Feishu - Privacy Policy

Updated Date: May 7, 2020

Effective Date: May 15, 2020

Welcome to use Feishu suite products and services that are provided, operated and controlled by Beijing Feishu Technology Co., Ltd (hereinafter referred to as “we”, “us” or “Feishu Technology”), including Feishu (and applications available in Feishu Workplace which are provided and operated by Feishu Technology), Feishu Lite, Feishu Meetings, Feishu Conference Room and other products and services (hereinafter referred to “this Platform”).

This Privacy Policy sets out the basis on which your personal information will be collected, processed, used and disclosed by us in the process of your access and use of this Platform.

This Privacy Policy constitutes a legally binding agreement between you and us and therefore, we hereby specifically remind you to read carefully and fully understand all the terms of this Privacy Policy, especially such terms that disclaim or relieve our liabilities, terms that restrict your rights, terms of dispute resolution and governing law etc. The terms that may exclude or limit our liabilities are marked in bold or underlined for your special attention. Please read this Privacy Policy prudently and choose whether or not to accept this Privacy Policy and please cease to use or access to this Platform if you disagree with this Privacy Policy.

If you are using this Platform as an Authorized User of Corporate User, we may either collect and process your personal information through your employer (e.g. when your employer opens your account on your behalf) or from yourself (e.g. when you are using this Platform). When your employer opens your account for you to use this Platform, your employer will provide us with your relevant personal information, including your account name, business email address, business phone number (if any), work location information as well as name of your supervisor. Your employer may provide us with your additional personal information, or update your personal information provided to us in the process of your use of this Platform.

If you are using this Platform with a Corporate User account, you understand and agree that in order to enable your use of this Platform, your employer has provided us with your relevant personal information, including your account name, business email address, business phone number (if any), work location information as well as name of your supervisor. Based on your employer’s representations and warranties, your employer has obtained your express authorization before providing any of your personal information to us, and has fully notified you of the purposes, scope and methods of use of your personal information collected. If you cannot confirm the foregoing matters, please immediately cease to access and use this Platform and confirm with your employer. Simultaneously, you may contact us through the contact information set forth in this Privacy Policy and we will coordinate with you to manage relevant matters within our capacity.

Permissions to access contact list, geographic location, camera, microphone, and album will not be automatically turned on and they will only be used with your express authorization and to the extent of particular use of functions and services. You can withdraw any of the foregoing permissions. It should be noted that notwithstanding your express authorization to grant us these sensitive permissions, we will not collect any of these information from you if it is not required for the relevant functions and services. See list of permissions from your operation system.

Before you continue to read this Privacy Policy to understand how we process your personal information and our practical methods of processing your personal information, we hereby set forth the following table of contents. You may click on the headings to directly browse the relevant content you would like to check.

I. Basic Definitions

II. Personal Information We Collect on this Platform

III. How We Use Your Personal Information

IV. How We Use Cookie or Similar Technologies

V. How We Share, Transfer and Disclose Your Personal Information

VI. How We Store Your Personal Information

VII. How We Protect Your Personal Information

VIII. Your Rights

IX. Amendment

X. How to Contact Us

XI. How We Protect Children’s Personal Information

XII. Miscellaneous

I. Basic Definitions

1. Personal Information refers to all types of information recorded electronically or otherwise that can be used independently or collectively to identify the identification of a specific natural person or reflect the activities of such person.

2. Personal Sensitive Information refers to the personal information that may endanger personal and property safety, easily lead to personal reputation, physical and mental health damage or discriminatory treatment once it has been leaked, illegally provided or misappropriated, including identification number, personal biometric information, correspondence record and content, property information, whereabouts, physical health information and transaction information, etc.

3. Employer refers to an entity that registers, logs in and uses this Platform with certain authorization of organization membership management, including but not limited to corporation, governmental authority, other organization, partnership, or individual proprietorship. Employer may register a corporate account on behalf of its members with such member’s authorization.

4. Corporate Account refers to an account of Employer’s member who is invited by the Employer to use the Platform with Employer’s authorization.

5. Affiliates refer to the entities that are controlled by Feishu Technology, control Feishu Technology and under common control with Feishu Technology. Control herein refers to the power of an entity to dominate the main commercial business or activities of another entity and such power can be formed based on equity, voting rights and other relationships that are generally considered to be dominant or significant.

6. De-identification refers to the process during which the data subject cannot be identified without additional information by technical processing of personal information.

