This policy applies to all services we provide. This policy applies when you visit our platform website and/or log in to relevant application (collectively, the "Platform") to use our services.
This policy does not apply to services provided to you by other independent third parties. For example, when a third party on our platform provides services to you, the personal information you provide to the third party does apply to this policy, we are not responsible for any third party’s use of the information provided by you.
Privacy Protection Summary
1. How we collect and use your personal information
3. How we share, transfer, and publicly disclose your personal information
4. How we protect your personal information
5. Your rights
6. How we handle children's personal information
7. How your personal information is transferred globally
9. Contact us
We understand the importance of personal information to you and will do our best to protect your personal information. We are committed to maintaining your trust in us, and we promise that we will take appropriate security measures to protect your personal information in accordance with the industry's mature security standards. Please read and understand this policy before using our services.
1. How We Collect and Use Your Personal Information
1.1. Personal information refers to all kinds of information recorded electronically or otherwise that can identify the identity of a specific natural person or reflect the activity of a specific natural person, either alone or in combination with other information.
1.2. We collect your information for the following purposes:
(1) To provide, maintain, or improve products or services to you.
(2) Send you important notices.
(3) Activate or verify the product or service.
(4) Carry out promotion and introduction of products to you as permitted by laws and regulations.
(5) Other uses with your permission.
1.3 We will only collect and use your personal information for the following purposes described in this policy:
(1) When you create an account on our platform, you must provide us with a username, set and confirm your login password, and provide your mobile phone number or email. The mobile phone number or email you submit is used to accept the verification code when you register, bind your account, and retrieve your password, and as one of the contact methods you specify with us, to accept relevant business notifications (such as new product launch, event reminders, service changes , service-related notifications, etc.).
(2) After you have registered the account, you can continue to fill in and complete your personal information in the profile settings, including: ① your user identity type, real name, certificate number (individual), region, industry and other related additional information; ② contact information (area, detailed address, contact phone, fax), hobbies. Failure to provide such information will not affect your use of a particular technical service. When you provide information of type ① of this section, you need to submit true, legal, and valid information before you can officially purchase our products and services; we may use your information of type ② of this section to promote, promote products or communicate with you.
(3) User experience improvement plan: We will receive and record your personal common device information: such as operating system version, unique device identifier, software and hardware feature information, and where the device is located, based on the specific permissions you grant in software installation and use Location-related information (such as IP address, GPS location, and sensor information such as Wi-Fi access points and Bluetooth that can provide relevant information). Based on your usage data of our products and services, combined with the personal device information mentioned above, to diagnose system problems and optimize product experience. We will use tools (including third-party tools, including but not limited to Shence Data Analytics, Zhuge IO, etc.) to count the data and information you generate during the use of our products and services, including but not limited to the number of application launches and page visits, the number of key button clicks, the configuration properties of the setting items, the IP address, the type of browser, the language used, device positioning, access date and time, software and hardware feature information, log information, related device information, and web records of your needs, etc. As the subsequent versions of the product are upgraded, the scope of our statistics will change, and your download/installation/use of subsequent versions of our products will be considered as your consent to the relevant changes at that time.
(4) Before accepting the service, we will show you the information you need to submit through our platform page, which will be displayed on the platform page at that time. If you do not use some services, you do not need to provide relevant information.
(5) In order to use the audio-related functions of our products, you can open the microphone permissions of the device for audio input (such as piano sound recognition, video sparring, etc.), in this process, we will use your voice content, we will do necessary processing to meet the software usage requirements. In order to use the video-related functions of our products, you can authorize the device camera permissions for video input (such as hand and facial recognition, video sparring and other functions), in this process, we use your video content, we will do necessary processing to meet the software usage requirements. During video sparring function we will use tools (including third-party tools, including but not limited to the SoundNet SDK) to process and transmit audio and video data.
(6) In order to use our application to connect with a smart piano or smart light bar (Piano Hi-Lite), you can open the BLE Bluetooth connection or USB-MIDI connection permission. During this process, we will collect the MIDI data generated during the process you are using the smart piano or smart light bar (Piano Hi-Lite) to meet the software requirements.
