Correct your personal information
When you find that there is an error in the personal information we handle about you, you have the right to ask us to make corrections. You can request corrections as listed in the Personal Center Access to Your Personal Information.
If you are unable to correct this personal information via the above link, you can email service\@dauyan.com. We will respond to your request for correction within 15 business days.
（3）Delete your personal information
You can request us to delete personal information in the following situations:
1）If our handling of personal information violates laws and regulations;
2）If we collect and use your personal information without your consent;
3）If our handling of personal information violates the agreement with you;
4）If you no longer use our products or services, or if you log out of your account;
5）If we no longer provide you with products or services.
If we decide to respond to your request for deletion, we will also notify those entities that have obtained your personal information from us and require them to be removed in a timely manner, unless otherwise provided by law or regulations, or if these entities have obtained your independent authorization.
When you delete information from our services, we may not immediately delete the appropriate information from the backup system, but will delete it when the backup is updated.
（4）Change the scope of your authorized consent
Each business function requires some basic personal information to complete (see “Part One” of this strategy). You may at any time give or withdraw your authorization for the collection and use of additional collected Personal Information.
You can do it yourself in the following ways:
Enter the IOS Generic-Settings, turn these permissions on or off.
When you withdraw your consent, we will no longer process the appropriate personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously performed based on your authorization.
If you do not wish to accept the commercial we sent you, you may cancel it at any time by:
Personal Center-Message notifications turn on close notifications themselves or send an email to service\@dauyan.com. We will respond to your request within 15 business days.
（5）The personal information subject cancels the account
You can log out of your previously registered account at any time, and you can submit a logout request using the logout feature in our product. We will complete your account cancellation within 15 business days.
After you log out of your account, we will stop providing you with products or services and delete your personal information at your request, unless otherwise required by laws and regulations.
For DAUYAN IELTS SPEAKING App: Click sequentially on Settings, Personal Profile, and then Cancel Account. For Swift IELTS App: Click sequentially on Personal Center and then Cancel Account.
（6）The subject of personal information obtains a copy of personal information
You have access to copies of your personal information, and you can do so yourself:
Send an email to service\@dauyan.com. We will respond to your request within 15 business days.
Subject to technical feasibility, such as data interface matching, we can also directly transmit a copy of your personal information to your designated third party at your request.
（7）Automatic decision-making of restraint information system
In some business functions, we may make decisions based solely on non-manual, automated decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will provide appropriate relief.
(8) Respond to your above request
To ensure security, you may need to provide a written request or otherwise prove your identity. You may be asked to verify your identity before processing your request.
We will reply within thirty days. If you are not satisfied, you can also file a complaint through the following channels:
Send an email to service\@dauyan.com.
We will respond to your request within 15 business days.
We do not charge a fee in principle for your reasonable requests, but we will charge a certain cost for repeated requests that exceed reasonable limits. Requests that are unwarranted duplication, that require excessive technical means (for example, the need to develop new systems or radically change current practices), that pose a risk to the legitimate interests of others, or that are highly impractical (for example, involving information stored on backup tapes), may be rejected.
In the following cases, we will not be able to respond to your request as required by law and regulation:
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 and trial;
4）There is sufficient evidence to indicate that you have subjective malice or abuse of rights;
5）Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations.
7. How do we handle children’s personal information
Our products, websites and services are primarily aimed at adults. Children are not allowed to create their own user accounts without the consent of their parents or guardians.
For the collection of personal information of children with the consent of parents, we will only use or publicly disclose this information if it is permitted by law, with the explicit consent of parents or guardians, or necessary to protect the child.
Despite the different definitions of children in local laws and customs, we regard anyone under the age of 14 as a child.
If we find that we have collected the child’s personal information without the prior consent of verifiable parents, we will try to delete the relevant data as soon as possible.
8. How to update this privacy policy
We may make adjustments or changes to this Privacy Policy in due course. Any updates to this Privacy Policy will be published on our service platform in a manner that indicates the update time. Except as otherwise required by laws, regulations or regulations, the adjusted or changed content will take effect 7 days after notice or publication. If you continue to use any of the services provided by us or access our relevant service platform services after the privacy policy has been adjusted or changed, we believe that this represents your full reading, understanding and acceptance of the revised privacy policy and is subject to it.
9. Dispute Resolution
This User Agreement and your relationship with us shall be governed by the laws of the Mainland Region of the People’s Republic of China, but shall not include the conflict of laws and regulations. You and we agree to submit to the jurisdiction of our local courts.
10. How to contact us
If you have any questions, comments or suggestions regarding this Privacy Policy, contact us at:
email：service@dauyan.com
We have a dedicated Personal Information Protection Department (or Personal Information Protection Specialist) that you can contact at service@dauyan.com
In general, we will reply within 15 working days.