Privacy Policy

Updated on:  10/27/2023

Effective date:  10/27/2023

This policy applies to products or services such as  GM Education (hereinafter referred to as "this application")

This privacy policy section will help you understand the following:

1、 Definition and Scope of Application

2、 Explanation of self start and associated start

3、 How do we collect and use your information

4、 How do we use cookies and similar technologies

5、 How do we share, transfer, and publicly disclose users' personal information

6、 How do we protect user information security

7、 How do you manage personal information

8、 How do we handle information about minors

9、 How does your information transfer globally

10、 How to update this privacy policy

11、 How to contact us

GENIUS MANAGER EDUCATION INC.

(hereinafter referred to as "us") is well aware of the importance of personal information to you. We will provide sufficient protection for your personal information security in accordance with legal and regulatory requirements and in accordance with industry best practices. We are committed to maintaining your trust in us and 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 consent, the principle of minimum adequacy, and the principle of ensuring security, The principle of subject participation, the principle of openness and transparency, and so on. In view of this, we have formulated this Privacy Policy (hereinafter referred to as "this Policy/Privacy Policy") to help you fully understand how we collect, use, share, store, and protect your personal information during your use of our products/services, as well as how you manage your personal information.

Before using various products or services of this application, please carefully read and thoroughly understand this policy. After confirming full understanding and agreement, use the relevant products or services. Once you start using various products or services of this application, it means that you have fully understood and agreed to this policy. If you have any questions, opinions or suggestions regarding the content of this policy, you can contact us through the various contact information provided by this application.

Our product is developed based on DCloud uni app (5+App/Web2App), and during application operation, we need to collect your device unique identification code (device ID, IMEI/android ID/DeviceID/IDFA, device MAC address, OAID, software list, SIM card IMSI information) to provide statistical analysis services. We also improve performance and user experience through application startup data and abnormal error log analysis, providing better services for users. For more information, please visit the "DCloud User Service Terms". (DCloud User Service Terms hyperlink to https://ask.dcloud.net.cn/protocol.html ).

Our product is developed based on DCloud uni app (5+App/Web2App), and during application operation, we need to collect your device unique identification code (device ID, IMEI/android ID/DeviceID/IDFA, device MAC address, OAID, software list, SIM card IMSI information) to provide statistical analysis services. We also improve performance and user experience through application startup data and abnormal error log analysis, providing better services for users. For more information, please visit the "DCloud User Service Terms". (DCloud User Service Terms hyperlink to https://ask.dcloud.net.cn/protocol.html ).

1、Definition and Scope of Application

Personal information: Various types of 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, Personal information includes (name, date of birth, ID number, personal biometric information, address, communication contact information, communication records and content, account password, property information, credit information, travel trajectory, accommodation information, health and physiological information, transaction information), etc.

Personal sensitive information: Personal information that, once leaked, illegally provided, or abused, may endanger personal and property safety, and can easily cause damage to personal reputation, physical and mental health, or discriminatory treatment, Personal sensitive information includes (ID number, personal biometric information, bank account, communication records and content, property information, credit information, travel trajectory, accommodation information, health physiological information, transaction information, personal information of children under 14 years old (including), etc.).

Personal information processing: including the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of personal information.

Personal information deletion: refers to the act of removing personal information from systems involved in implementing daily business functions, leaving it in a state that cannot be retrieved or accessed.

Data anonymization of personal information: a process in which the subject of personal information cannot be identified or associated through the technical processing of personal information, and the processed information cannot be recovered.

Deidentification of personal information: The process of processing personal information through technology, making it impossible to identify or associate with the subject of personal information without the use of additional information.

Personal information subject: The natural person identified or associated with personal information.

Personal information controller: An organization or individual with the ability to determine the purpose, method, etc. of personal information processing.

Device information: including device identifiers (IMEI, IDFA, Android ID, MAC, OAID, IMSI, and other device related information), application information (application crash information, notification switch status, application installation list, and other application related information), device parameters and system information (device type, device model, operating system, and hardware related information), The device network environment information (IP address, WiFi information, base station information, and other network related information) shall be based on the actual collection of the product.