7. Anonymization refers to the process during which the data subject cannot be identified by technical processing of personal information and the processed information shall not be recovered.

II. Personal Information We Collect on this Platform

In the process of your use of this Platform, we may collect the following types of personal information.

1. Basic personal information: name, profile picture, phone number and email address

2. Work information: name of organization, department and position

3. Network identity information: account, IP address

4. Personal communication information: messages, chats, documents, calendar information uploaded, released, submitted, and sent by you

5. Contact information: phone contact list, friend list and group list

6. Personal Internet records: operations stored in logs, including history of using software, search history, click history, Cookies

7. Personal active device information: including hardware model, type and version of operating system, device screen size, device hardware serial number, MAC address, unique device identity number (IMEI, Android ID, IDFA, OpenUDID, SIM card IMSI information), time zone, language setting

8. Personal location information: GPS information, WLAN access point, Bluetooth, base station and other sensor information, itinerary, travel and residence information

9. Personal health information: temperature, medical history (during the time period of COVID-19 pandemic only)

Please note that part of the abovementioned information alone will not be sufficient to identify a specific individual. In case we combine such non-personal information with other information to identify certain natural person, or use the same in combination with personal information, then such non-personal information may be deemed as personal information during such combination, and we will anonymize and de-identify such personal information unless with your authorization or otherwise provided by laws and regulations.

III. How We Use Your Personal Information

A. Basic functions of this Platform shall only be operated properly and securely based on certain information and therefore, we may need you to provide us with or allow us to collect the following information

1. Authentication Function

In the process of your use of this Platform, you need to provide your phone number and/or email address which is necessary for your use of this Platform. If you refuse to provide such information, you will not be able to use the normal functions of this Platform. You may also choose to upload profile picture for personalized display purpose once you have logged in with your account. You are not required to register an account and provide the foregoing information if you only browse and search introduction of Feishu Technology products, functions and services on the official website of this Platform.

2. Instant Messaging

To ensure that new members could check all the historical messages anytime and anywhere once they join the group and quickly integrate into the team and project, as well as to improve the group work efficiency, we will store your message logs on a cloud server and automatically synchronize with all devices of group members.

In case of emergency, in order to quickly inform you of the in-app messages, we will push text messages to your registered phone number or call your number to help other users remind you to view information by using the phone number you provided at the time of registration.

3. Calendar Services

You could manage your work status (on business/on leave/in a meeting) and event reminder, subscribe to public schedule and workmate schedule, and send conference call invitation through the calendar functions of this Platform. We will collect and synchronize relevant communication information you managed for your schedules in this Platform to display such information in the calendar entries and help you create and manage your calendar information, arrange tasks and remind you of relevant schedules. For example, when you respond to accept, decline or put meeting as tentative for a conference call invitation, such responses will be noted in your calendar. If you are the owner of a calendar event, you can set your calendar privacy as private, public or public within a specific scope. You can subscribe to other users’ calendars if they permit you to view their calendars.

4. Cloud Docs Services

You can through the cloud docs functions of this Platform view, edit, comment and receive documents on a cloud server at the same time with other colleagues [“Docs Session”]. In order for other users in the same collaborating document editing session to clearly understand your edits, we will collect information posted by you and make you name, profile picture and posted content available to other users when you publish the document content and comments. You can also choose to set the scope of Feishu notification for document sharing and editing.

5. Audio/Video Conferencing Services

In order to achieve audio/video conferencing functions of this Platform or voice interactions with AI robot, you need to turn on the microphone or camera/webcam permissions. Please also note that we will only obtain audio and video information when you voluntarily click on the microphone/camera icon in the client application even if you have agreed to turn on the foregoing permissions.

6. Security Inspection

In order to improve the security of your use of this Platform and protect you or other users or the public’s personal and property security from infringement, prevent fishing websites, frauds, network vulnerabilities, computer viruses, network attacks, network intrusion and other security risks, and more accurately identify violations of laws and regulations, we will automatically collect your IP address, unique device identity number, hardware model and settings, operation system and application functions (such as MAC address) and the details of your use of our services, such as browsing history, time zone, region and language settings, server logs (including visit date and time) and application crash to conduct comprehensive assessment of risks of your account and transactions, authenticate, detect and prevent security incident and take necessary measures including record, audit, analysis and intervention in accordance with laws.

