Last modified: Jun 1, 2017
Xunjing Technology Inc. ("Xunjing Technology", "we", "us", or "our") operates various websites including, but may not be limited to, www.laioffer.com, learning.laioffer.com, code.laioffer.com, laicode.io, sso.laioffer.com ("Sites), and offer various products and services through these Sites. In this Policy, we refer to the Sites and all the related products or services offered by Xunjing Technology Inc. through the Sites collectively as "Services".
1. Our Commitment to Privacy
2. We May Change this Policy
We may change this Policy from time to time. If we make any changes, we will notify you by revising the "Last Updated" date at the top of this Policy.
Your continued access or use our Services after the posting of such changes shall constitute your consent to such changes and you will be bound by such changes.
If you disagree with any terms of this Policy, or any changes to this Policy, or do not wish to be subject to this Policy, you will stop accessing or using our Services, and deactivate your account if applicable.
3. Your Consent to this Policy
When you register an account, and/or access or use our Services, you agree to the terms and conditions of this Policy.
By continuing to access and/or use our Services after we posted the changes, you agree to the changes to this Policy and be bound by the updated Policy.
If you do not agree with the terms and conditions of this Policy, or do not agree with the changes made to this Policy, you may not access or use the Services.
4. Definitions of Terms
- Sites: Sites refer to all websites operated by Xunjing Technology Inc. including, but may not be limited to, www.laioffer.com, learning.laioffer.com, and code.laioffer.com.
- Services: Services refers to the various products and services offered by Xunjing Technology Inc. through our Sites, including www.laioffer.com, learning.laioffer.com, code.laioffer.com.
- Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data: Usage Data is data collected automatically either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).
- Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).
- Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.
5. Types of Data We Collect
A. Personal Data
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
B. Usage Data
We may also collect information on how the Services are accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
C. Location Data
We may also use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Services, to improve and customize our Services. You can enable or disable location services when you use our Services at any time, through your device settings.
D. Tracking Cookie Data
6. How Do We Collect Information?
A. Information You Provide Us
We may collect personal information from you when you save or otherwise provide to us, or when you expressly authorize us, including without limitation:
- Account Registration Information: Information you provided when you set up a user account and password, login to access our Services, inquire about or interacting with us (whether in person or by phone, e-mail, or through our websites, mobile optimized websites, mobile applications, or WeChat), searching for our Services, purchase or use our Services, including without limitation, first name, last name, email, phone number, schools attended, majors, work experiences, salary, copy of photo id, user name and password.
- Event Registration information: We record information that you provided when you (i) register for an event, including webinars or seminars, (ii)subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download or access any product, whitepaper, course materials, or other materials, (iv) participate in contests or respond to surveys.
- Transaction and Payment Information: Transaction and payment details related to your use of our Services, including without limitation the amount charged, billing information necessary to process the charges (e.g., names and address of the credit card holder, expiration date of the credit card, and last four digits of the credit card number), and other related transaction details.
- Service Request Information: Information provided when you request any services or assistance, including without limitation: selected area(s) of interest, questions, comments, support tickets, account recovery requests sent to our support team or report a problem in connection with your access to or use of the Services.
- Testimonials: When you authorize us to post testimonials about our Services, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
- Correspondence: Records and copies of your correspondence if you contact us by any means and for any purposes, including without limitation: email correspondence and chat logs.
- Other Personally Identifiable Information: Other information by which you may be personally identified or contacted.
B. Information Collected Using Technology
We may also automatically collect information about your use of our Services, when you access or use our Services, including but not limited to:
- Usage and Preference Information Collected by our Servers: Information about your access to and/or use of the Services, traffic data, the date and time of your visit to the Services, the features of the Services accessed, web pages and sites viewed, advertisement(s) served, length of time advertisements are viewed, your preferences, and other communication data and resources in connection with your access to and/or use of the Services.
- Device Information Collected by our Servers: Information about your device on which you access or use the Services, including device name, the unique device identification number of your device, MAC address, IMEI, device make and model, IP address, operating system or platform, language, apps you have installed, browser type and version, network provider, search terms, and other identifiers that may be associated with an end user’s device.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
- Information Collected Using Pixel Tags: In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
- Advertising Identifiers: Mobile advertising identifiers, including but not limited to iOS IDFAs and Android advertising IDs, which may be associated with other information we collect through the Services or from third parties.
