7Short Privacy Policy
Updated: February 01, 2024
7Short products are provided by Shenzhen Lutong Network Technology Co., Ltd (Address: 801-804, Building 2, Chongwen Park, Nanshan Zhiyuan, No. 3370 Liuxian Avenue, Fuguang Community, Taoyuan Street, Nanshan District, Shenzhen, China, Contact: 0755-26995700, hereinafter collectively referred to as "we" or "7Short") for the benefit of users (including registered and non-registered users, hereinafter referred to as "you") and/or you. "7Short") provides game products and/or services for users (including registered and non-registered users, hereinafter referred to as "you") and/or your children. In accordance with the Network Security Law of the People's Republic of China, the Provisions on Network Protection of Children's Personal Information and other relevant laws and regulations, and with reference to national standards such as the Specification for Personal Information Security of Information Security Technology (GB/T 35273) and other national standards, we have formulated the "Agreement on the Protection of Users' Privacy" (hereinafter referred to as the "Agreement") to protect the personal information security of you and/or your child(ren). children's personal information.
7Short products and/or services are intended for children, minors over the age of 14, or adult users over the age of 18 who are still interested in using 7Short products and/or services. In the case of children and minors over the age of 14, a guardian must read this Agreement and agree to it in its entirety before we will provide the 7Short Products and/or Services to such children and minors over the age of 14.
This Agreement describes the purpose, manner, scope and information security measures of the collection, use, storage, entrustment, sharing, transfer and public disclosure of your and/or your child's personal information in the course of providing 7Short products and/or services to you and/or your child, as well as the means by which we provide you with access to, and the means by which you may correct, delete, etc., and control your personal information. Please read this Agreement in conjunction with our User Service Agreement.
We will collect and use your and/or your child's personal information for the purposes set out in this Agreement in accordance with the principles of lawfulness, necessity and transparency. If we use your and/or your child's personal information for purposes other than those stated in this Agreement, or if we collect your and/or your child's personal information for other specific purposes, we will inform you in a reasonable manner and obtain your consent again before collection and use.
1.1. Personal information volunteered by you in the course of providing products and/or services to you
1.1.1. We need to collect personal information from you and/or your child(ren) in order to fulfill our basic business functions, and if you refuse to provide it, we will not be able to provide you and/or your child(ren) with the appropriate services. Note: If you provide personal information about yourself or your child, please ensure that you have obtained a copy of your personal information.
If you provide personal information about yourself or your child, please make sure that you have obtained the consent of the relevant subject; your provision of such information shall be deemed to be deemed to have obtained the valid and authorized consent of the relevant subject.
1.1.1.1. Registration, Login and Verification
(1) When you use your cell phone number to register for a 7Short Game Software account, you need to provide us with your cell phone number, and we may send a verification code to your cell phone number to verify your identity. According to our laws and regulations and for safety and security purposes, if you do not provide your cell phone number for verification, it will lead to registration failure, so you cannot use the relevant functions of 7Short Game Software, but you can return to the main page to browse after exiting the registration/login page.
(2) When you choose to use your cell phone number to log in to any 7Short Gaming Software account, you will need to provide us with the cell phone number you registered with and log in after obtaining the verification code.
(3) 7Short apps use the same account system for different internet channels, i.e. if you have already registered an account on one platform such as TV app, you can use that account to log in to other platforms directly without having to re-register.
(4) Third-party login: When you use a third-party account (including other channels such as Google, Apple, etc.) to log in and/or make payment, you may choose to authorize us to read and obtain your publicly available information on that third-party platform. When you log in using a third-party account such as a WeChat account, the third-party account will share your information with us. The purpose of obtaining such information is to remember your login identity as a 7Short user in order to provide you with better products and/or services, and we will only use such information to the extent that you have consented. When you log in using a third party account, your third party account will be tied to your 7Short account. If you need to cancel such third party account binding, you may contact us in the manner provided in Section 9 of this Agreement.