B. In order to optimize your service experience and improve our service quality, you may at your own discretion provide us with or allow us to collect the following information

1. Face Recognition Based Check-in Function

For identity verification purpose, we may collect face images that you voluntarily provide to us and compare with your face image. The aforesaid information is sensitive information and you will not be able to use such function if you reject to provide information on face images, however your use of other functions of this Platform will not be affected.

2. AI Assistance Function

In order to help you improve the efficiency of obtaining information, we use AI technology to provide voice-to-text and search recommendation functions, for which we request users’ communication logs and search logs. In some cases, we will provide users’ search logs after being technically processed by us to third parties providing technical support for the optimization of the search recommendation functions. You acknowledge and understand that under such circumstance the third parties will not be able to associate the foregoing information with any individual.

3. Geographical Location Information

In the event that you intend to have the function of arranging conference rooms when using the calendar function, you shall authorize us to obtain the location information set by your SIM card, IP address and mobile device address, as well as location information obtained by using GPS (in case your mobile device has activated such function). We will use such information to provide you with relevant location-based services. If you reject to provide such information, we may not provide any location-based services to you, however, it will not affect your normal use of other functions and services of this Platform.

4. Pre-installed Application

We will pre-install certain applications of Feishu App Store on this Platform (“Pre-installed Applications”) and you can click to view the Pre-installed Applications in Feishu Workplace for detailed information. If you choose not to use any Pre-installed Application, you may delete such Pre-installed Application and such deletion will not affect your use of other functions/applications of this Platform.

5. Function of Invitation to External Contacts

We will collect your mobile phone contact lists voluntarily provided by you to match external contacts. The aforesaid information will only be used to match your friends and will not be stored or be used by us for any other purposes. Such information is sensitive information and you will not be able to use the abovementioned function if you reject to provide such information, however your use of other functions of this Platform will not be affected.

If you choose to share password, invitation link or QR code to invite external contacts, we will collect your profile picture, name, position and organizational information and only generate password, link or QR code on the clipboard of your device. Please note that your profile picture, name, position and organizational information will be disclosed when inviting external contacts in the process of invitation.

6. Service Optimization Function

In order to provide you with better and more personalized services, such as providing more personalized but consistent services on different server or devices, providing search recommendations, customer service or push information and other services suitable for your needs and understanding product suitability, we will collect your preference, user behavior, location and device information.

The aforesaid information or functions are not necessary for the operation of this Platform which are not mandatorily requested. Your rejection to provide such information or use of such functions will not adversely affect your use of this Platform.

We will take appropriate and feasible measures to avoid collection of personal information irrelevant to the purposes of collection and use. If we use your personal information beyond the intended purposes and the reasonable and directly related scope of use, we will further inform you and obtain your explicit consent before using your personal information.

In the event that we suspend the operation of this Platform, we will cease to collect your personal information in a timely manner, notify you of the suspension by [60]-day public announcement, and delete or anonymize your personal information possessed by us in accordance with applicable laws.

IV. How We Use Cookie or Similar Technologies

We will use cookies and other similar technologies (such as, web beacons, flash cookies, etc., together, “Cookies”) in order to optimize your experience of using this Platform. When you are using this Platform, we may use relevant technologies to place Cookie(s) or anonymous identifier(s) to your device to collect and store information of your access and use of this Platform.

Most of the Internet browsers will automatically accept Cookies, however, it will be autonomously determined by yourself whether or not to accept Cookies. You understand and agree that we may also place Cookies necessary for the operation of this Platform, including Cookies enable you to log in the security area of this Platform. The Cookies placed by us will be invalidated after 15 days or once you terminate the website session. Placing the foregoing essential cookies is the prerequisite of this Platform to provide basic services and you may not be able to use any services of this Platform if you do not agree to the relevant authorization.

V. How We Share, Transfer and Disclose Your Personal Information

A. Sharing of Personal Information

1. We will not share and transfer your personal information to any third parties unless authorized and approved by you in advance. Otherwise, we may share and transfer the personal information which has been de-identified and the recipient cannot re-identify the data subject.

2. In the event that we share your personal information, we shall comply with the following principles:

Authorization and Consent: we shall not share your personal information without your consent unless the shared information has been de-identified and the recipient cannot re-identify the data subject. If the purposes of third party using personal information exceed the original scope of your authorization and consent, they shall further obtain your consent to their use of your personal information.