- Location Information: General location and precise geo-location of your device. You may opt-out of such collection of location information. Note, however, that opting out of the collection of location information will disable the location-based features of the Services.
- Error Information: Any error reporting information if the Services crash or hang up for the sole purposes of investigating and remedying the errors and improving the Services. Such error reports contain information about the type and version of your device and browser, the device identifier, and time, features being used, and the state of the Services when the error occurs.
- Feedback: Information about ratings, reviews and feedback you provide on the Services.
C. Information Collected from Other Sources
We may collect additional information about you from other sources, including without limitation:
i. Federated authentication service providers: If you log in to our Services using supported federated authentication service providers such as LinkedIn, Microsoft and Google. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address.
ii. Referrals: If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at email@example.com to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
iii. Information from our service providers: If you register for or attend an event that is sponsored by Xunjing Technology, the event organizer may share your information with us. We may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.
iv. Information from social media sites and other publicly available sources: When you interact or engage with us on social media sites such as Facebook, Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our Services, or better understand user reactions and issues. We may also add and update information about you, from other publicly available sources. (such as public databases, federated authentication service providers, referrals, joint marketing partners, social media platforms, as well as from other third parties), including information provided by third parties for advertising or analytics purposes, data to fight fraud, payment verification data, demographic data, and we may combine them with other information we have collected and maintained about you.
D. Information About Others Provided by You
If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We may maintain this information indefinitely in our database and may also use this information to help us establish networks of contacts, document relationships, facilitate referrals, and improve our services. We may also use this information to show you and other users that you may know each other or have shared contacts. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at firstname.lastname@example.org to request the removal of this information from our database. The e-mail that is sent to your friends will come from your e-mail address so that your friends know that you want to invite them to visit the Site.
7. Our Legal Basis for Processing Your Personal Data under GDPR
If you are from the European Economic Area (EEA), our legal grounds for collecting, storing, processing or using the personal information described in this Policy depends on the Personal Data we collect and the specific context in which we collect.
We may process your Personal Data because:
- You Provided Your Consent: To store and/or gain access to information, we rely on your consent, including the “cookie consent.”
- The Processing is in Our Legitimate Interest: In some cases, we rely on legitimate interest as a legal basis for processing Personal Data to provide our and/or other data controllers’ services. For instance, legitimate interests may include the tailoring of promotional communications, providing analysis of and reporting about ad campaigns, maintaining the security of our Services.
- Contractual Relationships: Sometimes we process certain data as necessary under a contractual relationship we have.
- Legal Obligations: Some processing of data may be necessary for us to comply with our legal or regulatory obligations.
8. Your Choices in Your Information
- Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages such as promotional messages by using the ‘unsubscribe’ function included in all such messages or email us at email@example.com. However, you will continue to receive notices and essential transactional emails.
- Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
- Optional information: You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
9. We Use Your Information for These Purposes
A. We may Use Your Personal Information for General Business Purposes
We may use your personal information primarily for our internal business purposes, for delivering better and more personalized Services, and for improving the content and functionality of our Sites and Services including, but may not be limited to:
- To provide, maintain, or improve our Services;
- To notify you about changes to our Services;
- To allow you to participate in interactive features of our Services when you choose to do so;
- To provide customer support;
- To ask you to participate in surveys, or solicit feedback on our Services;
- To gather analysis or valuable information so that we can improve our Services;
- To monitor the usage of our Services;
- To detect, prevent and address technical issues;
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.
- To enforce our rights arising from any contracts between you and us, such as for billing and collection purposes;
- To monitor, investigate, to prevent illegal, abusive, fraudulent, or suspected illegal activities or content;
- To fulfill any other purpose for which you provide it; and/or
- To fulfill any other purpose with your consent;
- To contact, or permit third parties to contact, you via email, SMS, or otherwise for marketing and advertising purposes, including for the purposes of introducing new products, features, services, promotions, or events offered by us or third parties (you may opt-out after the instructions on such communications).
