Donner Music Privacy Policy

1. Special Tips

1.1. Donner Music 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 of the People’s Republic of China. To this end, Donner Music has formulated Donner Music 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 of Donner Music (hereinafter referred to as “Donner Music”) and related services. Users’ use of or continuing to use the products and services provided by Donner Music 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 Music for feedback through the contact information published in Article 11 “Contact Us” of this Policy.

1.2. This Policy applies to all products and services provided by Donner Music. Guangzhou Rantion Technology Co., Ltd. with its registered address at Room 432, Building 4, No.50 Nanxiang First 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 Music 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 Music. 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 Music.

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 Music 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

(1) When a user registers a service account, the Company may collect personal information that the user is required to provide, such as the user’s name, password, mobile phone number or email address (personal sensitive information, which is used to receive verification codes to match personal identities) and social network ID. Only by providing the above true and accurate personal information can a user successfully register an account and use products and services of Donner Music.

(2) Donner Music supports users to log in with an account of a third-party platform (such as Facebook or Google). If a user logs in with an account of a third-party platform, the Company will obtain relevant information (including user’s name, nickname, avatar, etc.) and authentication information (personal sensitive information) under the third-party account according to the authorization of the user. The Company promises that the above information is collected for providing account login service, ensuring account security and preventing risks. If users refuse to authorize such information, they cannot log in to Donner Music with the account of the third-party platform.

(3) After registering an account, the picture of the user’s name, user name and personal information (if the user registers with social network ID) will be automatically displayed on the user’s personal information page and provided to other users through the service. The user allows other users to identify, find and correctly recommend the picture.

(4) In addition to the user’s name and user name (automatically displayed on the personal information page), 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. Any such information added by the user to the personal information page of the service (except the birth date and gender) can be publicly provided. 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).

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

When users use the search function in Donner Music, some information of users shall be collected, including the following personal information: equipment information, log information, including searched words or phrases, browsing records and time, search time and times. The purpose of collecting such information is to quickly match the content that users need and may be interested in, and to improve products and services of Donner Music.

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

(1) When Donner Music provides users with audio and video display and playback services during the promotion of music and musical instrument courses, users’ personal information shall be collected, including the following personal information: 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). In order to collect the above-mentioned basic personal equipment information, Donner Music will apply for permission to access the user’s equipment information, which is collected to provide audio and video display and playback services to users. If the users refuse to provide the above permission, the related products and services will be unavailable.

(2) When a user logs in to Donner Music using a device and uses the audio and video display and playback services, according to the situation of different devices, the user can enable or cancel the permission at any time through the related function setting page. The user’s enabling this permission is deemed as authorizing the Company to access, acquire, collect and use the user’s personal information. However, when the user cancels the authorization, the Company will no longer collect the above information and cannot provide the above services to the user. The cancellation by the user will not affect the processing and storage of personal information based on the previous authorization of the user.

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

When a user initiates a complaint, appeal or consultation to the customer service platform of Donner Music, for the sake of the security of the user’s account and system, the user may need to provide the account information first, and match it with the previous personal information of the user to verify the user’s identity. At the same time, in order to facilitate contact with the user or help the user solve the problem, the user may also be required to provide personal information (personal sensitive information) such as name, mobile phone number, email and other contact information. In addition, the Company will also collect 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. The purpose of collecting such information is to investigate the facts and help the user solve the problem. If the user refuses to provide the above information, the customer service platform will not be able to timely feedback the complaint, appeal or consultation result to the user.

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

When a user uses the functions of commenting, sharing and posting, the Company will collect the above-mentioned text, picture and video information provided by the user voluntarily, and at the same time, access the user’s mobile phone photo album with the user’s permission to facilitate the user to share videos and pictures. The user can enable or cancel this permission at any time through the user’s device system or the related function setting page of the products and services of Donner Music. The user’s enabling this permission is deemed as authorizing the Company to access, acquire, collect and use the user’s personal information. When the user cancels the authorization, the Company will no longer collect the information and will not be able to provide the above services to the user. The cancellation by the user will not affect the processing and storage of the user’s personal information by the Company based on the user’s previous authorization.