Legitimacy and Necessity: data sharing must have legitimate purpose and the scope of sharing shall be limited to such categories and amount of personal information necessary to achieve the purposes.

Prudence and Diligence: we will prudently evaluate the purposes of third parties’ use of our shared personal information and will conduct a comprehensive assessment of such third parties’ security capability and require them to comply with relevant cooperation agreement for information sharing. We will also conduct rigorous security monitoring of software development kit (SDK) and application programming interface (API) used by the third parties to obtain information in order to protect data security.

3. Sharing of information to enable functions and services

If you choose to use the services provided by third-party service provider on this Platform (including applications in Feishu App Store), such third-party service provider may share certain of your information with us. You shall review the relevant privacy policy of third-party services for such data which may be shared with us.

For example, in order to complete the registration of your account on this Platform, you agree that the carrier will send a SMS verification code to us based on your personal phone number, otherwise you will not be able to register your account. In order to complete the payment services, protect your legitimate rights and interests, prevent fraud, gambling and other risks and maintain the safe and stable operation of this Platform and payment-related functions, we need to obtain user identification information of your payment account from [Wuhan Ulpay Technology Co., Ltd], the third-party service provider providing wallet function of this Platform.

(1) If you are an employee of Corporate User, when the administrator of the Corporate User chooses to open, manage and use third-party products or services through this Platform, the administrator will consent on your behalf that we provide your personal basic information (account name, name, profile picture, business mobile phone number, business email address, department and organizational structure) and basic permissions to the third-party application service providers, otherwise you cannot use such third-party application services. When using third-party application services, the administrator of Corporate User must read and fully understand and comply with the product functions and privacy protection policies of third-party services. If you, as an individual User, choose to open, manage and use third-party products or services through this Platform, you consent that we provide your personal information (account name, name, profile picture, business mobile phone number, business email address, department and organizational structure) and basic permissions to the third-party application service providers, otherwise you will not be able to use such third-party application services. When you open and use third-party application services, you must read and fully understand and comply with the product functions and privacy protection policies of the third-party services.

(2) Log in and link products in this Platform: With your consent, when you use your Feishu account to log in to a third-party product and/or service (including applications in the Feishu App Store) or bind your account to other third-party accounts, we will share your basic information (name, profile picture) and other information authorized by you with the abovementioned products and services.

(3) Location service provider (Amap). We will share your de-identified location data to the Location service provider (Amap) to provide you with more precise location in the calendar function.

(4) Affiliates. We undertake not to share your personal information with any Affiliates under unnecessary circumstances. Exceptions deemed as necessary circumstance shall include: we may provide you with the service you need only after sharing your information, and for the purpose of providing you with better relevant services, we may store, transfer, and process your personal information using more sophisticated tools, including [Bytedance Cloud] provided by Bytedance and relevant function [plug-ins], provided by Affiliates based on the purposes of using your personal information under this Platform.

(5) Other processing assistance program supporters: you understand and agree that in order to ensure the implementation of the functionalities of this Platform and safe and stable operation of relevant applications, we may integrate SDK provided by third parties for realizing such purposes. We will conduct rigorous security monitoring of SDK used by the third parties to obtain information in order to protect data security. Integrated third parity SDK will be specified in the directory.

We will only share with third parties the information necessary to achieve the purpose, and you understand and authorize our information sharing under such circumstances. If the third party is required to use personal information beyond the foregoing purpose for business reason, such third party shall further obtain your consent for such use of personal information.

Before our collaboration with any third parties, we will make commercially reasonable efforts to test the third party’s security capabilities, assess the legitimacy and necessity of sharing relevant information with such third party, enter into a non-disclosure agreement, conduct technical monitoring of the third parties’ inquiries, and make commercially reasonable efforts to urge third parties to comply with laws and regulations and confidentiality and security measures as agreed in the agreement when using users’ information.

B. Transfer of Personal Information

With the continuous development of our business, your personal information may be transferred in the event that we are involved in a merger, acquisition or asset transfer and if it occurs, we will continue to protect or request the successor to protect your information in accordance with laws, regulations and security standards not less than what have been required in this Privacy Policy, otherwise we will require the successor to obtain your authorization and consent again.