(7) Our customer service and after-sales functions will use your account information to provide you with consulting services. When you contact us, we may save your communication or call history and content or the contact information you leave to help you solve the problem, or to record the solution and results of the related problem. Our customer service will use your account information to verify our identity with you. You may provide information other than the above when communicating with our customer service staff.
(8) In order to use the payment function of our products, you may use third-party payment services to complete the payment function. In the process, we will collect the payment statement generated by the third-party payment service, to record it as your proof of payment.
(9) Anonymization of personal information: After collecting your personal information, we will anonymize the data in a timely manner through technical means. We will store the anonymized data separately from the information that can be used to respond to identify the individual and guarantee that the individual will not be re-identified in the subsequent processing of personal information. Without disclosing your personal information, we have the right to mine, analyze and utilize the anonymized user database (including commercial use). We will notify you and obtain your consent if we use your personal information for purposes or scopes other than those set out in this policy or in a manner inconsistent with the data used for data collection.
2.1 To ensure the website works properly, we store small data files called cookies on your computer or mobile device. Cookies usually contain an identifier, a site name, and some numbers and characters. Cookies enable websites to store data such as your preferences or the items in your cart.
2.3 In addition to cookies, we use other similar technologies such as web beacons and pixel tags on our websites. For example, an email we send to you may contain a click URL that links to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags in the email, we can know if the email was opened. If you do not want your activity to be tracked this way, you can unsubscribe from our mailing list at any time.
2.4 Many web browsers have a Do Not Track function, which can post Do Not Track requests to the website. At present, major Internet standards organizations have not yet established policies to regulate how websites should respond to such requests. But if your browser has Do Not Track enabled, all of our sites will respect your choice.
3. How We Share, Transfer, and Publicly Disclose Your Personal Information
We do not share your personal information with any company, organization, or individual other than us, except in the following cases:
(1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
(2) We may share your personal information externally in accordance with laws and regulations, or in accordance with mandatory requirements of government authorities.
Our affiliates are any companies or legal institutions that either party controls, is under or under common control with, or is under its control. "Control" refers to the right to determine the financial and operating policies of a company, directly or indirectly enjoy more than 50% of the company's management or decision-making rights, and to obtain benefits from the company's operating activities.
(4) Sharing with authorized partners: For the purposes stated in this policy, some of our services will be provided by authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legitimate, proper, necessary, specific, and clear purposes, and we will only share the personal information necessary to provide the service. Our partners are not authorized to use shared personal information for any other purpose.
We'll not transfer your personal information to any company, orgazination, or individual, except as follows:
(1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.
3.3 Public disclosure
We only disclose your personal information publicly if:
(1) After obtaining your explicit consent.
(2) Disclosure based on law: We may disclose your personal information publicly in the case of legal, legal procedures, litigation or mandatory requirements of government authorities.
3.4. Exceptions for obtaining prior consent when sharing, transferring, or publicly disclosing user information
In the following situations, sharing, transferring, and publicly disclosing your user information does not require your prior consent:
(1) Related to national security and national defense security.
(2) Related to public safety, public health, and major public interests.
(3) Related to crime investigation, prosecution, trial and enforcement of judgments.
(4) Out of the protection of your or other individual's life, property, and other significant legal rights and interests, but it is difficult to obtain your consent.
(5) personal information that you disclose to the public.
(6) Where personal information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
4. How We Protect Your Personal Information
4.1 We take your information security very seriously. We strive to take all reasonable physical, electronic, and administrative security measures to protect your user information. Protect user information from unauthorized access, public disclosure, use modification, damage or loss. We will use encryption technology to improve the security of user information. We will use trusted protection mechanisms to prevent user information from being maliciously attached. We will deploy access control mechanisms to ensure that only authorized personnel can access user information, and we will host security and privacy training courses to increase employees' awareness of the importance of protecting user information.
4.2 We will take all reasonable and feasible measures to ensure that unrelated personal information is not collected. We will only retain your personal information for as long as necessary to achieve the purposes described in this policy, unless we need to extend the retention period or as permitted by law. We will delete or anonymize your personal information after the user information retention period has expired.