Children: Refers to minors who have not reached their fourteenth anniversary.

2、Explanation of self start and associated start

1. To ensure that this application can receive the installation package download broadcast information pushed by the client normally when it is closed or running in the background, this application must use the (self start) ability. There will be a certain frequency of self start or associated start behavior through system broadcast wake-up, which is necessary to achieve functions and services.

2. In order to provide you with a better application update experience, the application has introduced network connection status monitoring (android. net. conn. CONNECTIVITY_CHANGE, android. net. wifi. STATE-CHANGE) to remind you to avoid unnecessary traffic waste when the network changes. At the same time, it is associated with self startup function (android. content. action. DOWNLOAD_NOTIFICATION_CLICKED), The purpose is to immediately remind you to install the application installation package when it is completed.

3. Before you agree to the user agreement and privacy policy, if you click to view the user agreement and privacy policy, to prevent third-party SDKs from collecting your personal information, we will launch a system browser for you to view the user agreement and privacy policy.

4. Our application has integrated WeChat sharing. After WeChat sharing is completed, it will return to the app to display the sharing status. We need to restart the app. The link shared by our app will open the app when it is already installed, in order to make it more convenient for you to open the app and view it

5、Self startup permission: our app is integrated with Aurora Push. Tofacilitateuick Look of notification content, we will open the app through notification and display the corresponding content of the notification. Our application integrates WeChat Pay. After WeChat Pay is completed, it will return to the APP to display the payment status, and the APP needs to be restarted. In order to ensure that you can receive messages, messages, and other related content sent by platform users in a timely manner, we will request that you authorize the program to start automatically. The purpose of using this permission is to ensure that the app does not kill the running status of the app in the background in a timely manner after exiting the background, to ensure that you can receive messages within the application in a timely manner. If you refuse to grant the program self start permission, you will not be able to use this feature, but it will not affect your normal use of the app.

3、How do we collect and use your information

When you use our products/services, we need to collect and use your personal information, including the following two types:

1. In order to provide you with the basic functions of our products/or services, you must authorize us to collect and use necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. In order to provide you with additional features of our products and/or services, you may choose to separately share or disagree with the information we collect and use. If you refuse to provide, you will not be able to use the relevant additional features normally or achieve the desired functional effects, which will not affect your use of our basic functions.

3. When providing you with local channel content or content or services related to the location of the device, with your authorization, we will use geographic location information related to this service (such as precise positioning information, WLAN access points, Bluetooth and base stations, sensor information) to ensure the quality of the content or service. Precise location information is personal sensitive information. If you refuse to grant location permission, it will affect the accuracy of the location, but it will not affect the normal use of other functions and services. We will only display content or services that may be related to you based on the city and/or county corresponding to network information (such as IP).

4. When you use the app, you will obtain direction sensor and gyroscope device sensor information to identify whether you are a real user. When you use recording and photography related functions, you will obtain acceleration device sensor information to obtain the camera phone angle.

5. Clipboard permission: When you may need to copy and paste text during use (such as SMS verification code, phone number, device SN, etc.), we may apply to call the clipboard copy/paste function and collect text information from your device's clipboard. The information of the clipboard will only be processed on your device, and we will not store your clipboard information for other purposes.

We would like to remind you that this information is not necessary for the operation of the business function, but it is of great significance for improving service quality, developing new products or services, etc. We will not force you to provide this information, and your refusal will not have an adverse impact on the use of this business function.

The specific functional scenarios we provide for you include:

1. Help you become our user

To complete the creation of an account so that we can provide you with services, you need to provide the following information: your phone number and other information. When you register, provide us with the mobile phone number used for registration (to receive a verification code), and we will verify your identity by sending a text message verification code. You can modify and supplement your nickname, gender, birthday, avatar, real name verification binding, your Alipay account, WeChat account (for account withdrawal) and other relevant information, which belong to your "account information". When you log in using a third-party account (WeChat account, Apple account), if you decide to bind to the account of the third-party platform, after your third-party platform account binding authorization, the third-party platform will synchronize a portion of your relevant information under the third-party platform account to us, such as username, phone number, avatar, nickname, region, gender, etc. (subject to your authorization) and identity verification information. We collect the above information to provide you with account login services and ensure your account security and prevent security risks. If you refuse to authorize the above information, you will not be able to log in to this application platform using the account of a third-party platform, but it does not affect the other products and services we provide to you and the normal use of other services.