As provided below, you may always choose not to receive promotional materials or marketing information.
B. We may Use Your Testimonials and Feedback
We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content for promotional purposes. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only.
C. We may Use Anonymous Data
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
10. Disclosure of Your Personal Data
We may disclose your Personal Data as described below and as described elsewhere in this Policy:
- Share Your Information with our Affiliates. If you purchase products or services from any of our Affiliate through our Services, we may share your personal information with that Affiliate, so that it can communicate with you (whether by e-mail, phone, mail or otherwise) and provide you with promotional materials and additional information about its products, services, contests, promotions and special offers that may be of interest to you, or collect and use that information subject to and for other purposes contemplated by this Policy.
- We Do Not Sell Your Information to Third Parties. We do not sell or rent your personal information to non-affiliated third parties except as permitted by law, except in the event of a sale of all or substantially all of our business or another similar transaction as discussed in more details in the next paragraph.
- Transfer/Disclose Information to Purchasers of Our Business. In the event of a merger, acquisition, consolidation or restructuring, dissolution or other sale or transfer of all or a portion of Xunjing Technology's assets, whether in a going concern or as part of bankruptcy, liquidation or similar proceeding, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Policy.
- Transfer Information to Third Party for Processing. We may transfer personal information to non-affiliated third parties such as vendors, consultants, contractors, marketing partners, service providers for processing pursuant to agreements that prohibit the third parties from using or disclosing the personal information other than for the purpose of processing and which impose security safeguards appropriate to the sensitivity of the information.
- Use of Information by Advertising Agencies. We may also use third-party advertising agencies to collect data and/or serve ads when you visit our websites. These agencies may use information (not including your name, address, email address or telephone number) about your visits to this website in order to provide tailored advertisements about goods and services of interest to you. If you would like more information about this practice or opt-out of receiving these ads, visit http://optout.networkadvertising.org/.
- When Required by Law. We reserve the right to disclose your personal information in response to facially valid subpoenas, search warrants, any court orders, any law, legal or law enforcement request, or regulatory request, or to protect the property,
- To Protect Our Interests. We reserve the right to disclose your personal information to protect the interests and rights of Xunjing Technology and the rights of our Affiliates, including without limitation, to exercise our legal rights, resolve disputes, protect and defend property or safety of Xunjing Technology, our Affiliates, our Services, our clients, enforce other agreements, including for billing and collection purposes;
- Other Purposes. We may transfer your personal information to fulfill any other purposes for which you provide it, and/or with you consent.
We may disclose aggregated or anonymous information which cannot be used to identify you or any users personally for any lawful purposes without restriction.
11. How Long Do We Retain Your Information?
We will keep your personal information only as long as is reasonably necessary for the purposes described in this Policy, or for other important purposes such as complying with legal obligations (for example, if we are required to retain your data to comply with applicable law), resolve disputes, and enforce our legal agreements and policies. When we no longer have a legitimate need to process your information, we will delete, anonymize, or isolate your information, whichever is appropriate.
If you are a client of ours and thus have an account with us, we will typically retain your personal information for a period of 3 years after you have requested that your account be closed, or such account has been inactive.
12. We May Transfer of Your Information to Other Countries
Our Services are provided, supported and hosted in the United States, and our operations are governed by the laws of the United States. Your personal information, including Personal Data, that we collect from you may be transmitted to, processed and/or stored on computers located outside of your state, province, country or other governmental jurisdiction where data protection laws may differ than those from your jurisdiction.
When we transfer Personal Data outside of the European Economic Area (EEA), Switzerland, or the UK, we take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Please contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we may use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
- Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
14. How to Inquire, Assess, Change, or Erase Your Personal Data?
We will ensure that the personal information it collects is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
If you wish to confirm that we are processing your data, have access to the personal data we may have about you, to make correction of your personal information collected by us, or to erase your personal information collected by us, please contact our privacy officer at firstname.lastname@example.org.
