隱私政策
Effective May 24, 2018.
1. Introduction
1.1 The ABCs of Chinese website and services are used by thousands of users around the world. To better provide service to all our users and customers, we have included GDPR (General Data Protection Regulation) compliance information in our Privacy Policy. This Privacy Policy explains how we collect, share and use personal data. We care about your privacy and appreciate your patronage.
1.2 We are committed to safeguarding the privacy of our website visitors and service users.
1.3 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4我們使用我們網站上的cookies。只要這些cookie不是絕對必要的提供我們的網站和服務，我們會要求你同意我們使用cookies當您第一次訪問我們的網站。
1.5在這一政策， “我們”， “我們” 和 “我們的” 是指近代中國學習系統，LLC。，它控制當您使用我們的“服務”收集到的信息。中國現代學習系統公司。提供語言學習的工具和產品，還擁有並運營多個網站。所有這些產品，加上我們的其他服務和網站是我們的 “服務” in this policy. For more information about us, see Section 13
。1.6 我們最新的隱私政策自動地成為對2018 5月24日，我們所有的服務的用戶的影響。 By continuing to use our services after this date, you agree to our updated Privacy Policy.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“使用數據“). The usage data may include your IP address, geographical location, device type and version, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“帳戶數據”) and your information included in your personal profile on our website (“配置文件數據”). The account data and profile data may include your username, name, email address, address, telephone number, profile pictures, gender, date of birth, educational details and employment details. The account data and profile data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.4 We may process your personal data that are provided in the course of the use of our services (“服務數據”). The service data may include your username, name, email address, address, telephone number, profile pictures, gender, date of birth, educational details and employment details. The source of the service data is you, your employer, or your educational institute. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.6 We may process information that you post for publication on our website or through our services (“發布數據“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“查詢數據“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.8 We may process information relating to our customer relationships, including customer contact information (“客戶關係數據”). The customer relationship data may include your name, your employer, your job title or role, your educational institute, your contact details, and information contained in communications between us and you or your employer or educational institute. The source of the customer relationship data is you, your employer, or educational institute. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“交易數據”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“通知數據“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.11 We may process information contained in or relating to any communication that you send to us (“對應數據“). The correspondence data may include the communication content and metadata associated with the communication. Our website may generate the metadata associated with communications made using the website or service forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.12我們可以處理任何在這個政策確定了你的個人資料在必要時設立，行使或法律要求辯護，無論是在法庭程序或行政或外的法庭程序。該處理的法律依據是我們的合法利益，即保護我們的合法權利主張，您的合法權利和他人的合法權益。
3.13我們可以處理任何在這個政策確定了你的個人資料在必要時獲得或維持保險，風險管理，或獲得專業意見的目的。該處理的法律依據是我們的合法利益，抵禦風險我們的業務即適當的保護。
3.14除了為我們可以處理您的個人資料載於本第3節中，我們也可以處理的特定用途的任何您的個人數據，其中這樣的處理是必要的遵守，這是我們的主題，或在法律義務為了保障您的切身利益或其他自然人的切身利益。
3.15請不要提供任何其他人的個人資料給我們，除非我們提示您這樣做。
4.提供您的個人資料給他人
4.1 We may display your username, learning achievements and time spent using our services on an achievement board, recent activity board, instructor dashboard, or similar platform. We may also display this information in periodic newsletters or marketing material。
4.2我們可能會透露你的個人資料，以員工和承包商進行產品開發，客戶服務和技術支持的目的。
4.3我們可能會透露你的個人資料給分包商和服務供應商誰幫助我們，包括網站託管服務提供商，營銷和分析服務，安全和防欺詐服務，訂閱管理服務，身份驗證服務和業務工具服務只要合理必要的改進我們的網站和服務。
4.4我們可能會透露你的個人資料給我們的保險公司和/或專業顧問，只要合理地需要獲得或維持保險，風險管理，獲得專業意見或法律要求建立，行使或防禦的目的，無論是在法庭上訴訟或行政或外的法庭程序。
4.4關於我們的網站和服務金融交易可以通過我們的支付服務提供商，貝寶處理。我們將分享我們的支付服務提供商交易數據只需要處理您的款項，退還這些款項和處理與這樣的付款和退款的投訴和查詢的目的的程度。你可以找到有關的支付服務提供商的信息’ 隱私政策和做法 https://www.paypal.com/us/webapps/mpp/ua/privacy-full。
4.5 We may disclose your enquiry data to third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
4.6除個人資料載於第4節的具體披露，我們可以這樣的披露是必須遵守，這是我們的主題，或為了保護您的切身利益或法律義務透露您的個人資料另一自然人的切身利益。這樣的披露是必要的法律要求建立，鍛煉還是防守，無論是在法庭程序或行政或外的法庭程序，我們也可能披露您的個人數據。
4.7我們可能會披露與購貨你的數據給購買者或者我們的資產或業務，他們的專業顧問的全部或部分的準買家。
5.您的個人數據跨國傳輸
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 As a provider of a global service, we run our service with common operational practices and features across multiple jurisdictions. For example, we currently store data in hosting facilities provided by Microsoft Azure (see https://docs.microsoft.com/en-us/azure/security/azure-security 或 https://www.microsoft.com/en-us/trustcenter/security/azure-security for information on their security practices). We may also allow employees and contractors located around the world access to certain data for product development, customer and technical support purposes.