1.1.1.2. Creating a profile
In order for you and/or your child to have a good experience when using 7Short Game Software for learning, we suggest that you help you and/or your child to upload/fill in the avatar, nickname, date of birth or age, gender in 7Short Game Software (all of the above are optional), or provide the above information (all of the above are optional) to us when our salespersons, tutors, etc. contact you via WeChat, SMS, phone call, etc. so as to help you and/or your child create a personal profile. Provide the above information (all optional) to help you and/or your child create a personal profile. Failure to provide such optional information to create a profile for you and/or your child may affect our ability to provide you and/or your child with a more personalized service, but will not affect your and/or your child's ability to use other features of the 7Short Games Software. We especially remind you that in order to protect your and your child's privacy, if not necessary, we recommend that you do not upload your and your child's real face photo and name as your avatar and nickname, and do not easily post your and your child's real identity information publicly or share it with others.
1.1.1.3. Marketing or Promotions, Sending Physical Items
In order to carry out marketing and promotional activities (such as sending gifts) or send other physical items to you, you need to provide us with the name, address, and cell phone number of the recipient. If you do not provide us with this information, we may not be able to deliver the item(s) to you, but this will not affect your and/or your child's ability to use the 7Short Products and/or other features of the Services.
You agree that if you provide your shipping information in a 7Short game software, you authorize us to save the information, and when you need to fill in the shipping information again in the process of using the 7Short game software in the future, in order to simplify your operation steps and save your time, we may automatically display the information on the relevant page, and you can directly use or modify the shipping address In order to simplify your operation steps and save your time, we may automatically display the information on the relevant page, you can directly use or modify the shipping address, without the need to fill in again.
In order to provide better services to you and/or your children, we may send you commercial service/promotional information, the latest news about our products and/or services, relevant management and other notices related to 7Short's products and/or services through phone calls, text messages, notifications on our website, emails and other means.
1.1.1.4. Customer Service or Complaints
When you lodge a complaint, grievance or inquire about 7Short products and/or services, you are required to provide us with your contact information (e.g., cell phone number, email address) and account-related information, order screenshots (if any) for the purpose of your account and system security, so that we can verify your user identity. You also need to provide us with appropriate supporting materials (including but not limited to pictures, videos or text messages), other necessary information in order to quickly resolve the issues you have raised. If you do not provide the above information, we may not be able to provide you with timely feedback on the outcome of your complaint, grievance or inquiry, but it will not affect you and/or your child's normal use of the 7Short products and/or other features of the Services.
When you make a complaint, grievance or inquiry about 7Short Children's products and/or services through the "Contact Us" section of the website, you will need to provide us with your nickname, e-mail address, and message in order for us to quickly resolve the issue you have raised. If you do not provide the above information, we may not be able to make accurate feedback in conjunction with your questions, but it will not affect the normal use of 7Short products and/or services by you and/or your children.
1.1.2. In order to provide you with better 7Short products and/or services, we may need to collect the information described below. Your refusal to provide such information will not affect your and/or your child's ability to use the basic business features under 1.1.1, but we will not be able to provide you with certain extended business features and services.
1.2 Personal information we actively collect in the course of providing you with products and/or services
Subject to laws and regulations, we may collect and use the following information about you and/or your children in the course of using 7Short products and/or services in order to protect your account and provide you and/or your children with quality services:
1.2.1. device information
When you and/or your children use the 7Short Games Software, we may collect information about your device, including browser type, carrier information and usage ,information about the location of the device (IP address), device model number, device version, operating system version number, IDFA (iOS only), IDFV (iOS only), and software listings. We may collect this information while the app is running in the foreground, while the app is running in the background, and correlate this information so that we can provide you with a consistent service.
Please be especially aware that some third parties also collect the Mac address of your device.
When you and/or your children browse the official website, we may receive and record your relevant device information, including device model, unique device identifier, and operating system information, based on your specific permissions in the installation and use of the software, so that we can provide you with consistent services.
1.2.2. Log Information
When you and/or your children use the 7Short Game Software, we will automatically collect details of your and/or your children's use of the 7Short Game Software and save them as web logs, including browser type, browsing history, network diagnostics, lagging information, clicking events, and level successes or failures, in order for us to compile statistics on the use of the 7Short Game Software, optimize the 7Short Game Software, and provide you with consistent service. 7Short Game Software to provide you with a better service experience.
When you and/or your children browse the official website, we will automatically collect the details of your usage and save them as web logs, including your IP address, browser type, browsing history, so that we can count the usage of the official website and provide you with better experience and service.