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

When a user logs in to products of Donner Music with mobile devices and use the functions of video download and screenshot download, the Company may obtain the storage permission of the user’s device. If the user refuses to provide it, the user will not be able to use this function. The user can enable or cancel this permission at any time through the user’s device system or the related function setting page of the products and services of Donner Music. The user’s enabling this permission is deemed as authorizing the Company to access, acquire, collect and use the user’s personal information. When the user cancels the authorization, the Company will no longer collect the information and will not be able to provide the above services to the user. The cancellation by the user will not affect the processing and storage of the user’s personal information by the Company based on the user’s previous authorization.

2.2.7. Collect and use users’ personal information in the process of commodity trading

(1) When a user purchases commodities or services from the products and services of Donner Music, the user needs to provide some information related to the completion of the transaction, including: information of the commodities or services traded, the consignee information (consignee’s name, address and telephone number) (personal sensitive information). In addition, the Company may collect some other information related to orders, including transaction amount, order placing time, order number, order status, payment method, payment serial number and payment status, which are collected by the Company to help users successfully complete transactions, ensure users’ transaction security, inquire about order information and provide customer service, etc.

(2) After the user successfully places an order, if the commodities need to be delivered by a third party, in order to deliver and ship the commodities to the user smoothly, safely and accurately, the third-party delivery company will inevitably get the relevant delivery information (personal information) of the user during the delivery and distribution process. The Company promises to the users that it will do its best to ensure the safety of users’ personal information, and strictly requires the third-party delivery company to keep users’ personal information confidential.

2.2.8. Collect and use users’ personal information during payment

When users pay for goods and courses on Donner Music, they need to use the payment function. In the process of payment, the Company may collect the users’ third-party payment account or bank card information (such as PayPal, Alipay, VISA or bank card information) (personal sensitive information). The above information is necessary for the Company to provide banks with information of the purchased goods and services, and the Company cannot obtain the personal property information of users only based on this information, nor can it identify the identity information of specific natural persons.

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

When a user uses the tuner function service, Donner Music will gain permission to access the user’s device recording (microphone), may collect the user’s voice information and voice interaction information (personal information), analyzes 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. If the user refuses to provide such information, the user will not be able to use this function. The user can also enable or cancel the permission at any time through the user’s equipment system or by using the related function setting page of the products and services of the Company. The user’s enabling this permission is deemed as authorizing the Company to access, acquire, collect and use the user’s personal information. When the user cancels the authorization, the Company will no longer collect the information and will not be able to provide the above services to the user. The cancellation by the user will not affect the processing and storage of the user’s personal information by the Company based on the user’s previous authorization.

2.3. User information from third parties that Donner Music 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.

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

Please understand that according to the laws of the People’s Republic of China and relevant national laws and regulations, the Company may collect and use users’ personal information without the authorization and consent of users if the information is:

(1) Related to the performance of obligations provided by laws and regulations;

(2) Directly related to national security and national defense security;

(3) Directly related to public safety, public health and major public interests;

(4) Directly related to criminal investigation, prosecution, trial and judgment execution;

(5) Collected or used to protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals, whose consent is difficult to obtain;

(6) Disclosed to the public by users themselves;

(7) Collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(8) Necessary for signing or performing contracts according to the requirements of users;

(9) Necessary to maintain the safe and stable operation of software and related services, such as finding and handling faults of software and related services;

(10) Other circumstances provided for by laws and regulations.

2.5. 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 Music 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 Music, 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. The purpose of collecting this kind of information with Cookie and similar technologies is to meet users’ necessity to use the products and services of the Company, simplify the steps of repeated operations (such as registration and login), facilitate users to view the use history (such as video viewing history), provide users with content that is more suitable for users’ personal needs and that users may be more interested in, protect users’ information and account security, and improve the products and services of the Company.

3.2. If the user refuses the Company to use Cookie and similar technologies to collect and use the user’s relevant information, the user can manage and refuse Cookie and similar technologies through the user’s settings, provided that the user has this function; or delete Cookie and similar technologies already stored in the user’s mobile devices or other devices, so that the Company can’t track all or part of the user’s personal information. Users understand and are aware that the products and services provided by Donner Music can only be realized by using Cookie or similar technologies. If users refuse to use or delete Cookie or similar technologies, users will not be able to normally use the products and services provided by Donner Music or get the best service experience through the products and services provided by Donner Music, which may have a certain impact on users’ information protection and account security.

