Privacy Policy-Golden Finance

Foreword
Welcome to use the products and services of Shanghai GOLDEN Education & Training Co., Ltd. (hereinafter referred to as "GOLDEN")! We value your privacy protection and personal information protection. This Privacy Policy applies to information you retain about your access to and use of your GOLDEN product (or service).
We try to present this privacy policy in a way that is clearer and easier to understand, so we want to be able to truly convey the message we want to convey to you, and we hope that you are providing us with certain information (which may include your Personal information) and the ability to process and share certain information before we can clearly understand the purpose, possible use, and other aspects of such information collection.
This Privacy Policy is designed to help you understand what data we collect, why we collect it, what we do with it, and how to protect it. Please read and understand this policy carefully before using our services. If you do not agree to the content of this policy, we will not be able to provide you with a complete service, and please stop using our products and services immediately. By using GOLDEN's services or products, you are agreeing to what we have described in this policy.

This privacy policy will help you understand the following:

1. The scope of application of this privacy protection policy and the definition of related terms
2. How we collect and use your personal information
3. How do we use cookies and similar technologies?
4. How do we share, transfer, and publicly disclose your personal information?
5. How do we save and protect your personal information?
6. Your rights
7. How do we deal with the personal information of minors?
8. How your personal information is transferred across borders
9. Revision of the Privacy Policy
10. How to contact us

1. The scope of application of this privacy protection policy and the definition of related terms
1.1 This policy applies when you use any of our products and services, regardless of whether the product and service have separate privacy policies, whether you are browsing users (visitors) or registered users. However, please note that this policy does not apply to the following situations:
(1) Information collected by third party services (including any third party websites) accessed through our services;
(2) Information collected by other companies and institutions that conduct advertising services in our services.

1.2 Definition of related nouns
(1) “we” or “GOLDEN” means Shanghai GOLDEN Education and Training Co., Ltd. or the GOLDEN affiliate company that actually provides services for you;
(2) Personal information, personal information refers to various information recorded by electronic or other means that can identify the natural person's personal identity, either alone or in combination with other information, including but not limited to the name of the natural person, date of birth, ID number, personal creature. Identification information, address, telephone number, etc.;
(3) Personal sensitive information refers to personal information that may easily lead to personal reputation, physical and mental health damage or discriminatory treatment, including personally identifiable information, bank account number, communication, if it is disclosed, illegally provided or abused, which may endanger the safety of person and property. Records and content, property information, transaction information, personal information under 14 years of age, etc. You agree that your personally sensitive information will be treated in accordance with the purposes and methods described in this policy;
(4) Equipment, equipment refers to devices that can be used to access GOLDEN products or services, such as desktop computers, laptops, tablets or smartphones;
(5) Related parties and partners refer to Gaodun's affiliates, investment holding companies, alliance members, partners and other trusted third party suppliers, service providers and agents.

2. How do we collect and use your personal information?
2.1 Information you provide to us
(1) When you use our specific products and services, you need to create a personal account on the GOLDEN platform for the purpose of providing products and services to you. When creating an account, you may need to provide data including mobile phone number, email address, Weibo account number and password. After you create an account, you need to further use certain products and services (such as registration), you include Name, ID number\passport, mobile number, education\work background, etc.;
(2) The return visit information you leave when browsing our website in order to understand our products and services, which may include your name, mobile number, email address, occupation, etc.
(3) After you create your personal account, you can choose to upload, set, modify or improve related personal information in the personal information editing office, including: personal avatar, nickname, mobile phone number, email address, login password, delivery address, commonly used Student registration information, etc. If you log in using the facial recognition function on the client, you will also provide your portrait and facial features;
(4) In some offline promotions, our (or our affiliates, partners) staff may distribute promotional materials and retain some of your personal information when providing you with product and service inquiries. May include your name, mobile number, email address, college, occupation, WeChat or QQ number;
(5) When you prepare for consumer payment in the purchase of our products or services, you need to provide us with relevant personal information, such as name, gender, ID number, password, grade, bank card number, transaction bill information, delivery address, Invoice information, remark information, etc.;

2.2 Our information is automatically obtained by us
  (1) Device information, in order to provide better products and / or services and improve the user experience, we will collect device attribute information (such as your hardware model, operating system version, device configuration, unique device identification) that you log in or use the account. , international mobile device identity code IMEI, network device hardware address MAC, advertisement identifier IDFA, etc., device connection information (type of browser, telecom carrier, language used) and device status information (eg device sensor data, device) Application installation list). For information collected from your various devices, we may associate them so that we can provide you with consistent service on those devices.
  (2) Log information, when you use GOLDEN platform products and services, our server will automatically record some information, such as your use of our products and / or services, IP address, URL of the service accessed, browse Type and language used, information to download, install or use mobile applications and software, information to communicate with communications software, and date, time, duration, etc. to access the service.
  (3) Location information, when you use the high-end platform products and services with location function, when you turn on device location and use our location-based related services, we may collect and process your actual location. Information so that you do not need to manually enter your own geographic coordinates to get the relevant services. We use a variety of technologies for positioning, including IP addresses, GPS, and other sensors that provide relevant information. You can stop the collection of your location information by turning off location, but you may not be able to get the service or feature, or you may not be able to achieve the desired performance of the service.