1.2.3. Browsing Records
When you and your child(ren) use 7Short products and/or services, we may collect relevant browsing information about you and/or your child(ren), including browser type, browsing history and click history. This information is collected in order to provide you with the 7Short Products and/or Services and to improve the functionality of the 7Short Products and/or Services and to provide you with a better service experience.
1.3. Please see Section 5 Purpose of Personal Information Collection by Third Parties for the important system permissions required for your use of the 7Short Gaming Software and their corresponding purposes (including permissions required by the third parties accessed). In particular,we are unable to prohibit the application of permissions requested by certain channels in order to ensure that you are able to use the services of the SDKs of those channels. We recommend that you carefully evaluate the reasonableness of the permission request before authorizing it and proceed with caution.
1.4 Exceptions to Consent
In accordance with laws and regulations, your consent is not required for the collection and use of your and/or your child's personal information in the following cases:
1.4.1 In connection with the fulfillment of our obligations under laws and regulations;
1.4.1 Directly related to national security and national defense security;
1.4.2 directly related to public safety, public health, and significant public interests;
1.4.3 Those directly related to criminal investigation, prosecution, trial and judgment execution;
1.4.4 For the purpose of safeguarding your and/or your child's or other individual's life, property and other significant legitimate rights and interests, but it is difficult to obtain my consent;
1.4.5 The personal information involved is disclosed by you to the public;
1.4.6 It is necessary for the conclusion and performance of a contract at your request;
1.4.7 the personal information involved is collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;
1.4.8 Necessary to maintain the safe and stable operation of the 7Short products and/or services provided, such as detecting and disposing of malfunctions of 7Short products and/or services;
1.4.9 Other cases stipulated by laws and regulations.
2.1. Cookie
When you and/or your child use 7Short products and/or services, we store small data files called cookies on your computer or mobile device, which typically contain an identifier, the name of the site, and some numbers and characters. Cookies allow us to recognize you as a user each time you and/or your children use the 7Short Products and/or Services when you sign in to your account; they also allow you to jump directly from one page to another without having to sign in again on each page. Web beacons, pixels or other similar files can do the same thing. We use the term "cookie" in this policy to refer to all files that collect information in this way.
2.2 How cookies are used
We use cookies to determine whether you are logged in or not without having to log in again on each page, to record the pages you have visited so that you can browse faster and easier next time, and to improve the quality of our services/quality of our products and optimize the user experience. We also use cookies to enable and support security features to monitor and prevent suspicious activity, fraudulent traffic and violations of the 7Short User Agreement. We will not use cookies for any purpose other than those stated in this Agreement.
3.1 Delegated Processing
In order to provide you and/or your child with better, high-quality products and services, certain features may be provided by our technical service partners, and we may entrust our partners with the processing of certain personal information about you and/or your child. We will sign strict confidentiality agreements with companies, organizations and individuals that we entrust to process your and/or your child's personal information, specifying the responsibilities of both parties, the matters to be processed, the duration of the processing, the nature of the processing and the purpose of the processing, etc., and requiring them to process the personal information only in accordance with our requirements, this Agreement, and any other relevant confidentiality and security measures. Your refusal to allow our partners to collect personal information necessary to provide the Services may result in your inability to use 7Short products and/or services to take advantage of the services provided by such partners. Our partners include:
3.1.1 Analytics, Push and/or Statistics Service SDK Providers. In order to better analyze and/or count the usage of 7Short users, we entrust the service providers of data analysis, information push and/or statistics to process your device information, user click records, which will be used to maintain or improve 7Short products and/or services, and to enhance user experience.
3.1.2 Technical Service SDK Providers. We may engage partners of the Service (e.g., voice technology service providers) to process your and/or your child's voice in order to provide pronunciation accuracy measurements and to better enhance the user experience. We may also commission partners of the Service (e.g., application anomaly technology service providers) to process your system version, generation ID, and cell phone style in order to provide anomaly analysis and processing of 7Short products and/or services.
3.1.3 In the marketing and promotional activities, if you need to send items to you, or need to send other physical items to you, we may commission third party warehousing, logistics and service providers to provide you with logistics services, and we may provide them with the name of the consignee, the consignee's address, and the consignee's cell phone number. If you do not provide such information, our aforementioned partners will not be able to deliver your shipment for you.
