BOXFiSH – PRIVACY POLICY

INTRODUCTION

Welcome to BOXFiSH!

Beijing Boxfish Education Technology Co., Ltd. values your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information (as defined in the "The Information We Collect and How We Collect It" section below) you provide to us.

The use of BOXFiSH (through the BOXFiSH mobile app, www.boxfish.cn or any third party platforms through which BOXFiSH is provided) may involve the collection and use of your Information. It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

By using BOXFiSH, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact our Privacy Officer via email at info@boxfish.cn

SCOPE AND APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to BOXFiSH, including any services associated with BOXFiSH that incorporates this Privacy Policy by reference. Those BOXFiSH-related services may have further privacy-related terms that you must agree to as part of your use of those services.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy. Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you via BOXFiSH (including via direct messaging or the BOXFiSH website), other direct communication to you, or other means prior to the change becoming effective.

By continuing to use BOXFiSH after any changes to this Privacy Policy, with or without notice from us, you are agreeing to the revised Privacy Policy.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

"Information" is Personal Information and Non-Personal Information;

"Personal Information" is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:

"Log Data" is technical information that is automatically collected by us when you use BOXFiSH, whether through the use of cookies, web beacons, log files, scripts and etags (as explained in more detail in the "Tracking Technologies" section below) or otherwise, including:

"Non-Personal Information" is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymized or pseudonymous form.

"Shared Information" is information about you or relating to you that is voluntarily shared on BOXFiSH. Shared Information may include videos and voice recordings as accessed with your prior consent through your device's camera and/or microphone sensor).

HOW WE USE YOUR INFORMATION

We may use your Information for any of the following purposes:

SHARING OF YOUR PERSONAL INFORMATION

By agreeing to this Privacy Policy, you consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section. Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

Sharing for the provision of BOXFiSH

We may share your Personal Information with third party service providers, (such as communication service providers who send emails or push notifications on our behalf), in each case, for the following purposes:

UPDATING OR AMENDING YOUR PERSONAL INFORMATION

If you would like to update or amend your Personal Information within BOXFiSH, you may do so at first instance by logging into your account and making the appropriate changes.

If you wish to make further changes to your Personal Information; request access to, or deletion of, your Personal Information from BOXFiSH; or to request the removal of an unauthorized BOXFiSH account, please contact our Privacy Officer. We will respond to your request within a reasonable timeframe.

In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may require disproportionate technical effort or extremely impractical (e.g. any requests that relate to our backup systems), or are prohibited by law.

COMMUNICATIONS FROM US

Newsletters and other types of communications

When you use BOXFiSH, we may use your Information to send you messages or push notifications to your device. If you no longer wish to receive these communications, you can do so by opting out of notifications at the device level (if available) or contacting our Privacy Officer.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend BOXFiSH for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.

You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.

We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information.

In BOXFiSH, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access BOXFiSH may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.

PERIOD OF USE OF YOUR PERSONAL INFORMATION

We will generally only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the "How We Use Your Information" section above. However, in the following circumstances, we may be required to retain, preserve or disclose your Personal Information for a longer period of time:

Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to our Privacy Officer, or where we offer this option in BOXFiSH, you may also log into your account with us and make the appropriate changes. We will use reasonable efforts to respond to all such requests made to our Privacy Officer within 60 days.

Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through BOXFiSH, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using BOXFiSH may put your Personal Information in the hands of third parties that we cannot control.

TRACKING TECHNOLOGIES

We may, from time to time, use cookies, log files, web beacons, scripts, tags and other tracking technologies to collect, use and store Information about you or relating to you. This section describes how we use such tracking technologies.

Why do we use tracking technologies?

To help us better understand and provide BOXFiSH to you and our users.

Tracking technologies enable us to better understand and provide BOXFiSH to you – for example, tracking technologies help us collect the following Information:

What are tracking technologies?

The "tracking technologies" that we use within BOXFiSH include the following:

How do we use tracking technologies?

Tracking technologies used in partnership with third parties

We and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:

Our own tracking technologies

In addition, we also use our own tracking technologies to personalize your experience on BOXFiSH and for various other purposes, including:

Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyze how you and others use our services and to serve advertising.

General terms in relation to tracking technologies

It is important to note that third party tracking technologies are subject to the relevant third party's own privacy policies and not our Privacy Policy. We are not responsible for any tracking technologies used by third parties.

We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for BOXFiSH via a third party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered BOXFiSH. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.

How you can control tracking technologies

You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal BOXFiSH experience and some or all of BOXFiSH's features may not function properly.

You may also control what tracking technologies-collected Information we receive by certain settings within BOXFiSH.

Specific types of cookies

We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser.

Category of cookies use Description
Authentication These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you. These cookies will also remember certain Information about your personal preferences – for instance, your preferred language and region.
Security We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities. In particular, security cookies help us to prevent fraudulent logins and your user data.
Functionality We use such cookies to perform and improve the functions of our services. In particular, we use these cookies to help us collect information about how our users are interacting with BOXFiSH.
Analysis and Research We use such cookies to follow up and improve our services and provide us with reference data for research and development of new services or functions. For example, these cookies helps us better understand the demographics of the BOXFiSH user base, which in turn helps us consider what new BOXFiSH features may be the most relevant for our users.