2.3 Your personal information collected by indirect access
When you use GOLDEN's related party and partner services through our products or services, you agree that we will receive, use, aggregate, and analyze from our affiliates and partners based on actual business and cooperation needs. Provided your personal information.

2.4 Personal sensitive information
Before providing any information that is sensitive to GOLDEN, please be aware that such provision is appropriate and that your personal sensitive information may be processed in accordance with the purposes and manner described in this guide.
We will collect and use your sensitive information to achieve the functions associated with the GOLDEN business with your consent, and allow you to make disapproval of the collection and use of such sensitive information, but refusing to use this information will affect You use related features.

2.5 We may use the information collected during the process of providing services to you for the following purposes.
  (1) By using the collected information, we will use it for data collation, analysis and research, so that you can have a better experience and improve our products and services;
  (2) To improve the security of your use of our products and services, we may use your information for authentication, customer service, security, fraud monitoring, etc. to prevent, detect, investigate fraud, endanger security, illegal or Violation of our agreements, policies or rules to protect you and our legal rights;
  (3) We may recommend products that have a higher degree of matching with you or provide you with new products or services based on your use of the products or services, etc.; may include products or services including It is not limited to the products or services involved in various websites, apps, WeChat, applets, lectures and various marketing activities of GOLDEN (or GOLDEN Affiliates);
  (4) To allow you to participate in surveys about our products and services or through our products and services, it is up to you to participate in the survey and it is up to you to provide information.
  (5) In order to improve our products and services, GOLDEN may share user usage information with third-party analysts to demonstrate the overall usage of our services and analyze future trends, but these statistics will not include your Any identification information;
    In order for our users to have a better experience, improve our services or other uses that you agree to, we may collect personal information collected through one of our services in accordance with relevant laws and regulations. Or a personalized way for our other services. For example, your personal information collected while you use one of our services may be used in another service to provide you with specific content or to show you information that is relevant to you, not generally pushed.
Please note that unless you delete or withdraw your consent (ie, refuse to collect and use it through the system settings), all personal information you provide while using our services will continue to authorize us during your use of our services. Used within the scope of this policy. After you cancel your account, we will delete your personal information or anonymize it according to your request, except as otherwise provided by laws and regulations.

How do we use cookies and similar technologies?
When you use our services, we store a small data file called a cookie on your computer or mobile device. Cookies usually contain an identifier, a site name, and some numbers and characters. We use this information to determine if a registered user has logged in, improve product or service quality, and optimize the user experience. If you don't want your personal information to be stored in a cookie, you can configure your browser and choose to disable cookies. Disabling the cookie feature may affect your access to GOLDEN or the full availability of the services provided by GOLDEN.
We do not use cookies for any purpose other than those stated in this guide. You can manage or delete cookies based on your preferences. You can clear all cookies saved on your computer, and most web browsers have the ability to block cookies.

4. How do we share, transfer, and publicly disclose your personal information?
4.1 Sharing
(1) We do not share your personal information with any company, organization or individual, except:
l Obtain your explicit authorization or consent in advance: After obtaining your explicit consent, we will share your personal information with other parties.
l Sharing under statutory circumstances: Share your personal information in accordance with applicable laws and regulations, legal procedures, government mandates or judicial decisions;
l It is necessary to provide your personal information to third parties in order to protect the interests, property or safety of GOLDEN and its users or the public from harm, to the extent required by law;
lShare with our affiliates: Your personal information may be shared between our affiliates. We only share the necessary personal information and this is subject to this privacy policy. If the affiliate company wants to change the purpose of processing personal information, it will ask for your authorization again;
lShared with authorized partners: In order to provide you with better and better products and services, some of our services will be provided by authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legitimate, legitimate, necessary, specific, and specific purposes, and will only share the personal information necessary to provide the service. At the same time, we will enter into a strict confidentiality agreement with our partners to process your personal information in accordance with our instructions, this guide and any other relevant confidentiality and security measures. Our partners do not have the right to use the shared personal information for any other purpose. If you refuse to collect personal information that our partners must provide in order to provide services, it may result in your inability to use the third party service in GOLDEN.
(2) Currently, our authorized partners include the following types
l Advertising, consulting services / advertisers. We will not share your personal information with advertising and consulting services without your authorization. However, we may treat information that is unrecognized by your recipient and that cannot be recovered by the recipient, such as an anonymized user image, shared with an advertising or consulting service provider or advertiser to help them not identify you personally. Under the premise, improve the effective reach of advertising, and analyze the use of our products and services, etc.
l Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business on a global scale, including providers of services such as express delivery, software development, and data storage. We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, and require them to process personal information in accordance with our instructions, privacy policy and any other relevant confidentiality and security measures.