3.2 Sharing
With respect to your and/or your child's personal information, we collect and use it only for the purposes and to the extent described in this Agreement or as required by law or regulation, and in strict confidence.
In order to provide you with better and high-quality products and services, certain 7Short services will be provided by our partners, therefore, we may share certain personal information of you and/or your child with our partners. We will only share your and/or your child's personal information for lawful, legitimate, necessary, specific, and express purposes, and will only share personal information that is necessary to provide you with the Services. We will not share personal information that identifies you, unless otherwise required by law or regulation or with your otherwise authorized consent. The partners in such sharing are data controllers who have obtained your consent to process your personal information on their own behalf. The partner may have its own separate privacy policy/personal information protection policy and user agreement, and we recommend that you carefully read and comply with the third party's user agreement and privacy policy/personal information protection policy. Your refusal to allow our Partners to collect personal information necessary to provide the Services may result in your inability to use the 7Short Products and/or Services to take advantage of the Services provided by such Partners.
3.3 Transfer
In principle, we will not transfer control of your and/or your children's personal information to other companies, organizations or individuals, except in the following circumstances:
3.3.1 Transfer with explicit consent: We will transfer your personal information to other parties after obtaining your explicit consent;
3.3.2 In the event of a merger, acquisition, or bankruptcy or liquidation that involves the transfer of personal information, we will require the new company or organization that holds your personal information to continue to be bound by this personal information protection policy, or we will require that company or organization to seek authorization and consent from you again.
Please be informed that if the transfer of personal information is necessary for the reasons mentioned above, we will inform you of the purpose, type, and transferee of the transferred information (if sensitive information is involved, we will also inform you of the content of the sensitive information involved) before the transfer, and will transfer the information with your consent, unless otherwise stipulated by laws and regulations.
3.4 Public Disclosure
In principle, we will not release personal information about you and/or your children to the public or to unspecified groups of people, except in the following cases:
3.4.1 With your explicit consent;
3.4.2 Disclosure based on law: We may publicly disclose your personal information in cases where it is mandatory by law, legal process, litigation or governmental authorities.
Please be aware of this:
(1) If public disclosure is necessary for the above reasons, we will inform you of the purpose of public disclosure and the type of information (if sensitive information is involved, we will also inform you of the content of the sensitive information involved) and obtain your consent for public disclosure before disclosure, unless otherwise stipulated by laws and regulations.
(2) Even if we have obtained your consent, we will only publicly disclose your and/or your children's personal information for lawful, legitimate, necessary, specific and clear purposes, and we will try our best to de-identify the personal information in the publicly disclosed content.
3.5 Exceptions to Prior Consent for Sharing, Transferring, and Public Disclosure of Personal Information
In accordance with laws and regulations, we are not required to obtain your prior authorized consent for the sharing, transfer, or public disclosure of personal information in the following cases:
3.5.1 In connection with the fulfillment of our obligations under laws and regulations;
3.5.2 Directly related to national security and national defense security;
3.5.3 Directly related to public safety, public health, and significant public interests;
3.5.4 Those directly related to criminal investigation, prosecution, trial and judgment execution;
3.5.5 For the purpose of safeguarding your and/or your child's or other individual's life, property and other significant legitimate rights and interests but it is difficult to obtain my authorized consent;
3.5.6 Personal information that you disclose to the public on your own;
3.5.7 Personal information collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;
3.5.8 Other cases stipulated by laws and regulations.
4.1. Accessing or Correcting Your and/or Your Child's Personal Information
4.1.1. You have the right to log in and access your account at any time to view your and/or your child's personal information, including your account information and your and/or your child's personal profile. You may correct your and/or your child's personal information if you discover that the personal information we have collected, stored, used, or disclosed about you and/or your child is incorrect or incomplete, or in other circumstances as required by law or regulation.
4.1.2. If you wish to access or correct other personal information about you and/or your child, or if you encounter difficulties in exercising the above rights, you may contact us via the contact information provided in Article 9 of this Agreement, and we will respond to your request promptly after verifying your identity, except as otherwise provided by laws and regulations or as otherwise agreed in this Agreement.
