1.Special Tips

1.1.Donner is well aware of the importance of personal information to users, and will protect users’ personal information and privacy in accordance with relevant laws and regulations where we operates. . To this end, Donner has formulated Donner Privacy Policy (hereinafter referred to as this “Policy”), and provide the following special tips: Please carefully read and fully understand this Policy before using the mobile phone application or our website of Donner (hereinafter referred to as “Donner”) and related services. Users’ use of or continuing to use the products and services provided by Donner means that the users agree that the relevant information of the users are used and handled according to this Policy. If users have any objections or questions about the terms of this Policy, please communicate with Donner for feedback through the contact information published in Article 9 “Contact Us” of this Policy.

1.2.This Policy applies to all products and services provided by Donner. The data controller responsible for this application and website is Donner, who can be contacted at Room 7002 and 7003, 7th Floor, Digital Entertainment Industrial Park, the Great Bay Area District, No. 28, Huangpu Park West Road, Huangpu District, Guangzhou (hereinafter referred to as the “Company”) will provide related Internet-based products and services (hereinafter referred to as the “Service”) in accordance with the provisions of Donner Service Agreement and the operating rules thereof issued from time to time.

1.3.Since the Company will launch more products and services in the future, and the contents of products and services provided to users are also different, this Policy is a general privacy policy applicable to Donner. For specific products and services to be launched later, the Company will also formulate specific privacy policies, so as to more specifically stipulate with users on the privacy policies and rules of the Company. Users should fully read and agree with all the contents of the specific privacy policies before using the specific products and services.

1.4.Only when users confirm and agree to the modified Policy will the Company collect, use, process and store the users’ personal information according to the modified Privacy Policy. Users have the right to refuse to agree to the modified Policy. Once the users refuse to agree to the modified Policy, the users will be unable to continue to use the related services and functions of Donner.

2.Collect and Use Users’ Personal Information 

2.1.The Company collects and uses personal information provided by users in the process of using services or generated due to the needs of products or services in accordance with laws and regulations and following the principles of justice, legality and necessity. If the Company intends to use the users’ personal information for other purposes not specified in this Policy, or use the collected information for other purposes based on specific purposes, the Company will inform the users in a timely and reasonable manner.

2.2.Donner will collect and use users’ personal information in the following scenarios.

2.2.1.Collect and use users’ personal information during the account registration process.

Data Processing Activities Type of Data Legal Basis for Processing
When a user registers a service account user’s name, password, mobile phone number or email address and social network ID the picture of the user’s name, user name and personal information (if the user registers with social network ID) Where you have provided your consent
When a user log in with an account of a third-party platform (such as Facebook or Google) user’s name, nickname, avatar and authentication information  Where you have provided your consent
When a user voluntarily adds additional profile the user can also voluntarily provide personal information chart, birth date, gender, place and other information about the user and the user’s interests on the personal information page Where you have provided your consent
When a user upload content content uploaded by users to the Service can be used by others to identify the users (for example, photos of users, recordings or texts containing users’ names, status updates, comments on content that mentions users). Where you have provided your consent

 

2.2.2.Collect and use users’ personal information in the search process

Data Processing Activities Type of Data Legal Basis for Processing
When a user uses the search function in Donner equipment information, log information, including searched words or phrases, browsing records and time, search time and times Necessary for our legitimate interests: to support customers and other enquiries, to operate our business

 

2.2.3.Collect and use users’ personal information during multimedia presentation and playing

Data Processing Activities Type of Data Legal Basis for Processing
When Donner provides users with audio and video display and playback services during the promotion of music and musical instrument courses device model, device name, unique device ID, browser type and settings, language settings, operating system and application version, login IP address, network access method, network quality data, mobile network information, product version number and network log information (such as operation log and service log) Where you have provided your consent

 

2.2.4.Collect and use users’ personal information in the process of operation service

Data Processing Activities Type of Data Legal Basis for Processing
When a user initiates a complaint, appeal or consultation to the customer service platform of Donner, user’s identity needs to be verified Account information, name, mobile phone number, email and other contact information, communication information between the user and the customer service platform (including text/picture/audio/video/call records) and other necessary information related to the user’s needs Where you have provided your consent

 

2.2.5.Collect and use users’ personal information in the process of sharing pictures, texts and videos

Data Processing Activities Type of Data Legal Basis for Processing
When a user uses the functions of commenting, sharing and posting Above-mentioned text, picture and video information provided by the user voluntarily,  user’s mobile phone photo album with the user’s permission to facilitate the user to share videos and pictures Where you have provided your consent