If you provide the following additional information to complete your personal information during use, it will help us provide you with better service and experience: your birthday, occupation, interests, and phone number. But if you do not provide this information, it will not affect the basic functions of using this application product or service.

The above information you provide will continue to authorize us to use it during your use of this service. When you voluntarily apply to cancel your account, we will make it anonymous or delete your personal information as soon as possible in accordance with applicable laws and regulations.

2. To provide you with services and needs

To showcase content or services to you, we will collect and use device information (including device identifiers (IMEI, IDFA, Android ID, MAC, OAID, IMSI, and other device related information), application information (application crash information, notification switch status, application installation list, and other application related information) when you visit or use this website or client Device parameters and system information (device type, device model, operating system, and hardware related information), device network environment information (IP address, WiFi information, base station information, and other network related information) Service log information (browsing records, click to view records, search query records, favorites, follow and share information, publish information, IP address, browser type, telecom operator, language used, access date and time), and basic information you submit (such as nickname, gender, phone number), to improve your personal information.

3. Providing you with goods or services

3.1 The information you provided to us

The relevant personal information you provide us with when registering your account or using our services, such as basic WeChat information (nickname, avatar, gender), phone number, etc;

The shared information you provide to other parties through our services, as well as the information stored when you use our services. Before providing the aforementioned personal information of the other party to this application, you need to ensure that you have obtained their authorized consent.

3.2 Description of directional push function

Personalized content recommendations are available on the homepage, categories, or shopping cart interface, only for displaying products to users on the app. Do not collect user information. Users can independently turn off personalized content recommendation. Closing method: Click on the My Settings icon, Personalized Content Recommendation, and then click Close to turn off personalized content recommendation.

3.3 The information we collected during your use of the service

To provide you with search results, understand product compatibility, and identify abnormal account status, we will collect information about the services you use and how you use them, and associate this information. This information includes:

3.3.1 Equipment information:

In order to ensure the safe operation of applications and services, we will collect your device model, application list (installation list), device name, device unique identifier, login IP address, product version number, and mobile network information.

We will collect your (device identifier, device serial number, Android ID, application list, IMEI, IDFA, MAC, name, phone number, location) and other information in a silent/background state to identify the user's identity information.

3.3.2 Based on the specific permissions granted by you during software installation and use, we explain the purpose, method, and scope of collecting personal information for this application during your installation and use, as follows:

Explicit list of personal information collected by xxx APP
Business ScenarioUse permissionsCollection purposeCollection methodPersonal information field
registering and logging inUnused permissionsUsed to register and create accounts, improve network identity identificationUser input/APP collectionMobile number, email, nickname
modifying personal profile informationRead photo albums, camera permissionsUsed to modify avatars in personal profilesAPP CollectionHead photo

(5) The purpose, method, and scope of collecting information through the third-party SDK integrated with this application are explained as follows:

Xxx APP accessing third-party SDK directory
SDK NamePackage name informationPurpose of useInvolving personal informationPrivacy Policy Link
Uni app integrates the following third-party SDKs by default to ensure operation:
Uni app (5+, web2app)Io.dcloudBasic moduleStored personal files, device information (IMEI, MAC, ANDROID_ID, DEVICE_ID, IMSI), network informationhttps://ask.dcloud.net.cn/article/36937
Alibaba WeexSDKCom.taobaoThe default integration of the uni app basic module is used to render the nvue page engine of the uniappStored personal fileshttp://doc.weex.io/zh/
Fresco GalleryCom. Facebook. FrescoUsed for nvue page loadingStored personal fileshttps://www.fresco-cn.org/
Glide GalleryCom.bumptech.glideUsed for image previewStored personal fileshttp://bumptech.github.io/glide/
Mobile security Alliance OAIDCom.bn.mitmdid, com.zui.opendeviceidlibrary, com.netease.nis Com.netease, com.samsung.android, com.huawei.hmsObtain oaidDevice Informationhttp://www.msa-alliance.cn/col.jsp?id=122
This application integrates the following third-party SDKs to ensure operation:
SDK NamePackage name informationPurpose of useInvolving personal informationPrivacy Policy Link
Personal push · Message pushCom. igexin. sdk, com. getui. gtc, com. getui, com. g. sysdkMessage pushDevice information (IMEI, MAC, ANDROID_ID, DEVICE_ID, IMSI), application installed list, network informationhttp://docs.getui.com/privacy
Aurora, Aurora pushCn.jpush, cn.jiguangPush MessageDevice information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM card IMSI information, etc.), network information and location information (IP address, WiFi information, base station information), application installation listhttps://www.jiguang.cn/license/privacy
Youmeng StatisticsCom.uc.crashsdk, com.efs, com.umengstatisticsWhen running the APP front-end, it is necessary to obtain device information (IMEI, ANDROID_ID, DEVICE_ID, IMSI), application installed list, network information, and obtain device serial numberhttps://www.umeng.com/page/policy

3.3.3 Service log information: including browsing records, click to view records, search query records, favorites, transactions, after-sales, follow and share information, published information, as well as IP address, browser type, telecommunications operator, language of use, access date and time.

When you use products or services provided by our website or client, we will automatically collect detailed usage information of our services from you as a relevant network log for storage. For example, your search query content, Idiv address, browser type, telecom operator, language used, visit date and time, and the web page records you visited.

Please note that individual device information, log information, etc. are information that cannot identify a specific natural person. If we combine this kind of non personal information with other information to identify the identity of a specific natural person, or use it with personal information, during the combined use, this kind of non personal information will be regarded as personal information, and unless we obtain your authorization or otherwise specified by laws and regulations, we will Data anonymization and de identify this kind of personal information.

When you contact us, we may save your communication/call records and content, or the contact information you left behind, in order to contact you or help you solve problems, or record the solutions and results of related issues.

3.4 Your personal information collected through indirect means

You can use the products or services provided by our affiliated companies through the link portal provided by us through this application account. In order to facilitate our one-stop service based on the associated account and facilitate your unified management, we will display your information in this application set. You can discover and use the above services through the basic information and authentication information functions of your personal center.

When you use the above services through our products or services, you authorize us to receive, summarize, and analyze your personal information or activity information from our affiliated companies based on actual business and cooperation needs. We confirm that its source is legitimate, or you authorize us to agree to its provision to us.

If you refuse to provide the above information or refuse authorization, you may not be able to use the corresponding products or services of this application normally, or be unable to display relevant information, but it does not affect the use of core services such as browsing and participating in activities that do not require privacy authorization.

4. Providing you with security

Please note that to ensure the authenticity of user identity and provide you with better security, you can provide us with identity information such as your ID card to complete real name authentication. If you refuse to provide the above information, you may not be able to use account management, continue potentially risky transactions, and other services, but it will not affect your use of browsing, purchasing goods, and other services.

We may use or integrate your user information Transaction information, device information, relevant network logs, as well as information authorized or legally shared by our affiliated companies and partners to comprehensively assess your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

5. Provide you with collection, follow, and sharing functions

During your browsing of our website or client, you can choose to bookmark products and/or services, and share information with other third parties through the functional components we provide. During your use of the above functions, we will collect service log information, including records of your favorite and coupon information, as well as sharing history, for the purpose of achieving the above functions and other clearly stated purposes.