4.3 Please use complex passwords to help us keep your account secure. We will do our best to keep any information you send us secure. In order to more effectively protect your information security, we also hope that you can strengthen your self-protection awareness. We are only responsible to the extent that we directly cause the leakage of your personal information. Therefore, please keep your account and password information properly to avoid the leakage of your personal information.
4.4 The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send us. After the unfortunate occurrence of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or are about to take, and suggestions you can prevent and reduce the risks on your own, remedies for you, etc. We will promptly inform you about the event by email, letter, phone, push notification, etc. When it is difficult to notify the individual information subject one by one, we will take a reasonable and effective way to make an announcement. At the same time, we will proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.
5. Your Rights
You should ensure that all personal data submitted is accurate, we will do our best to maintain the accuracy and completeness of the personal data. In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you exercise the following rights over your personal information:
You may: (1) have the right to access certain personal data that we hold about you, with the exception of laws and regulations; (2) require us to update or correct your inaccurate personal data; and (3) We are required by law to delete your personal data. If you want to exercise the relevant rights, please contact us. For security reasons, you may need to provide a written request. If we have reasonable grounds to believe that these requests are deceptive, unenforceable, or prejudicial to the privacy or rights of others, we will refuse to process them.
You can ask us to delete personal information if:
(a) if our processing of personal information violates laws and regulations.
(b) if we collect and use your personal information without your explicit consent.
(c) if our behavior in processing personal information is a serious breach of our agreement with you.
For security reasons, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
For your reasonable request, we do not charge in principle, but for repeated requests that exceed a reasonable limit, we will charge a certain cost as appropriate. For those that are unreasonably repetitive, require excessive technical means (for example, need to develop 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) The request may be rejected by us.
We will not be able to respond to your request if:
(1) It is related to the fulfillment of the obligations provided by laws and regulations by the controller of personal information.
(2) Directly related to national security and national defense security.
(3) Directly related to public safety, public health, and major public interests.
(4) Directly related to crime investigation, prosecution, trial and execution of judgments.
(5) The controller of the personal information has sufficient evidence to show that the subject of the personal information is subjectively malicious or abuses his rights.
(6) It is difficult to obtain the consent of the individual due to the protection of the life, property and other important legal rights of the subject of personal information or other individuals.
(7) Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals and organizations.
(8) Involving business secrets.
6. How We Handle Children's Personal Information
Without the consent of a parent or legal guardian (hereinafter collectively referred to as the "guardian"), a child may not create their own user account to use our services.
In the case of collecting personal information of a child with the consent of the guardian, we will only use or publicly disclose this information if permitted by law, the explicit consent of the guardian, or necessary to protect the child.
Although local laws and customs define children differently, we treat anyone under the age of 14 as a child. If we find that we have collected personal information from a child without the prior consent of a verifiable guardian, we will try to delete the data as soon as possible.
7. How Your Personal Information Is Transferred Globally
We store your information collected within the territory of the People's Republic of China. If personal information is transmitted overseas due to business needs in accordance with applicable laws, we will obtain your consent in advance and inform you of the information leaving purpose, recipient, security measures, security risks, etc.
Significant changes referred to in this policy include, but are not limited to:
(1) Major changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, how personal information is used, etc.
(2) Major changes have taken place in our ownership structure and organizational structure. Such as business adjustment, bankruptcy mergers and acquisitions, etc.
(3) The main objects of personal information sharing, transfer or public disclosure have changed.
(4) Major changes in your right to participate in the processing of personal information and the manner in which it is exercised.
(5) When our responsible department for handling personal information security, contact methods and complaint channels change.
(6) When personal information security impact assessment report indicates high risk.
9. Contact Us
Last updated: December 24, 2019
Children's Privacy Protection Statement
Children Guardians Special Instructions
If you are the guardian of a child user, please read and choose whether you agree with this statement. We want to ask you to work with us to protect your child's personal information, help us protect your child's personal information and privacy, ask them to read and accept this statement under your supervision, and use our products and services, submission of personal information with your consent and guidance.
Special Instructions for Children
We recommend that any child participating in an online activity should obtain prior consent from a guardian. If you are a minor under 14 years of age, please notify your guardian to read this statement together and use our products, services or provide us with information after obtaining the consent of your guardian.