 

2.2.6.Collect and use users’ personal information during the downloading of videos and screenshots 

Data Processing Activities Type of Data Legal Basis for Processing
When a user logs in to products of Donner with mobile devices and use the functions of video download and screenshot download Obtain the storage permission of the user’s device  Where you have provided your consent

 

2.2.7.Collection and use of personal information of users during purchasing

Data Processing Activities Type of Data Legal Basis for Processing
When the user purchases goods or services in Donner's products and services, to help the user successfully completes the transaction, guarantees the user's transaction security, inquires the order information, provides customer service, etc. Information on the goods or services in the transaction, consignee information (the name of the consignee), delivery address, billing address and contact number and zip code transaction amount, order time, order number, order status, payment method, payment serial number, payment status  Performance of a contract with you

 After the user successfully places an order, if the product needs to be delivered by a third party, in order to complete the delivery and delivery of the goods to the user smoothly, safely and accurately, the third-party delivery company will inevitably Obtain the relevant delivery information (personal information) of the user. The company promises users that it will do its best to protect the security of users' personal information, and strictly requires third-party delivery companies to keep users' personal information confidential.

2.2.8.Use the tuner function to collect and use users’ personal information 

Data Processing Activities Type of Data Legal Basis for Processing
When a user uses the tuner function service, to analyse the sound played by the user by collecting the above information of the user, and prompts to feedback whether the sound played by the user is accurate Obtain permission to access the user’s device recording (microphone), user’s voice information and voice interaction information (personal information) Where you have provided your consent

 

2.2.9.Collect and use of personal information when you voluntarily contact us

Data Processing Activities Type of Data Legal Basis for Processing
When a user voluntarily contact us by our need help function or by subscribing our email user’s name and email address  Where you have provided your consent

 

2.2.10. Collect and use of personal information to undertake marketing, advertising, or other promotional activities

 

Data Processing Activities Type of Data Legal Basis for Processing
When a user uses the services of marketing and advertising The personal information provided above  Where you have provided your consent

The above is the personal information collected and used by Donner. The account of Donner can directly log in to Donner app and the account of Donner app can also log in to Donner website for access and use.  

2.3. Collect and use of personal information when you are using our mobile phone application

Data Processing Activities Type of Data  Legal Basis for Processing
When a user registers a service account user’s email address and account password Where you have provided your consent
When a user voluntarily adds additional profile user’s name, gender, birth date, nationality, and what instrumental lessons do you want to learn Where you have provided your consent
When you complete our survey to new registers voluntarily gender, whether you own donner instrument, your favourite genre of music Where you have provided your consent
When you’re using classroom function learning status, such as your learning progress and course content in order to recommend courses, relevant knowledge, tips to you Necessary for our legitimate interests: to support customers and other enquiries, to operate our business
When you’re using community function storage permission, recording permission, camera permission, dynamic publishing and dynamic interaction Necessary for our legitimate interests: to support customers and other enquiries, to operate our business

 

2.4.User information from third parties that Donner may collect indirectly.

(1) Users understand and know that the Company will not be able to obtain personal information provided to or collected by external third parties, nor will it use unconventional methods to obtain personal information without authorization. If it is really necessary to collect personal information indirectly from a third party due to the needs of business development, and the Company directly or jointly provides products or services for users, the Company (or a third party) will clearly indicate the source, type, purpose and method of use of shared personal information, the business functions and the scope of authorization and consent before collection. When some products or services of the Company are provided or jointly provided by third-party business partners, in order to carry out business reasonably and necessarily, the Company may collect some information indirectly from some business partners and information about users provided by other parties in using the products and/or services of the Company.

(2) The professional security team will strengthen the security of personal information (including filing of sensitive information, encrypted storage of sensitive information, access control, etc.), and protect the indirectly acquired personal information by protection means and measures that are not less strict than those for the personal information of their own users.

2.5.Third party SDKs that Donner may use

The Company may use the following third party SDK services to provide personalized recommendation, third-party account login service and product improvement, the services providers may collect your device information and internet records. We suggest that you read their privacy policies to learn about their practices.