6. Exceptions to obtaining authorized consent

According to relevant laws and regulations, collecting your personal information does not require your authorized consent in the following situations:

6.1 Related to the fulfillment of obligations stipulated by laws and regulations by personal information controllers;

6.2 Directly related to national security and national defense security;

6.3 Directly related to public safety, public health, and major public interests;

6.4 Directly related to Criminal investigation, prosecution, trial and judgment execution;

6.5 For the purpose of safeguarding the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain my authorized consent;

The personal information involved in 6.6 is disclosed by the individual information subject to the public on their own;

6.7 Necessary for signing and performing contracts according to the requirements of the personal information subject;

6.8 Collecting personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;

6.9 Necessary for maintaining the safe and stable operation of the provided products or services, such as detecting and handling malfunctions in the products or services;

6.10 The personal information controller is a news unit and is necessary for conducting legitimate news reporting;

6.11 The personal information controller is an academic research institution that is necessary for conducting statistical or academic research in the public interest, and when providing academic research or descriptive results to the public, the personal information contained in the results is de labeled.

If we stop operating this application product or service, we will stop collecting your personal information in a timely manner, notify you of the notice of stopping operation in the form of delivery or announcement one by one, and delete or Data anonymization the personal information we hold.

7. Customer service and after-sales functions

When you contact us or apply for after-sales or dispute resolution during sales, in order to ensure the security of your account and system, we need you to provide necessary personal information to verify your membership status. At this point, our customer service and after-sales functions may use your account information and order information.

For the convenience of contacting you, helping you solve the problem as soon as possible, or recording the handling plan and results of related issues, we may save your communication/call records and related content with us (including account information, order information, other information you provide to prove relevant facts, or contact information you leave). If you inquire, complain, or provide suggestions regarding a specific order, We will use your account information and order information.

In order to provide services and improve service quality, we may also use your other information, including the relevant information you provided when contacting customer service, and the questionnaire response information you sent us when participating in the survey.

4、How do we use cookies and similar technologies

1. Cookies

Cookies and similar device information identification technology are commonly used technologies in the Internet. When you use our services, we may use related technologies to send one or more cookies or anonymous identifiers (hereinafter referred to as "cookies") to your device to collect, identify, and store information about your access to and use of this product. We promise not to use cookies for any other purpose other than those stated in this privacy policy, We mainly use cookies to ensure the safe and efficient operation of our products and services. They can help us confirm the security status of your account and transactions, troubleshoot related anomalies such as crashes and delays, and help you avoid repeating the steps and processes of filling out forms and entering search content.

2. Website Beacons and Pixel Labels

In addition to cookies, we also use similar technologies such as website beacons and pixel labels on our website. A website beacon is usually a transparent image embedded in a website or email. With the help of pixel labels in emails, we can know if emails have been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

5、How do we share, transfer, and publicly disclose users' personal information information

1. Sharing

We will not share your personal information with companies, organizations, or individuals outside of our application service provider, except for the following situations:

1.1 Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

1.2 Sharing under legal circumstances: We may share your personal information with others in accordance with laws and regulations, litigation dispute resolution needs, or as required by administrative or judicial authorities in accordance with the law.

1.3 Sharing with affiliated companies: In order for us to jointly provide services to you based on our affiliated account, your personal information may be shared with our affiliated companies. We will only share necessary personal information (if it is convenient for you to use our affiliated company's products or services using this application account, we will share your necessary account information with the affiliated company). If we share your personal sensitive information or if the affiliated company changes the purpose of using and processing personal information, we will seek your authorization and consent again.

1.4 Sharing with authorized partners: For the purposes stated in this privacy policy only, certain of our services will be provided jointly by us and authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. For example, arranging partners to provide services. We will only share your personal information for legitimate, legitimate, necessary, specific, and clear purposes, and only share personal information necessary for providing services. Our partners have no right to use the shared personal information for other purposes unrelated to the product or service.

Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even sensitive personal information of you or others. Please consider and make a decision with greater caution.

Currently, our authorized partners include the following types:

1.4.1 Authorized partners for advertising and analysis services. Unless we obtain your permission, we will not share your personally identifiable information (referring to information that can identify you, such as name or email address, mobile phone number, through which you can be contacted or identified) with partners providing advertising and analysis services. We will provide these partners with information about their advertising coverage and effectiveness, without providing your personal identification information, or we will summarize this information so that it does not identify you personally. For example, only after advertisers agree to comply with our advertising guidelines can we possibly tell them how effective their advertisements are, or how many people have seen their advertisements or installed applications after seeing them, or provide these partners with personally identifiable statistical information (such as "male, 25-29 years old, located in Beijing") to help them understand their audience or customers.