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 the People’s Republic of China. If it is really necessary to carry out cross-border data transfer, the Company will separately and clearly inform the users (including the purpose of data transfer, receiver, use mode and scope, use content, security measures, risks, etc.), and obtain the authorization and consent of users to ensure that the data receiver has sufficient data protection capability to protect the personal information of users.

4.1.2. Storage period: Keep the users’ personal information only for the period necessary for the purpose of providing Donner Music 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 Music’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 Music 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 Music 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 Music.

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 Music is a part of the organization of the Company, which has many legal entities, business processes, management structures and technical systems. Donner Music 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 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.

(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.

5.5. In accordance with the laws and regulations of the People’s Republic of China, sharing, transferring and publicly disclosing users’ personal information does not require the prior authorization and consent of users if the information is:

(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; or required by laws and regulations, administrative organs or public security organs, procuratorates and courts;

(4) Shared, transferred or publicly disclosed to protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals, whose consent is difficult to obtain;

(5) Disclosed to the public by users themselves or collected from legal channels (such as legal news reports and government information disclosure and other channels);

(6) Necessary for signing or performing contracts according to the requirements of users;

(7) Other circumstances provided for by laws and regulations.

6. Users Manage Personal Information

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 their 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 Music 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 canceling 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.

6.5. The right to cancel users’ accounts at Donner Music

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 Music 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 canceling your account. Once the account at Donner Music is cancelled, it cannot be restored. If users have any questions when canceling your accounts, please communicate with the Company through the contact information in Article 11 “Contact Us” of this Policy.

7. Provisions on Minors

7.1. If the user is a minor under the age of 18, before using Donner Music and related services, the user should read this Policy under the supervision and guidance of the user’s guardian, and ensure that the user’s guardian’s prior consent has been obtained. Otherwise, the Company does not recommend that minor users use the services of the Company.

7.2. If the user’s guardian disagrees with the user’s use of the Company’s services or providing personal information to the Company according to this Policy, please stop using services of the Company immediately and notify the Company in time.

7.3. The Company protects the personal information of minors in accordance with relevant national laws and regulations, and will only collect, use, store, share, transfer or disclose the personal information of minors when permitted by law, expressly agreed by the guardian or necessary for the protection of minors.

7.4. If the user is the guardian of a minor and has any questions about the personal information of the minor under the custody of the user, please contact the Company through the contact information publicized in this Policy.

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 Music 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 Music and related services immediately. If the user logs in or continues to use Donner Music 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. Notice and Service

9.1. All notices under this Policy can be made through important page announcements, e-mails or regular letter transmission. The notice shall be deemed to have been served to the addressee on the date of sending.

10. Applicable Laws and Jurisdiction

10.1. The conclusion, entry into force, performance, interpretation and dispute resolution of this Agreement shall be governed by the laws of the People’s Republic of China. If this clause is partially invalid due to its conflict with the current laws of the People’s Republic of China, the validity of other parts shall not be affected. The User agrees that the latest version of Donner Music Service Agreement approved by the User shall prevail when resolving disputes.

10.2. In case of any dispute between the two parties on the content of this Agreement or its implementation, both parties shall try their best to settle it through friendly consultation. If consultation fails, the parties to the dispute agree to submit the dispute to Guangzhou Arbitration Commission for arbitration in accordance with its arbitration rules. The arbitral award is final and legally binding on all parties.

10.3. Unless otherwise agreed in writing, the validity of provisions of applicable laws and jurisdiction shall extend to this Agreement and other Donner Music rules, including their amendments, supplements and updates.

10.4. The User agrees that Guangzhou Arbitration Commission has relevant nationality jurisdiction and territorial jurisdiction, and that the User waives any objection to such jurisdiction or place. If the relevant disputes cannot be resolved through Guangzhou Arbitration Commission, both parties can freely seek any rights or remedies granted by applicable laws.

11. Contact Us

Users are welcome to ask questions and provide comments on this Policy or its provisions. You can contact the Company at any time through the customer service platform.