We remind you that the important clauses in this statement that are closely related to the rights of you and the children you are guarding (possibly), we have used bold fonts to remind you, please check them.
If you have any questions or requests for personal information during the reading of this statement, we have provided you with a dedicated feedback channel. For details, please refer to the "Contact Us" section of this statement, and we will answer your questions as soon as possible.
What Data We Collect About You
We strictly abide by the provisions of laws and regulations and the agreement with users, follow the principles of legitimate necessity, informed consent, clear purpose, safety protection, and legal use, and collect the following personal information about you and your children based on the choice of product or service.
(1) For our products and services or some functional sections of products and services that are specifically targeted at children under 14 years of age, or products or services that require users to enter birthday, age information, etc. that can identify the user's age, for registering or using such products or services, we will ask users to fill in personal birthday information to identify whether the user is a child under 14 years of age, and in accordance with laws and regulations, only allow children to continue to use related products or services after obtaining the consent of a guardian.
(2) When we identify the user as a child under 14 years of age based on the information provided by the user, we will collect the contact information of the guardian (such as mobile phone number, email) and contact the guardian to verify their guardianship with the child. We may also associate your account with a child account in accordance with the specific plan for verifying the custody relationship with the product or service and obtaining your consent, in order to protect the personal information rights of you and your children. When we identify the user as a child, we may collect more information (such as name) from the guardian in order to better protect the rights of the child to further verify the guardianship between the guardian and the child.
In some transaction-related products or services, we may require the collection and binding of your bank card-related information so that you know and manage the transaction behavior of child users. If the product or service involves uploading avatars and other functions, we strongly recommend that you instruct children not to upload information such as real portrait photos while using our products or services.
(4) If we need to collect and use children's personal information beyond the above-mentioned scope, we will again obtain the consent of the guardian.
Please understand that you can choose whether to fill in or provide specific information to us, but if you do not fill in or provide certain specific information, it may cause our products or services to fail to operate normally or to achieve the services we intend to achieve. As a result, you and the children may not be able to use our products, services, or related specific functions.
How We Use Your Information
We strictly abide by the provisions of laws and regulations and the agreement with users, and use the information we collect about you and children under your supervision for the following purposes:
(1) Verify the identity of children and guardians.
(2) Provide necessary products or services, and specific functions of products or services;
(3) For the purpose of optimizing products or services, security guarantees, and service investigations.
If we need to use the personal information of you or a child under your supervision beyond the above-mentioned purposes, we will inform you again and obtain your consent.
Sharing, Transferring, and Disclosing Children's Personal Information
We strictly comply with the laws and regulations to strictly limit the sharing, transfer and disclosure of children's personal information.
1. In general, we do not share children's personal information with third parties. We may share children's personal information with third parties only with the prior consent of the guardian.
2.Share with your guardian
We will share some of the child's personal information (such as the child's user name, account number, password, and the child user's transaction content in some of our products and services) with the guardian, and the guardian can access and manage relevant personal information.
3. For the purpose of external processing only, we may work with third-party partners (third-party service providers, contractors, agents, application developers, etc., for example, communication service providers that send email or push notifications on our behalf) , map service providers who provide us with location services (they may not be located in your jurisdiction) share children's personal information, and let them process the above information for us in accordance with our instructions, privacy policies, and related privacy and security policies .
If we entrust a third party to process children's personal information, we will conduct a security assessment of the entrusted party and the entrusted behavior, and sign the entrustment agreement, requiring that the entrusted party's processing behavior not exceed our authorized scope. The information is mainly used for the following purposes:
(1) Provide our services to children.
(2) To achieve the purpose described in the "How we use your information" section.
(4) Understand, maintain and improve our services.
If we share you and your children's information with the above third parties, we will conduct a security assessment and use encryption, anonymization, de-identification and other means to ensure the safety of you and your children's information.
4. With the continuous development of our business, we may conduct mergers, acquisitions, asset transfers or similar transactions. When such transactions result in the sharing of personal information of you and your children with third parties, we will push notifications, announcements to inform you about the situation, continue to protect the personal information of you and your children in accordance with laws and regulations and the standards required by this statement. Otherwise, we will ask the company and organization to ask the guardian's authorized consent again.