1.4.2 Suppliers, service providers, and other partners. We send information to suppliers, service providers, and other partners who support our business, including providing technical infrastructure services, analyzing the usage of our services, measuring the effectiveness of advertising and services, providing customer service, facilitating payment, or conducting academic research and research.

1.4.3 In order to provide you with a one click sharing service, our product integrates Youmeng+U-Share SDK, which will collect your device identification information (such as IMEI/android ID/IDFA, etc.) and the public information of your social account that you need to share in order to complete the one click sharing service. For the sake of your information security, we have entered into data security and confidentiality agreements with third-party SDK service providers, who will strictly comply with our data privacy and security requirements. Unless we obtain your consent, we will not share your personally identifiable information with you. To help you better understand the types and purposes of data collected by [Youmeng+], as well as how to protect your personal information, you can log in https://www.umeng.com/policy Understand the privacy policy of Youmeng+.

We will sign strict data protection 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.

1.4.4 Our product integrates a push SDK, and during the operation of the application, it is necessary to collect your device's unique identification code (IMEI/android ID/IDFA, MAC, OAID information) to generate user IDs. By obtaining application list (installation list) information, service providers can adjust the push link and facilitate the closed SDK push process.

Message push service provider: Daily Interactive Co., Ltd. provides Push technology services (individual push igexin/getui SDKs). We may provide your device platform, device manufacturer, device brand, device ID code and other device information, application list information, network information and location related information to Daily Interactive Co., Ltd. to provide you with message Push technology services. When we push messages to you, we may authorize Daily Interactive Co., Ltd. to adjust the link and promote the closed SDK push process to ensure that you can receive the messages we push to you in a timely manner. For detailed information, please visit the "Personal Push User Privacy Policy". You can log in http://docs.getui.com/privacy Understand the 'Privacy Policy for Individual Twitter Users'.

2. Transfer

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

2.1 Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2.2 When it comes to mergers, acquisitions, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this personal information protection policy. Otherwise, we will require the company or organization to seek authorization from you again.

3. Public disclosure

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

3.1 After obtaining your explicit consent;

3.2 Disclosure based on law: In cases where required by law, legal proceedings, litigation, or mandatory requirements of government authorities, we may publicly disclose your personal information.

4. Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

4.1 Related to personal information controllers fulfilling their obligations under laws and regulations;

4.2 Directly related to national security and national defense security;

4.3 Directly related to public safety, public health, and major public interests;

4.4 Directly related to Criminal investigation, prosecution, trial and judgment execution;

4.5 For the purpose of safeguarding the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain my authorized consent;

4.6 Personal information disclosed by the individual information subject to the public on their own;

4.7 Collecting personal information from legally disclosed information centers, such as legitimate news reports, government information disclosure, and other channels.

According to legal regulations, sharing or transferring personal information that has undergone deidentification processing, and ensuring that the data recipient cannot recover and re identify the personal information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require separate notice to you and your consent.

6、How do we protect user information security

1. We have used security measures that comply with De facto standard to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information. For example, when exchanging data (such as credit card information) between your browser and server, it is protected by SSL (Secure Socket Layer) protocol encryption (i.e. HTTPS protocol); We will use encryption technology to improve the security of personal information; We will use trusted protection mechanisms to prevent malicious attacks on personal information; 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 enhance employees' awareness of the importance of protecting personal information.

2. We have an industry-leading data security management system centered around the data lifecycle, which enhances the security of the entire system from multiple dimensions such as organizational construction, institutional design, personnel management, and product technology.

3.We will take reasonable and feasible measures to ensure that unrelated personal information is not collected. We will only retain your personal information for the period required to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law.