4.2. Deletion of your and/or your child's personal information
4.2.1. You may request us to delete your and/or your child's personal information under the following circumstances, unless the data has been anonymized or unless otherwise provided by law or regulation:
4.2.1.1. we process your and/or your child's personal information in violation of laws and regulations or our agreement with you;
4.2.1.2. we collect or use your personal information without your consent;
4.2.1.3. you no longer use 7Short products and/or services or you cancel your account;
4.2.1.4. we no longer provide the 7Short Products and/or Services to you;
4.2.1.5. in any other circumstances as defined by law, regulation or otherwise.
4.2.2 If you wish to have your and/or your child's personal information deleted, you can contact us for assistance as set out in clause 9.
We attach great importance to the security of your and/or your child's personal information, and to this end, we have adopted multi-level protection measures, such as security technology measures in line with industry standards and supporting organizational structure and management system, in order to maximize the prevention of leakage, destruction, misuse, unauthorized access, unauthorized disclosure or modification of your and/or your child's personal information, which specifically include the following:
6.1 Data security technical measures
6.5.1. In terms of secure data transmission, we adopt cryptographic technologies such as transport layer security protocols, prevent the transmission link from being eavesdropped or intercepted by means of Https, etc., and establish a secure environment for private data to ensure the privacy and integrity of data. We also take additional security measures such as encrypted storage of your and/or your children's information.
6.5.2. In terms of security control of data access and use, we implement strict data authority control mechanisms, adopt multiple authentication techniques, and monitor the behavior of those who are able to handle your and/or your child's personal information to avoid unauthorized access and unauthorized use of data. We also monitor the entire process of the data life cycle to prevent unauthorized access, public disclosure, use, modification, human or accidental damage or loss of your and/or your child's personal information.
6.2 Data security organization and management measures
6.2.1. In accordance with the requirements of relevant regulations, we have set up a working organization specifically responsible for the protection of personal information and appointed a person in charge of the protection of children's personal information. We have also established relevant internal control and management processes, and strictly set information access rights for staff who may come into contact with your and/or your child's personal information on the principle of minimum authorization, so as to control the scope of knowledge of children's personal information.
6.2.2 We have established a data classification system, business data security use norms, data cooperation norms, etc. to ensure that the handling of your and/or your child's personal information meets the security requirements of laws and regulations in the collection, transmission, use, storage, transfer and destruction of personal information. According to the requirements of relevant laws and regulations, for staff who need to access children's personal information, we will require them to go through the approval of the person in charge of personal information protection or his/her authorized management personnel, record the access, and take technical measures to avoid illegal copying and downloading of children's personal information.
6.2.3. We organize staff to participate in security and privacy protection related training and require them to complete the required assessment to strengthen the staff's awareness of the importance of protecting personal information.
6.2.4. We also take other feasible security organization and management measures.
6.3 Guarantee of the terms of the cooperation agreement
6.3.1. Before we indirectly collect your and/or your children's personal information from a third party, we will explicitly require the third party to collect and process (e.g. share, etc.) your and/or your children's personal information with your express consent in writing (e.g., cooperation agreement, letter of commitment), and require the third party to make a commitment to the legitimacy and compliance of the source of the personal information at the level of the written agreement, and in the event of a violation by the third party, we will explicitly require the third party to provide a guarantee on the legitimacy and compliance of the source of the personal information. If the third party violates the law, we will explicitly require the other party to bear the corresponding legal responsibility.
6.3.2. Before we share your and/or your child's personal information with our business partners, we will strictly require our partners to assume the obligations and responsibilities of information protection. For this purpose, we will also require our business partners to sign a data processing agreement or set out the terms and conditions related to data protection in the cooperation agreement, which we will require our business partners to sign before cooperation. The agreement strictly stipulates the confidentiality obligations of user information of the business partners, including the storage, use and flow of information should meet our control requirements, accept our review, supervision and audit, once there is any violation, we will require the other party to bear the corresponding legal responsibility.
6.4 Handling of security incidents
6.4.1. In the unfortunate event of a personal information security incident, we will immediately activate the emergency response plan and take remedial measures. If serious consequences are caused or likely to be caused, we will immediately report the incident to the relevant authorities and inform you of the basic situation of the security incident and its possible impacts, the disposal measures that we have taken or will take, the suggestions that you can independently take precautions to prevent and minimize the risks, and remedial measures to be taken against you, etc. We will also inform you of the security incidents that have occurred. We will promptly inform you of the relevant situation of the incident by email, telephone or push notification, etc. If it is difficult to inform you one by one, we will take reasonable and effective ways to publish announcements.