You may also request information about: the purpose of processing; the categories of personal data concerned; who else outside of us might have received the data from us; what the source of the information was (if you didn't provide it directly to us); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by us if it is inaccurate. You may request that we erase that data or cease to processing it, subject to certain exceptions. You may also request that we cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. When technically feasible, we, at your request, will provide your personal data to you or transmit it directly to another controller.
Reasonable access to your personal data will be provided at no cost to our customers, course attendees and others upon request made to email@example.com. If access cannot be provided within a reasonable time frame, we will provide you with a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied.
15. How to Withdraw Your Consent & Lodge Complaints?
You can withdraw your consent to the collection, use and/or disclosure of personal information as identified herein by writing to our privacy officer at firstname.lastname@example.org.
If you have any questions or make any complaint in relation to this Policy and our privacy practices, please contact our privacy officer at email@example.com.
16. How to Opt-Out of Promotional Materials?
We communicate with you only if you want to hear from us. You may opt out of receiving promotional and newsletter emails from us by using the unsubscribe link situated at the bottom of any promotional message you receive from us. You may also opt-out of receiving promotional emails and other promotional communications from us or our Affiliates at any time by emailing our privacy officer at firstname.lastname@example.org with your specific request.
Please include your full name and the e-mail address you used when you registered with or made a purchase from us. It may take up to 2 weeks to process your request, during which period you may continue to receive communications from us or our Affiliates.
If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of our Services or those about your online account or our ongoing business relations.
You may also unsubscribe from our Email services by using the unsubscribe link situated at the bottom of any promotional message you receive from us.
17. Security of Your Personal Data
The security of your personal information is important to us, but we want to remind you that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, including your personally identifiable data that can be used to identify or contact you ("Personal Data"), we cannot guarantee its absolute security.
18. "Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
19. Your Mobile Privacy & Location Data
When you use our mobile optimized website or our mobile application, we may receive information about your location and your mobile device, including a unique identifier for your device. We and our service providers may use and store this information to provide you with location based services, search results, and other personalized content. We will provide notifications only to those customers who accept to receive such notifications. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device.
20. What is Excluded from this Policy?
- Your Public Information. This Policy does not apply to information published or displayed in public areas of the Sites or the Services, or to information transmitted to other users of the Services or information made available on mobile applications or websites owned and operated by third parties. These information are treated as non-confidential information.
- Third-Party Sites. If you visit, publish, or share your information on any applications or websites owned and operated by third parties, the collection and use of such information shall be governed by the privacy policies of the applicable third-party sites. We do not accept any responsibility or liability for those policies or any information you may share or transmit on a third-party site, even if we provide a link to such site on our Sites.
- Other Users' Actions. We cannot control the actions of any users of the Services or other third-party applications or websites with whom you choose to share your User Contributions. Therefore, we are not responsible for any use or misuse of such information that might result from your disclosure of such information.
21. Children under the Age of 13
Our Website is directed for use by adults. We do not knowingly collect any personal information from children under the age of 13. Those under age 13 should not access or use our Services.
22. Your GDPR Privacy Rights
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
- The right to lodge complaint. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Please note that we may ask you to verify your identity before responding to such requests.
To exercise your rights under GDPR, you can contact us at email@example.com.
23. Your California Privacy Rights
California civil code section 1798.83 permits customers who are California residents and who have provided us with “personal information” (as that term is defined in section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. if you are a California resident with questions regarding this, please contact us via email at firstname.lastname@example.org.
24. Third-Party Service Providers We Use to Process Your Data
We may employ third party companies and individuals to facilitate our Services ("Service Providers"), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
C. Behavioral Remarketing
- Google AdWords. Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.
The payment processors we work with are:
E. Meeting Hosts
We may use third-party service providers to host our meeting. The third-party service provider may collect meeting attendee's id, login time, IP address, geolocation etc., and provide ways for meeting organizer to access the data.
The meeting hosts we use are:
F. Sales and Marketing Services
25. Third-Party Links
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
26. A Note to Users Outside of the United States
27. Contact Us
- By email: email@example.com
- By mail: Privacy Officer, Xunjing Technology Inc., 2350 Mission College Blvd, Santa Clara, CA 95054.