4.2 Transfer
We will not transfer your personal information to any company, organization or individual other than GOLDEN and its affiliates, with the following exceptions:
(1) Obtain your explicit authorization or consent in advance;
(2) meeting the requirements of laws and regulations, legal procedures or mandatory government requirements or judicial decisions;
(3) If we or our affiliates involve transactions in the acquisition, merger, separation, liquidation, acquisition or sale of assets or business, your personal information may be transferred as part of such transactions, we will ensure that such The confidentiality of the information at the time of transfer, and requires that the new company or organization holding your personal information continue to be bound by this privacy policy, otherwise we will require the company and organization to re-submit your authorization.

4.3 Public disclosure
We will not disclose your personal information publicly unless we have your explicit consent.
We may disclose your personal information to the authorities based on laws, legal procedures, litigation or mandatory requirements of the competent government authorities. However, we guarantee that, when the above situation occurs, we will require the disclosure of the requesting party to issue valid legal documents corresponding to it, and to take legal and industry-standard security measures for the disclosed information.

4.4 Sharing, Transfer, and Public Disclosure of Exceptions to Personal Information Authorization
In accordance with the relevant laws and regulations, in the following cases, we may collect and use the necessary personal information without your consent:
(1) directly related to national security and national defense security;
(2) directly related to public safety, public health, and major public interests;
(3) directly related to criminal investigation, prosecution, trial and judgment execution;
(4) It is difficult to obtain the consent of the person for the protection of the life and property of you or other individuals;
(5) The personal information collected is disclosed to the public by yourself;
(6) Collecting your personal information from legally publicly disclosed information, such as from legitimate news reports and government information disclosure;
(7) necessary to sign and perform the contract according to your requirements;
(8) It is necessary to maintain the safe and stable operation of GOLDEN's products and services, such as the failure to discover or dispose of products or services;
(9) Other circumstances as stipulated by laws and regulations.

5. How do we protect your personal information?
The security of your personal information is critical to us. We will strictly abide by relevant laws and regulations and take reasonable and feasible measures approved by the industry to protect your personal information. Prevent unauthorized access, disclosure, use, and modification of information to prevent information from being damaged or lost.

5.1 Technical measures and data security measures
We strive to protect your personal information by taking various physical, electronic, and administrative security measures that meet industry standards. We actively establish data classification and grading systems, data security management practices, and data security development specifications to manage the storage and use of regulated personal information to ensure that personal information not related to the services we provide is not collected.
We conduct comprehensive security controls on data by signing confidentiality agreements, monitoring and auditing mechanisms with our contacts. Prevent unauthorized access, public disclosure, use, modification, damage or loss of your personal information.
We have used industry-standard security measures to protect the personal information you provide and to protect your data from unauthorized access, public disclosure, use, and modification to prevent data corruption or loss. We will take all reasonable and practicable steps to protect your personal information. For example, when you exchange data (such as credit card information) between your browser and GOLDEN, it is protected by SSL encryption; we use encryption to ensure data confidentiality; we use trusted protection mechanisms to protect data from malicious attacks. We will deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we conduct security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

5.2 Safety Certification
We have established a good coordination and communication mechanism with regulatory agencies and third-party assessment agencies to timely defend against and deal with all kinds of information security threats, and provide comprehensive protection for your information security.

5.3 Security incident handling
We will do our utmost to ensure the security of any information you send us, but please understand that due to technical limitations and various malicious means that may exist in the Internet industry, it is not always possible to ensure 100% security of information. You need to understand that the systems and communication networks you use to access our services may be problematic due to factors beyond our control. In order to prevent the occurrence of security incidents, we have developed a proper early warning mechanism and emergency plan. In the event of unfortunate personal information security incidents, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of security incidents, the disposal measures we have taken or will take, and the advice you can take to prevent and mitigate risks. And remedies for you, and immediately launch an emergency plan to minimize losses. We will promptly inform you of the incidents by phone, push notification, etc. When it is difficult to inform users one by one, we will issue announcements in a reasonable and effective manner.
At the same time, we will also report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities, and closely cooperate with the work of government agencies.