Third Party SDK Service Provider  Privacy Policy Link
byteplus https://urldefense.com/v3/__https://docs.byteplus.com/legal/docs/privacy-policy__;!!Nt8HgU3UPWRNOg!7NaBtNkq77in5vxCxy_12aUCb07_8VK55kbF-D7LTP-z1FOfpt9L3Arz8oGfxB9v6w$
AWS https://aws.amazon.com/privacy/
Firebase https://policies.google.com/privacy

 

2.6.Other lawful, reasonable and necessary collection and use of users’ personal information

Please understand that according to the applicable l laws and regulations, the Company may collect and use users’ personal information without the authorization and consent of users if the information is:

Data Processing Activities Type of Data  Legal Basis for Processing
To demonstrate compliance with regulatory requirements User information Necessary to comply with a legal obligation

 

2.7.Changes in the purpose of collecting and using personal information

Please understand that with the development of business, the functions and services provided by Donner may be adjusted and changed. When the new function or service is related to the currently provided functions or services, the personal information collected and used will be directly or reasonably related to the aforementioned use scenario. In the scenario that is not directly or reasonably related to the purpose of the above-mentioned use scenario, the Company will inform users again before collecting and using users’ personal information and obtain their authorization and consent.

3.About Using Cookie and Similar Technologies

3.1.When using products and services of Donner, the Company may use Cookie and similar technologies to collect some personal information of users, including but not limited to users’ habits of visiting websites, information about users’ browsing and login. For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

4.Storage and Protection of Users’ Personal Information

4.1.Information storage

4.1.1.Storage location: According to laws and regulations, the collected personal information about users will only be stored in the territory of China. With respect to personal data coming from the EEA, we comply with applicable legal requirements providing adequate safeguards for the transfer of personal data to countries outside of the EEA. Before each transmission, we analyse the transmission scenarios and the risks they may pose before deciding whether to transmit. We use standard contractual clauses as legal mechanism to implement the cross-border transfer of your personal data; or implement security measures like anonymization on the data before the cross-border data transfer.

4.1.2.Storage period: We only keep the users’ personal information for the period necessary for the purpose of providing Donner and related services. During the period when users do not withdraw, delete or cancel their accounts, the Company will keep relevant information. After the users withdraw and delete the information, comments and related information published by themselves, and cancel the account number, the Company will still store the above information for the purpose of information compliance audit, but the Company will store it after anonymizing it to ensure the safety of relevant information.

4.2.Information protection

4.2.1.The security of users’ personal information is very important for the Company. The Company will strictly abide by relevant laws and regulations, and strive to take reasonable security measures (including technical and management measures) to protect users’ personal information from unauthorized access, disclosure, use and modification, and to avoid damage or loss of the information.

4.2.2.The Company protects the personal information provided by users with safety protection measures conforming to industry standards, and prevents unauthorized access, public disclosure, use and modification of the data, and prevents the data from being damaged or lost. The Company will take all reasonable and feasible measures to protect users’ personal information.

4.2.3.In order to prevent the occurrence of accidents, the Company has set up a special data security department and formulated a proper early warning mechanism and emergency plan. In case of incident of personal information security, the Company will, in accordance with the requirements of laws and regulations, timely inform users of the basic situation and possible impact of the incident, the disposal measures taken or to be taken by the Company, the suggestions that users may take to prevent and reduce risks independently and the remedial measures for users, and immediately start the emergency plan to minimize losses. The Company will inform the users of relevant events in a timely manner by means of push notification.

4.2.4.Although the Company has taken the above-mentioned reasonable and effective measures and complied with the standards required by relevant laws and regulations, please understand that due to technical limitations and possible malicious means, in the Internet industry, even if we try our best to strengthen security measures, it is impossible to always ensure 100% security of information, but the Company will try its best to ensure the security of personal information provided by users.

4.2.5.Users are aware and understand that the systems and communication networks used to access Donner’s services may have problems due to factors beyond our control. Therefore, the Company strongly recommends that users take active measures to protect the security of personal information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account passwords and related personal information to others.

4.2.6.Once the user leaves Donner and related services and browses or uses other websites, services and content resources, the Company has no ability and obligation to protect any personal information submitted by the user in mobile phone applications and websites other than Donner and related services, regardless of whether the user’s login, browsing or use of other mobile phone applications or website is based on the link or guidance of Donner.

5.Share, Transfer and Publicly Disclose Users’ Personal Information

5.1.Except for sharing users’ personal information so that users can use our services, or when required or permitted by laws and regulations, the Company will not share users’ personal information with non-associated third parties. The Company may disclose users’ personal information under the following circumstances:

(1) Within the organization of the Company. Donner is a part of the organization of the Company, which has many legal entities, business processes, management structures and technical systems. Donner may share users’ personal information within the organization in order to provide services to users and provide services according to users’ requirements.