5. We may use the collected child information for big data analysis after anonymizing, such as forming a heat map, insight report, etc. that does not contain any personal information. We may disclose to the public and share with our partners information that does not contain identifying content after statistical processing, to understand how users use our services or to let the public understand the overall usage trends of our services.
6. In general, we prohibit the disclosure of children's personal information, but we may disclose children's personal information for the following purposes:
(1) Comply with relevant regulations such as applicable laws and regulations.
(2) To abide by the rules of court judgment, ruling or other legal procedures.
(3) Comply with the requirements of relevant government agencies or other legally authorized organizations.
(4) We have reasons to believe that we need to abide by relevant laws and regulations.
(5) Reasonable and necessary uses for the execution of relevant service agreements or this statement, the maintenance of public interest, the protection of the personal and property safety of our customers, us or our affiliates, other users or employees, or other legitimate rights and interests.
Store Children's Personal Information
We store children's personal information only for the period necessary for the purposes described in this statement and the minimum period required by laws and regulations. If we terminate the service or operation, we will stop the collection of children's personal information in a timely manner, and we will comply with relevant laws and regulations to notify the guardian in advance.
When our products or services cease to operate or your personal information storage period expires, we will take measures such as, push notifications, announcements, etc. to notify you and the children, and delete or anonymize within a reasonable period personal information about you and your children.
Manage Children's Personal Information
During the use of our products or services by child users, in order to make it easier for you and children to access, correct, and delete relevant personal information, we have provided you with the corresponding operating settings in the product design. You can also use the contact information provided by us to consult relevant information. We will contact you promptly after verifying your feedback. Please understand that during the verification process, we may require you to provide personal information such as child's account number, child's birth date, and contact information in order to continue to respond to your needs after completing identity verification and problem verification, and to ensure that guardians and children can access, correct, delete children's personal information, and cancel child registration accounts.
When accessing, correcting, deleting the foregoing information or requesting cancellation of an account, we may require the guardian and/or children to verify their identity to ensure the security of the information. Except as otherwise provided by laws and regulations, when guardians and children correct, delete children's personal information, or apply for account cancellation, we may not immediately correct or delete the corresponding information from the backup system, but we will correct or delete this information when the backup is updated.
Access to Children's Personal Information
You and your children can view personal information provided or generated by child users in the use of our products or services, including but not limited to usernames, passwords, avatars, nicknames, gender, unsolicited content, and more.
Update Children's Personal Information
We encourage guardians and children to update and modify children's personal information to make it more accurate and effective. Guardians and children who find that the personal information of children we collect, use, and process are incorrect can contact us to correct it. We will promptly take steps to correct it after completing the authentication and verification issues.
Delete Children's Personal Information
If the following situation occurs, you and the children you supervise may ask us to delete the personal information of the children we collect, use and process. We will promptly take steps to delete them after completing the authentication and verification.
(1) If we violate the laws, administrative regulations or the agreement of both parties to collect, store, use, transfer, and disclose children's personal information.
(2) If we exceed the scope of the purpose or the necessary period to collect, store, use, transfer, and disclose children's personal information.
(3) The guardian withdraws his consent.
(4) You or the child under your supervision terminates the use of the product or service by means such as cancellation.
However, please note that if you and the supervised child ask us to delete specific child personal information, it may prevent the child user from continuing to use our products and services or certain specific functions in the products and services.
If you find that your child's personal information has been collected without your prior consent, please contact us in time and we will try to delete the relevant data as soon as possible.
When Can Children Manage Their Own Accounts
The children will have the right to manage his or her own account after over 14 years old. If a child user chooses to manage their own account registered with our products or services, you will no longer be able to access or control their account. We'll notify you and the guardian when the guarded child has the right to manage the own account.
Application of This Statement
If you have any questions and feedback on this statement, please feel free to contact us through our platform email [firstname.lastname@example.org]. We will review the issue as soon as possible and respond within 15 days after verified your identity.
Last updated: December 24, 2019