C. Disclosure of Personal Information

We will not disclose your information to the public unless your consent is obtained. However, when we are required to disclose your personal information as per the requirements of laws, regulations, rules, other normative documents, mandatory administrative or judicial requirements, we may disclose your personal information to administrative or judicial authorities in accordance with the requested type of personal information and the methods of disclosure as requested. Upon receiving any requests for disclosure, subject to compliance with the applicable laws and regulations, we will ask such authorities to present the corresponding legal documents, and we will only provide the information to the extent that the administrative and judicial authorities are authorized to obtain for specific investigation purposes. To the extent permitted by laws and regulations, all the disclosed documents will be encrypted.

Please understand that in accordance with laws, regulations and national standards, we may share, transfer, disclose your personal information without your authorization and consent under the following circumstances:

(1) directly related to national security and national defense security;

(2) directly related to public security, public health and significant public interests;

(3) directly related to crime investigation, prosecution, trial and judgment enforcement;

(4) for the purpose of protecting your and others’ life, property and other significant legitimate interests, and where it is difficult to obtain personal consent, unless explicitly prohibited by applicable laws;

(5) personal information disclosed by you to the public;

(6) where personal information is legally collected from publicly disclosed information, such as from legal news reports, government information disclosure and other channels.

In accordance with the laws, sharing and transferring of de-identified personal information which cannot be recovered by the recipient to re-identify the data subject does not constitute an external share, transfer, and disclosure of personal information and therefore it may be processed without further notice to you and obtaining your consent.

VI. How We Store Your Personal Information

A. Location of Storage

We will store your personal information collected and generated during the process of domestic operation within the PRC in accordance with the laws and regulations. Currently, we will not transmit such information abroad and if there is cross-border data transmission, we will comply with relevant national regulations or ask for your permission.

B. Term of Storage

When you are using this Platform, we will continuously retain your personal information for such term that does not exceed the necessary duration of providing services to you. Unless otherwise stipulated in the laws and regulations for the terms of storing specific information, we will delete or anonymize your personal information upon your termination of using this Platform or withdrawal of relevant authorization. We will also delete or anonymize your personal information within a reasonable period in the event that we suspend the operation of this Platform.

VII. How We Protect Your Personal Information

A. We are highly concerned with the security of your personal information. Currently, Feishu has passed the National Information Security Level Protection (Level 3) evaluation and certification and ISO27001 information security management system certification. We have established a data security system to regulate and implement relevant security technical measures in order to prevent your personal information from unauthorized access, amendment and from damage or loss of data. Our network services have adopted a transport layer security protocol and other encryption technologies to ensure the security of your data transmission in the network.

B. We have taken strict data processing permission control to avoid illegal use of data; we have applied various data desensitization methods such as coding and screening and other de-identification technologies to enhance the security of personal information in use; we have adopted encryption technology widely used in the industry to store your personal information and isolated it with data isolation technology, for example, we will encrypt all the information stored in our servers and your terminal devices. We have always implemented such technical measures and organizational management methods and may revise them from time to time to enhance the overall security of the system.

C. In spite that the foregoing reasonable and effective measures have been taken and the standards requested by relevant laws and regulations have been complied with, please understand that even though we have taken every effort to strengthen security measures, the security of personal information for the Internet industry cannot be perfectly guaranteed and warranted due to technical limitations and various potential malicious methods. Nevertheless, we will try our best to assure the security of personal information provided by you to us. Please acknowledge and understand that problems may occur to the system and communication network accessed by you to our services due to the factors beyond our control and therefore we strongly recommend you to take proactive measures to protect the security of your personal information, including without limitation, using complex passwords, changing passwords on a regular basis, and not disclosing personal information such as account password to others.

D. In case of any incidents endangering network security, we will take appropriate remedies in a timely manner in accordance with the emergency precautions for Internet security incident. We will strictly assume corresponding liabilities for any infringement upon your legitimate interests due to any leakage, illegal provision and misappropriation of your personal information arising from the destruction of our physical facilities or technical protection measures.

E. Upon our awareness and knowledge of the unfortunate leakage, illegal provision and misappropriation of your personal information, we will promptly inform you in accordance with the requirements stipulated in laws and regulations and no later than [10] days of: the basic situation and possible impact of such security incident, the measures we have taken or to be taken, suggestions for your own prevention and risk reduction measures, any remedies provided to you, etc. The situation of security incident shall be notified to you by pushing notification in the Platform and we will adopt reasonable and effective means to publish announcements in case it is difficult to notify each subject of personal information. We will also report the personal information security incident and its disposal in accordance with the requirements of regulatory authorities.