(2) The Company may share users’ personal information with third-party service providers acting on behalf of the Company to help the Company operate the mobile phone software and website service. The third party can only use the users’ personal information according to the written documents of the Company, and must abide by the information security protection measures implemented by the Company. For more information, please see THIRD-PARTY SERVICE PROVIDERS LIST. 

3) Circumstances where the Company tries to be legal and compliant. The Company has the right to disclose users’ personal information as required by laws and regulations, or when the Company thinks that the disclosure of users’ personal information is necessary to protect the Company’s legal rights, comply with judicial procedures, court orders, requirements of regulatory authorities, or required by any other legal proceedings. If there is a business acquired, sold or purchased by the transferee, the Company may disclose users’ personal information to the potential owner of the business.

5.2.In order to provide more perfect and high-quality products and services to users, the Company will have some of its services provided by authorized partners. The Company may share some personal information of users with partners to provide better customer service and user experience. The Company will only share users’ personal information for legitimate, proper, necessary, specific and explicit purposes, and only share the personal information necessary for providing services. At the same time, the Company will sign a strict confidentiality agreement with its partners, requiring them to handle users’ personal information in accordance with the Company’s instructions, this Privacy Policy and any other relevant confidentiality and security measures. Partners of the Company have no right to use the shared personal information for any other purpose. If the user refuses the Company’s partners to collect the personal information necessary for providing the service when providing the service, the user may be unable to use the third-party service on the platform of the Company.

5.3.With the user’s consent, the Company may disclose the user’s personal information for any purpose.

5.4.The Company will not transfer the users’ personal information to any company, organization or individual unless the users’ explicit consent is obtained. In case of merger, acquisition or bankruptcy liquidation, personal information transfer may be involved. In this case, the Company will require new companies and organizations holding users’ personal information to continue to be bound by this Privacy Policy. If there is any change in the collection and processing methods of personal information stipulated in this Privacy Policy, such companies and organizations will re-ask the users for authorization and consent.

6.Users Personal Information Rights

The Company understands users’ concern about personal information and tries its best to ensure users’ rights to access, correct, delete and withdraw authorization for their personal information, so that users have sufficient ability to protect their privacy and security. Users’ rights include:

6.1.The right to access personal information 

Users can consult the relevant personal information provided by users to the Company according to the relevant specifications (or settings) of products and services provided by the Company, including:

6.1.1.Account information: Users can log in to the users’ personal center at any time through the relevant product pages to access the personal information in the users’ account;

6.1.2.Use information: Users can check their use information at any time through relevant product pages;

6.1.3.Other information: If the users need to obtain other personal information that cannot be known during the visit, the users can contact the Company through the way provided in this Policy.

6.2.The right to correct/modify users’ personal information

When the users find that the personal information provided by them to the Company is wrong, incomplete or updated, the users can correct and modify such personal information.

6.3.The right to delete users’ personal information

For some personal information of users, users can also actively delete the information they provide through the function pages of related products and services provided by the Company. Once the users delete the information, the Company will delete or anonymize the information, unless otherwise provided by laws and regulations.

6.4.The right to withdraw users’ authorization for personal information

Some functions of the products and services provided by Donner need the permission of users’ equipment (including: location, camera, microphone, schedule, etc., depending on the functions actually obtained by the products). Users can withdraw (or stop) the continued authorization of the permission at any time after authorization. Users can also permanently withdraw all authorization for collecting personal information by cancelling their accounts. Users should understand that after users withdraw their authorization, the Company cannot continue to provide users with corresponding specific functions and services. However, the users’ decision to withdraw the authorization will not affect the previous personal information processing based on the users’ authorization.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

6.5.The right to cancel users’ accounts at Donner 

Users can apply for cancellation of their account through the guidance provided by the customer service platform. After the users cancel their account, they will no longer be able to log in and use products and services of Donner with this account. The contents, information, data and records of this account will be deleted or anonymized (except as otherwise provided by laws and regulations). After the account is cancelled, all the data of the account will not be restored. Please consider carefully before cancelling your account. Once the account at Donner is cancelled, it cannot be restored.

If users have any questions when cancelling your accounts, please communicate with the Company through the contact information in Article 9 “Contact Us” of this Policy.