6.4.2. Please know and understand that the Internet is not an absolutely secure environment, and we strongly recommend that you assist us in ensuring the security of your account through secure methods and the use of complex passwords. If you find that your personal information has been compromised, in particular your account number or password has been compromised, please contact us immediately in accordance with the contact information provided in Section 9 of this Agreement so that we can take appropriate measures to protect the security of your information.
7.1. We will store personal information collected and generated in China. If we need to transfer or store personal information outside of China for business purposes, we will obtain your prior authorization and consent, and we will fulfill our obligations related to cross-border transfer of personal information in strict accordance with national laws and regulations.
7.2. We promise that, unless otherwise required by laws and regulations, you and/or your children's personal information will be stored for the shortest period of time necessary to achieve the purposes for which you have authorized its use.
7.3. In the event that we cease to operate due to poor business or other reasons, unless otherwise required by laws and regulations, we will inform you of such circumstances, cease the collection of your and/or your child's personal information, and delete or anonymize the personal information that has been collected.
8.1. We may update or modify this Agreement from time to time. We will notify you of any changes we make to this Agreement by posting a notice on the product page or by one or more of the following methods: notification on the website, SMS notification, email notification, etc. The updated policy will be effective from the date of update on the home page. However, we will not reduce your rights under this Agreement without your express consent. Such changes form part of this Agreement.
8.2. Please read the changed contents of this Agreement carefully. If you do not agree to this Agreement, or if you disagree with any changes or updates to this Agreement, you may choose to cancel your account and no longer use the 7Short Products and/or Services. However, please be aware that your behavior and activities prior to the cancellation of your account and the cessation of your use of the Service are still subject to this Agreement.
8.3. In the event of a material and substantial change, we will notify you in a conspicuous manner on a case-by-case basis. The circumstances of a material and substantial change include, but are not limited to, the following:
8.3.1. a significant change in our service model. For example, the purpose of handling personal information, the type of personal information handled, the way personal information is used, and changes in the situation of personal information (if any);
8.3.2. a significant change in our ownership structure, organizational structure, etc. Such as changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions, etc;
8.3.3. Changes in the primary recipients of personal information sharing, transfer or public disclosure;
8.3.4. Significant changes in your rights to participate in the handling of personal information and how you exercise them;
8.3.5. Changes in the department responsible for handling the security of personal information, contact information and complaint channels;
8.3.6. when a security impact assessment of personal information indicates a high risk.
9.1. If you and/or your children have any doubts or other related matters in the process of reading this Agreement (including questions, complaints, etc.), you can contact us in the following ways: (1) pay attention to the public number of 7Short, online complaints and feedback; (2) call the manual customer service telephone 0755-86969369; (3) send an e-mail to xingzheng @lutongnet.com for inquiry; and (4) other contact information provided by us. We will respond to your comments and suggestions as soon as we receive them.
9.2. We will complete the verification and processing of your comments and suggestions within 15 working days after receiving them and verifying your user identity, or within a shorter period as promised by us. If we are unable to respond to your request, we will send you a notice explaining the reasons within the maximum time limit required by law.
9.3. If you are not satisfied with our response, or if our handling of your and/or your child's personal information infringes on your and/or your child's legitimate rights and interests, and if we are unable to provide you with a satisfactory response and refuse to make improvements after you have provided us with your feedback, you may lodge a complaint and report the matter with the relevant supervisory authority.
10.1 The interpretation of this Agreement and dispute resolution shall be governed by the laws of China. Any dispute related to this Agreement shall be resolved amicably through negotiation between the parties; if it cannot be resolved through negotiation, you hereby agree to submit the dispute to the People's Court of Nanshan District, Shenzhen City.
10.2. If any court of competent jurisdiction rules or decides that any provision of this Agreement is invalid, such provision will be removed from this Agreement, but the invalidity of such provision will not affect the validity of the remaining provisions of this Agreement. The remaining provisions of this Agreement will continue to be enforceable.
10.3. The headings in this Agreement are designed for ease of reading only and do not affect the meaning or interpretation of any provision of this Agreement.