Xhanzi Education Co., Ltd. (“Xhanzi”, “we”, “our”, or “us”) is committed to protecting your privacy. Our Privacy Policy (the “Policy”) explains how we collect, use, disclose, and protect information about you or associated with you (“personal information”), and your choices about the collection and use of your information. This Privacy Policy applies to the online services offered by Xhanzi such as our website at www.xhanzi.com, and any other online service location (collectively the “Service”) that makes this Privacy Policy available to you.

By using the Service, you agree to our Terms of Service and consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

Information Collection

This section will discuss what type of information is collected. This includes categories of information that (1) you provide to us directly, (2) is collected by us automatically, and (3) we receive from third-party sources.

1. Information You Provide Directly to Us

You can browse our site without providing personal information, but you must register in order to access most of the features of Service. Certain personal information—such as a user name, email address—are required to create an account. You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

The following are categories of information we collect:

• Contact Data, including your first and last name, email address, postal address, and phone number.
• Account Credentials, including your username, password, password hints, and information for authentication and account access.
• Demographic Data, including your age, gender, and country.
• Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
• Profile Data, including your images, preferences and favorites.
• Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in your public profile, in reviews, and comments) as well as any content that you generate and submit for grading. We also collect content within any messages you exchange with us through the Service.

You may choose to voluntarily provide other information to us, and, in such instances, you are solely responsible for such information.

2. Information Collected Automatically

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect includes:

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

We use various current – and later – developed tracking technologies to automatically collect information when you use the Service, including the following:

• Log Files, which are files that record events that occur in connection with your use of the Service.
• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
• Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

Use of Information

This section discusses how collected information is used by Xhanzi.

We collect this information for a number of business purposes including to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages.

The categories with respect to our business purposes for using information include:

• Operate and manage our Service, including your registration and account.
• Perform services requested by you, such as respond to your comments, questions, and requests, and provide customer service.
• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Preventing and addressing fraud, breach of policies or terms, and threats or harm.
• Monitoring and analyzing trends, usage, and activities.
• Conducting research, including focus groups and surveys.
• Improving the Service or other Xhanzi websites, marketing efforts, products and services.
• Developing and sending you direct marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
• Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
• Sending you advertising.
• Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

Sharing of Information

This section explains our sharing practices with respect to information collected.

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of entities to whom we disclose and have shared information with include the following:

• Service Providers. We share information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, and technical support. We may permit our service providers to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• Vendors and Other Parties. We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
• Public Information. We share information you make public through the Service, such as information that you post on public boards or other public sections of the Service. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
• Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
• Facilitating Requests. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Service.
• Consent. We share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

Social Media and Technology Integrations

We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. Some examples include:

• Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. We may get a commission if you purchase a product after clicking on a link to an affiliate’s website.
• Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
• Video conference and online education. We offer our content through video conference provider such as Zoom and online education provider such as Nearpod. Any information you provide to us when you engage with our content is treated in accordance with this Privacy Policy.

Please note that when you interact with other entities, including when you leave our Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Analytics and Advertising

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Service, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Some technology services may provide us with their own data, which is then uploaded into another technology service for matching common factors between those datasets.

As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of service.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

Your Rights and Choices

You have rights and choices with respect to information that relates to you, however such rights will vary depending on the category of information, and the subsequent use of such information. This section further describes your rights.

1. Account Information.

You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

2. Tracking Technology Choices.

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

3. Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

4. Communications.

• E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link. Please note that you cannot opt-out of non-promotional emails, such as those about your account, servicing, or our ongoing business relations.

Please note that your opt out is limited to the email address and device used and will not affect subsequent subscriptions.

Data Security

Xhanzi uses commercially reasonable administrative, and technical security safeguards designed to preserve the integrity and security of all information collected through the Service. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable and appropriate steps to investigate the situation, notify those individuals whose information may have been compromised in accordance with any applicable laws and regulations, and take other steps as appropriate. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the Xhanzi Service, such as social networks. Xhanzi is not responsible for the functionality or security measures of any third party.

Changes to this Privacy Policy

Xhanzi reserves the right to modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically.

Links to Other Websites and Services

The Services may, from time to time, contain links to and from websites, platforms, and other services not operated or controlled by us. If you follow a link to any of these locations, please note that these locations have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those locations.