7.Provisions on Minors

Company’s general audience websites and mobile services are not directed to children under the age of 13 and do not knowingly collect personal information from children under the age of 13. Please contact us if you have concerns regarding the potential collection of your child’s information.

8.Revision and Notification of this Policy

8.1.In case of the following changes, the Company will modify this Policy in due course:

(1) The basic situation of the Company has changed, such as the change of ownership caused by merger, acquisition and reorganization;

(2) Changes in the scope, purpose and rules of collecting and using personal information;

(3) Changes in the object, scope and purpose of providing personal information to the outside world;

(4) Changes in the way users access and manage personal information;

(5) Changes in data security capabilities and information risks;

(6) Other changes that may have a significant impact on users’ rights and interests on personal information.

8.2.The Company may revise the relevant clauses of this Policy from time to time (including Donner Privacy Policy). In case of any changes to the contents of the clauses, the Company will prompt the revised contents on the relevant pages or send a notice of agreement modification to users. This kind of notice will be decided by the Company and sent by way of including but not limited to mail, telephone, text message, mobile terminal, webpage or other legal means.

8.3.The content of the revised agreement will form an integral part of this Policy, and users should abide by it as well. If the user disagrees with the revised agreement, please stop logging in and using Donner and related services immediately. If the user logs in or continues to use Donner and related services, the user will be deemed to have fully read, understood and accepted the updated Policy and is willing to be bound by the updated Policy.

9.Contact Us

If users have any questions about the way we process your personal data, please read this Privacy Policy first. For additional questions please go to customer service platform (Contact us). Please note that we take your satisfaction very seriously. Should you have a complaint, please also direct it to the same channel and we will respond to you as soon as we can.

You can of course also lodge a complaint with the Data Protection Authority via this LINK when you have a complaint about the use or processing of your personal data by the Company. For example, if you believe that we do not use your personal data carefully, or because you have sent us a request to access or rectification of your personal data and you are not satisfied with our reply or we did not reply in a timely manner.

Additional Statement for California Consumers

If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests per the requirements of California law.
  • You can request access to a copy of the personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
  • You can request that we delete your personal information.
  • You can request that we stop selling your personal information.
More information on each of these requests is below.

1.Request my Personal Information: 

If you make this request, which we also refer to as a Request to Access Information, we will return to you (to the extent required by law):

  • The categories of personal information we have collected about you.
  • The categories of sources from which we collect your personal information.
  • The business or commercial purpose for collecting or selling your personal information.
  • The categories of third parties with whom we share personal information.
  • The specific pieces of personal information we have collected about you.
  • A list of categories of personal information that we have sold, along with the category of any other company we sold it to. Any of the categories of personal information that we collect could be included in a sale to other companies, including those within our corporate family. If we have not sold your personal information, we will inform you of that fact.
  • A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
You can ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to personal information we collected about you in the previous 12 months.

2.Delete My Personal Information: 

You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account.

3.Stop Selling My Personal Information: 

In the twelve months prior to the effective date of this Statement, we has not sold any personal information of consumers, as those terms are defined under the California Consumer Privacy Act.

4.No Discrimination:

We will not discriminate against you for exercising your rights. This generally means we will not deny you using our services, provide a different level or quality of our services. Please know, if you ask us to delete your information, it may impact your experience with us, and you may not be able to participate in certain services which require usage of your personal information to function.

5.Excercise your rights:

To exercise the California privacy rights described above, please go to home page-need help.

6.Verifying Your Identity for Requests to Access or Delete Personal Information

We take the privacy of your personal information seriously and want to ensure that we provide only you or your authorized agent with your personal information. The CCPA also requires that we verify the identity of each person who makes a request to know what personal information we have about you or to delete the personal information we have about you.
What Personal Information Do I Provide to Verify My Identity?
To verify your identity, we ask you to provide your:

First name* and Last name*
Email address
Phone number
Address*
*required field

7.Your California Privacy Rights - Shine the Light

The following rights apply to California residents.
We share personal information with others outside of the Company for direct marketing of their products only if we have your affirmative consent (opt in).
We share personal information with other businesses within our corporate family. You may ask us for more information about this sharing and whether it affects you by contacting us at the address below. See “Collect and Use Users’ Personal Information”.

Additional Statement for NEVADA Consumers
Nevada Privacy Rights
Nevada consumers have the right to request that a company not sell their personal information for money. We do not sell your personal information for money. If you have any questions about how the company processes your personal information, please go to home page-need help.