4. The Internet is not an absolutely secure environment, and we strongly recommend that you do not use communication methods other than those recommended by this application to send personal information. You can establish connections and share with each other through our services. When you create communication, trading, or sharing through our services, you can freely choose who to communicate, trade, or share with as a third party who can see your transaction content, contact information, exchange information, or share content and other related information.

If you find that your personal information, especially your account or password, has been leaked, please contact our customer service immediately so that we can take corresponding measures based on your application.

Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even sensitive information of yourself or others, such as when you choose to upload pictures containing personal information when posting updates or in public places such as group chats or circles. Please be more cautious when considering whether to share or even publicly share relevant information when using our services.

Please use complex passwords to assist us in ensuring the security of your account. We will do our best to ensure the security of any information you send us. At the same time, we will also report the handling of personal information security incidents in accordance with regulatory requirements.

7、How do you manage personal information

You can access and manage your information through the following methods, and we will respond to your request in compliance with legal and regulatory requirements:

1. Access your personal information

You have the right to access your personal information, except for exceptions specified by laws and regulations. You can access your personal information through the following methods:

Personal Information - If you wish to access or edit other information such as birth date, occupation, interests, and phone numbers in your personal information, you can do so by logging in to your account through "My" - "Settings".

Authorized use - You can log in to your account by clicking on the "Settings" icon in the upper right corner, clicking on "avatar" - "Settings", and turning off or enabling authorization in the authorization options.

2. Correct or supplement your personal information

When you discover that there are errors in the personal information we process about you, you have the right to request us to make corrections or supplements. You can apply for correction or supplementation through the methods listed in "(1) Access to your personal information" in this article.

3. Delete your personal information

You can delete some of your personal information through the methods listed in "(1) Accessing Your Personal Information" in this article.

In the following situations, you can request us to delete personal information through customer service:

3.1 If our handling of personal information violates laws and regulations;

3.2 If we collect and use your personal information without your explicit consent;

3.3 If our handling of personal information seriously violates our agreement with you;

3.4 If you no longer use our products or services, or if you cancel your account;

3.5 If we are no longer providing you with products or services.

If we decide to respond to your deletion request, we will also notify the parties who obtained your personal information from us as much as possible and require them to delete it in a timely manner (unless otherwise provided by laws and regulations, or if these parties have independently obtained your authorization).

After you or we assist you to delete relevant information, we may not be able to immediately back up the information in response to the deletion from the backup system due to the legal and security technology restrictions. We will securely store your personal information and limit any further processing until the backup can be clear or achieve Data anonymization.

4. Change the scope of your authorization and consent

Each business can require some basic personal information to be completed (see "Article 1" of this privacy policy). In addition, for the collection and use of additional personal information, you can contact the customer service of this application to apply for or revoke your authorization consent.

Please note that for some types of personal information, we may not be able to respond to your request to change the scope of authorization if it is necessary for us to truthfully realize the basic functions of this application or fulfill our obligations under laws and regulations. After you revoke your authorization, we will no longer process the corresponding personal information, but your decision to revoke your authorization will not affect the personal information processing we conducted based on your authorization.

5. Constrained Information System Automatic Decision Making

In certain business functions, we may only make decisions based on non manual automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you can contact us through customer service.

6. Respond to your above request

To ensure security, you may need to provide a written request or otherwise prove your identity. We may require you to verify your identity before processing your request.

We will provide a response within 30 days. If you are not satisfied, you can also initiate a complaint through customer service on this application.

We do not charge any fees for your reasonable requests in principle, but for requests that are repeated multiple times and exceed reasonable limits, we will charge a certain cost according to the situation. We may refuse requests that are unfounded, require excessive technical means (such as developing new systems or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup tapes).

In the following situations, according to legal and regulatory requirements, we will not be able to respond to your request:

6.1 Related to the fulfillment of obligations stipulated by laws and regulations by personal information controllers;

6.2 Directly related to national security and national defense security;

6.3 Directly related to public safety, public health, and major public interests;

6.4 Directly related to Criminal investigation, prosecution, trial and execution of judgment;

6.5 The personal information controller has sufficient evidence to indicate that the personal information subject has malicious intent or abuse of power by the supervisor;

6.6 For the purpose of safeguarding the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain my authorized consent.

6.7 The request of the corresponding personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;

6.8 Involving trade secrets.

7. Account cancellation

We will keep the data on your account for 180 days. If you do not wish to continue using our product, you can submit a cancellation application to us through My Settings Account Cancellation.