5.3 Your personal data may be transferred to other countries for purposes related to providing products and services. The European Commission has made an “充足的決定” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards and certain legal frameworks relating to the transfer of data, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 We will retain your personal data as follows:
(a) We retain your personal information for as long as is necessary to provide the services to you and others, and for compliance with our legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
(b) We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our services. Where we retain information for service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our services, not to specifically analyze personal characteristics about you.
(c) If the Services are made available to you through an organization (e.g., your employer or educational institute), we retain your information as long as required by the administrator of your account.
(d) If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
(e) If you no longer want us to use your personal information or to provide you with services, you can request that we erase your personal information and close your account. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.
6.3儘管本節6中的其他規定，我們可能會保留您的個人數據，其中這樣的保留是必要的遵守，這是我們的主題，或為了保護您的切身利益或其他自然人切身利益的法律義務。
7.修正
7.1我們可以通過我們的網站上發布了新版本不時地更新本政策的時間。
7.2您應定期檢查我們的網站，以確保您滿意的任何改變這一政策。
7.3我們會通知你的這個政策通過電子郵件顯著變化。
8.您的權利
8.1 In this Section 8, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first digital copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4你必須有任何不準確的個人資料，你糾正的權利，考慮到處理的目的，有任何不完整的個人資料，你完成。
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11如果您認為我們對您的個人信息處理侵犯數據保護法，你要投訴與負責數據保護監管機構的合法權利。你可以在你慣常居住地，你的工作場所或涉嫌侵權的地方的歐盟成員國這樣做。
8.12要，對我們的個人信息處理的法律依據是同意的程度，你必須隨時撤回同意的權利。撤離前撤出不會影響處理的合法性。
8.13 You may exercise any of your rights in relation to your personal data by written notice to our support email support@abcsofchinese.com, in addition to the other methods specified in this Section 8.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “一貫” 餅乾或 “會議” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We limit our use of cookies by instead using HTML5 local storage to facilitate the use of our website and services. Data stored includes:
(a) username and other details displayed to you about your account.
(b) achievement and progress data tracking.
(c) caching of service data to make the application run more quickly.
(d) login token to keep user signed in.
10.2 We may use cookies for analysis purposes, as specified in Section 11.
11. Cookies used by our service providers
11.1我們的服務提供商使用cookie，當您訪問我們的網站時，這些cookie可能會存儲在您的計算機上。
11.2我們使用Google Analytics（分析）來分析我們網站的使用情況。 Google Analytics（分析）通過Cookie收集有關網站使用的信息。收集到的與我們網站有關的信息用於創建有關我們網站使用情況的報告。您可以通過以下網址獲得Google的隱私權政策： https://www.google.com/policies/privacy/。
11.3我們可以在我們的網站上發布谷歌的AdSense廣告。要確定您的利益，谷歌追踪在我們的網站和跨使用cookie的網頁其他網站你的行為。這種行為跟踪允許谷歌定制您在其他網站上看到，以反映您的興趣的廣告。您可以查看，刪除或添加通過訪問與瀏覽器相關的興趣類別： https://adssettings.google.com。您也可以選擇使用這些設置或使用網絡廣告組織的多cookie的退出機制在AdSense合作夥伴網絡的cookie出來： http://optout.networkadvertising.org。但是，這些選擇退出機製本身使用cookie，並且如果您從瀏覽器中清除cookie，則不會保留選擇退出。為確保針對特定瀏覽器保留選擇退出狀態，您不妨考慮使用以下網址提供的Google瀏覽器插件： https://support.google.com/ads/answer/7395996。
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2阻止所有cookie將對許多網站的可用性產生負面影響。
12.3如果您阻止cookie，則將無法使用我們網站上的所有功能。
13.我們的詳細信息
13.1該網站和服務由Modern Chinese Learning Systems，LLC擁有和運營。
13.2我們在台灣註冊。
13.3您可以使用support@abcsofchinese.com通過電子郵件與我們聯繫。
14.數據保護官
14.1我們的數據保護官員的聯繫方式是：support@abcsofchinese.com。