VIII. Your Rights

A. How to Access to and Correct Your Personal Information

1. Access to your personal information: to access to your profile picture, name, work status, department, direct supervisor, email address, mobile phone number- access [Feishu-Personal Profile Picture (on the upper left corner)] to check personal information.

2. If you are an Authorized User of the Corporate User, you may submit an application to correct your information to your employer and such application shall be processed by the administrator of the Corporate User.

B. Delete Your Personal Information

You may delete your information in accordance with the methods set out in the foregoing A. How to Access and Correct Your Personal Information.

You may request us to delete your personal information under the following circumstances:

1. If we deal with personal information in violation of laws and regulations;

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

3. If our processing of personal information seriously violates the agreement with you;

4. If you no longer use our products and services, or you voluntarily cancel your account;

5. If we no longer provide you with our products and services.

If we agree with your request to delete information, we will also notify entities that obtain your personal information from us to require them to delete the information concerned in a timely manner (unless otherwise stipulated by laws and regulations or such entity has obtained your separate authorization).

Once you have deleted or we have assisted you in deleting the relevant information, we may not be able to delete the corresponding information from the backup system immediately due to the applicable laws and security technologies. We will store your personal information securely and isolate it from any further processing until the backup can be cleared or anonymized.

C. Methods of Withdrawal of Your Authorization and Consent

In addition to the information necessary for operation of this Platform, you may change the scope of your authorization and consent as the following:

You can log in the mobile client of this Platform, click on your profile picture, choose “System Settings-Privacy Settings” or change the settings of your smart mobile device to give or withdraw your authorization and consent (for example, you can withdraw your authorization and consent of “search and find by phone number” in “System Settings-Privacy Settings” of your mobile client application).

After you have withdrawn your consent, we will not process the corresponding personal information any more. But your decision to withdraw your consent does not affect the previous processing of personal information based on your authorization.

D. How to Cancel Your Account

For an Authorized User of the Corporate User, you can submit an application to your employer for cancel your personal account and such application shall be processed by the administrator of such Corporate User. For an individual user, you can submit an application to cancel your account by clicking on personal profile picture on your mobile client and choosing “System Settings-Account and Security-Cancel Your Account”.

IX. Amendment

We will make every reasonable effort to notify every user in case of any substantial amendments to this Privacy Policy, such as post notifications on this Platform. Please review this Privacy Policy on a regular basis in order to check such amendments. We will also update the last update date and the effective date at the top of this Privacy Policy. Your continued use and access to this Platform after the renewal of this Privacy Policy will be deemed as your acceptance of the updated Privacy Policy and otherwise please cease to use or access to this Platform.

X. How to Contact Us

For any questions, suggestions, or requests of this Privacy Policy, please e-mail us at contact@feishu.cn. In normal cases, we will revert to you within [15] days after the receipt of your contact information and verification of your identity.

We do not charge any fees for your reasonable requests in principle. However, if your requests are lodged repeatedly or beyond a reasonable extent, we will charge fees of a proper amount depending on the cost. We may refuse your requests if they are not directly related to your identity, repeated without reason, need to be replied through too many technical methods (for example, a new system needs to be developed or the existing common practices need to be fundamentally reformed), pose risks to others' legal rights or interests, or are fairly unrealistic.

XI. How We Protect Children’s Personal Information

If you are under age of 14, you shall read and agree to this Privacy Policy under the supervision and guidance of your parents and other guardians before using the services of this Platform.

We will protect children’s personal information in accordance with relevant national laws and regulations and will only collect, use, store, share, transfer or disclose such information to the extent permitted by laws, parents or other guardians or for the necessity of protecting children.

We will make efforts to delete relevant children’s personal information as soon as possible if such information turned to be inadvertently collected by us without prior consent from verifiable parents.

If you are a guardian of a child, you may contact us via the contact information published in this Privacy Policy in the event that you have any questions concerning the personal information of the child under your guardianship.

XII. Miscellaneous

A. This Privacy Policy only applies to your use of the services of this Platform within the territory of Mainland China (only for the purpose of these terms, excluding Hong Kong, Macao, and Taiwan). There may be multilingual versions of this Privacy Policy. If there is any inconsistency or conflict between the terms of each language version, the Chinese version shall prevail.

B. The headings of this Privacy Policy are for convenience and readability only and the headings shall not have any effect on the meaning or interpretation of any terms of this Privacy Policy.