After you voluntarily cancel your account, we will stop providing you with products or services, and delete or Data anonymization your personal information according to the requirements of applicable laws, except for those required to be retained by laws and regulations.

If you are unable to access this personal information through the above path, you can contact us at any time through our application customer service. We will reply to your visit request within 15 days.

For any other personal information generated by you during the use of our products or services, we will provide it to you in accordance with the relevant arrangements in "(7) Responding to your above request" of this clause.

8、How do we handle information about minors

In digital office/learning, communication, and collaborative activities, we presume that you have corresponding civil capacity. If you are a minor, we request that you ask your parents or other guardians to carefully read this policy and use our services or provide us with information without obtaining the consent of your parents or other guardians.

If you are a child under the age of 14, before using our services, you and your guardian should carefully read the content of this privacy policy to ensure that you can only use our services under the guidance of your guardian with the consent of your guardian, ensuring your safety when using our services and conducting transactions.

If you are a parent or other guardian of a child, please pay attention to whether the child used our services after obtaining your authorized consent. If you have any questions about the child's personal information, please contact our personal information protection department.

For the collection of personal information of minors using our products or services with the consent of our parents or guardians, we will only use, share, transfer or disclose this information when permitted by laws and regulations, explicitly agreed by our parents or guardians, or necessary to protect minors.

9、How does your information transfer globally

Personal information collected and generated during our operations in the China is stored in China, except for the following circumstances:

8.1 There are clear provisions in laws and regulations;

8.2 Obtain your explicit authorization;

8.3 You engage in personal proactive activities such as cross-border live streaming/publishing updates through the internet.

In response to the above situations, we will ensure that your personal information is adequately protected in accordance with this privacy policy.

10、How to update this privacy policy

To provide you with a better product and service experience, we continuously strive to improve our products, services, and technologies. When new services and business processes change, we may update our privacy policy to inform you of your rights under this policy.

For significant changes, we will also provide more prominent notifications (including notification through small red dots or pop-up notifications to you),

Without your explicit consent, we will not reduce your rights under this personal information protection policy. We will post any changes made to this policy on this page.

For significant changes, we will also provide more significant notifications (including for certain services, we will send notifications via email explaining specific changes to personal information protection policies).

The significant changes referred to in this policy include but are not limited to:

1. Our service model has undergone significant changes. For example, the purpose of processing personal information, the type of personal information processed, and the way personal information is used;

2. We have undergone significant changes in ownership structure, organizational structure, and other aspects. Changes in ownership caused by business adjustments, bankruptcy mergers and acquisitions, etc;

3. Changes in the main objects of personal information sharing, transfer, or public disclosure;

4. Your right to participate in personal information processing and the way you exercise it have undergone significant changes;

5. When there are changes in the responsible department, contact information, and complaint channels for handling personal information security;

6. When the personal information security impact assessment report indicates the existence of high risks;

We will also archive the old version of this policy on the dedicated page of this application for your reference.

11、How to contact us

You can contact us through the following methods, and we will respond to your request within 15 days:

1. If you have any questions, opinions or suggestions regarding the content of this policy, you can contact us through the mini program customer service and the APP's "My" - "Contact Customer Service";

2. If you find that personal information may be leaked, you can report it through feedback on this application;

Company Name: GENIUS MANAGER EDUCATION INC.

Office address: A. CBK BLDG 495 QUINTIN PAREDES STREET, BARANGAY
289,BINONDO, NOR,CITY OF MANILA,FIRST DISTRICT,1006

Registered address: A. CBK BLDG 495 QUINTIN PAREDES STREET, BARANGAY
289,BINONDO, NOR,CITY OF MANILA,FIRST DISTRICT,1006

Contact phone number: 09672342853

Emall: hanhaoze99@gmail.com