6. Your rights
In accordance with China's relevant laws, regulations, standards, and other countries and regions, we guarantee that you exercise the following rights to your personal information.

6.1 Access rights. You can log in to your personal account at any time, access or edit the profile information in your account, change your password, add security information, account association or identity authentication.

6.2 Correction rights. You have the right to make corrections or updates to the wrong or incomplete information, after verifying your identity and correcting it without affecting the objectivity and accuracy of the information. You can do it on our website or client. Correction, or in certain circumstances, especially when data is incorrect, submit your correction request to us through the contact information provided at the end of this policy, and ask us to correct or update your data, unless otherwise required by laws and regulations. However, for security and identification purposes, you may not be able to modify some of the initial registration information submitted at the time of registration.

6.3 Right to delete. You may request us to delete your personal information through the contact information provided in this Privacy Policy. For example, you no longer need us to continue to provide services to you, except for data anonymization or other provisions of laws and regulations.

6.4 Change or revoke your authorization. If you want to change the scope of the relevant features (such as location, contacts, camera), you can modify your personal settings through your hardware device, or operate in the relevant function settings interface in our products or services. If you encounter operational problems during this process, you can contact us at the end of this policy.
When you cancel the authorization to collect personal information, we will not collect the information and will not be able to provide you with the above services; however, you acknowledge and agree that unless you exercise the aforementioned "right to delete", your This behavior does not affect the processing and storage of personal information that we perform based on your previous authorization.

6.5 Cancellation rights. You can cancel your account by contacting our customer service or by other means that we publicize (except as otherwise provided by laws and regulations). Once you cancel your account, you will not be able to use all the products or services we provide, so please be cautious. . In order to protect the legitimate rights and interests of you or others, we will judge whether you support your cancellation request in combination with the use of each product we provide. For example, if you have an unused balance in your account and you have a course, we will Your request will not be supported immediately, but you will be prompted to do so first. Except as otherwise provided by laws and regulations, after you cancel your account, all the information in your account will be emptied and your personal information will be deleted according to your request. When you log in to our service through a third-party account (such as WeChat, Weibo, QQ, etc.), you need to apply for cancellation of the account with a third party.

6.6 Know in advance that products and services will cease to operate. We are always willing to accompany you. If some or all of our products and services are forced to stop operating due to special reasons, we will send you an email or other suitable contact on the main page or website of the product or service 15 days in advance. You will be notified of your way, and will stop collecting your personal information, and will delete or anonymize your personal information held in accordance with the law, except as otherwise provided by laws and regulations.

7. Information protection for minors

We attach great importance to the protection of information about minors.
Our products, websites and services are primarily for adults. If you are a minor, we encourage you to ask your guardian to read this Privacy Policy carefully and use our products or services or provide us with the information of your guardian.
If your guardian does not agree that you use our services or provide information to us in accordance with this policy, please terminate your use of our services immediately and notify us in time so that we can take appropriate action.
If the guardian finds that we have collected personal information about the minor without the consent of the guardian, please contact us via personal information protection feedback and we will try to delete the data as soon as possible.

8. How does your personal information transfer globally?

In principle, the personal information we collect and generate in China will be stored in China. If some products or services involve cross-border, we need to transmit your personal information to overseas, we will strictly follow the rules and regulations, and ensure the security of your personal information.

9. Update of this privacy protection policy

Our privacy policy may change.
We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes to this policy on this page.
For major changes, we will also provide more noticeable notices (including notifications that we will post through the GOLDEN official website or even provide you with a pop-up reminder). Significant changes referred to in this policy include but are not limited to:
(1) Significant changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way in which personal information is used, etc.;
(2) We have undergone major changes in the ownership structure, organizational structure, etc., such as business adjustments, bankruptcy mergers and other changes caused by owners;
(3) The main objects of personal information sharing, transfer or public disclosure have changed;
(4) Significant changes in your rights to participate in the processing of personal information and how it is exercised;
(5) When we are responsible for handling the change of personal information security, contact information and complaint channels;
(6) The personal information security impact assessment report indicates that there is a high risk.

Ten, contact us

10.1 If you have any comments or suggestions about this Privacy Policy, you can contact us at fawu@gaodun.com. In order for us to process your issue efficiently and to provide you with timely feedback, you will need to submit proof of identity, valid contact information and written request and relevant evidence, we will process your request after verifying your identity. In general, we will respond within 10 days.

10.2 If you are dissatisfied with our response, especially if you believe that our personal information handling actions have harmed your legal rights, you can also file a lawsuit in a court of competent jurisdiction in GOLDEN's domicile.