Children's Privacy Policy

Beijing Congming Hetao Educational Technology Co., Ltd (hereinafter referred to as "Walnut Coding", "We" or "Company") understands the importance of personal information and privacy of children (under 14 years old, same below). We would like to, through this Walnut Coding Children's Privacy Policy ("The Policy"), explain the corresponding handling rules and other related matters when we collect and use children's personal information. This Policy applies to the online education products of Walnut Coding(hereinafter referred to as "Walnut Coding Products" or "Walnut Coding Platform"), including the Walnut Coding App, the official website of Walnut Coding (domain name: Walnut101.com), WeChat Official Service Accounts, and WeChat mini apps.

Before using Walnut Coding Products, please make sure that children and their guardians read and thoroughly understand this Policy, especially those highlighted in bold/underlined, and start using it only after confirming that they fully understand and agree to all the terms.

Special Note for Guardians.

If we learn that your child is under the age of fourteen, we will take special measures to protect the personal information we obtain about the child in your custody in accordance with this Policy. Please help us protect the personal information and privacy of children by asking them to read and choose whether to accept this Policy together with your supervision, and to use Walnut Coding Products and submit personal information with your consent and guidance. If you do not agree to the contents of this Policy, which may result in the child in your custody not being able to use the products and services provided by us or to achieve the intended results of our services, you should ask the child in your custody to stop accessing/using Walnut Coding Products immediately. By providing us with personal information about a child in your custody or allowing that child to use the Walnut Coding Platform, you will be deemed to have consented to our collection of personal information about that child. Please read this policy carefully before providing us with personal information about a child in your custody or allowing that child to use our services. If you become aware that a child has registered to use our products and/or services without your consent, or if you have questions about the personal information of a child in your custody, please contact us promptly using the contact information in Section 7.

Special Note for Children:

We recommend that any child should obtain prior consent from a guardian to participate in online activities. If you are a child under the age of fourteen, you should notify your parent or other guardian to read this policy together, and seek the consent and guidance of your guardian before you use Walnut Coding Products, or submit personal information. By clicking to agree to this Policy, or by using/continuing to use Walnut Coding Products, or submitting personal information, you will be deemed to have obtained permission from your guardian, and your guardian agrees to our processing of your personal information in accordance with this Policy (including updated versions).

This Policy applies to our activities such as collecting, using, storing and sharing children's personal information via the Internet within the People's Republic of China. By using any product or service provided by Walnut Coding, a child's guardian shall be deemed to agree to accept this Policy and the Walnut Coding Privacy Policy. In the event of inconsistent terms between this Policy and the Walnut Coding Privacy Policy on similar terms, this Policy shall prevail with respect to the personal information of children. Any matters not covered by this Policy is subject to the Walnut Coding Privacy Policy

If you have any questions about this Policy or matters related to this Policy, you may contact us through the contact information in Section VIII of this Policy, and we will provide answers as soon as possible.

This Policy will help you understand the following content:

I. How we collect and use children's personal information

II. How we use cookies and similar technologies

III. How we share, transfer, and publicly disclose children's personal information

IV. How we store and protect children's personal information

V. How we manage children's personal information

VI. How this policy will be updated

VII. How to contact us

 I. How we collect and use children's personal information

The Walnut Coding Privacy Policy describes our general personal information handling practices. We may collect and use the following types of personal information about children with the consent of their guardians for the following purposes:

1. Register account

(1)In order to complete the creation of an account, we require the following information from the user: the name, nickname, password and cell phone number of the account to be created.

In order to help you log in quickly, you can also log in by authorizing and bonding your WeChat account to. We may obtain your public information on your WeChat account after logging in through the aforementioned authorized log-in, and we will use your personal information in accordance with the agreement with WeChat and in compliance with the relevant regulations.

(2)In the process of completing user information, it will help us to provide you with better member services if the user provides the following additional information: avatar, child's real name, gender, birthday, grade level, and delivery address. If you do not provide the information above, it will not affect you to use the basic browsing function of the Service. We use the real names of children collected for the following purposes: 1) to push you notification messages containing real names; 2) to provide certificates for children. We use the delivery address we collect for the purpose of sending educational materials or merchandise.

2. Provide Products or Service

(1)When children upload and/or post information while using the Walnut Coding Service and engage in related conduct (including children speaking in live sessions), we will collect the information uploaded, posted or formed by children and display children's nicknames, head portraits and posted contents.

(2)When you purchase courses or other services on the Walnut Coding Platform, in order for you to complete the payment smoothly, you may pay for the settlement through online banking or third-party payment platforms (WeChat, Alipay) that Walnut Coding cooperates with, at which time we will collect the order information of your purchased courses. At the same time, we may share your order information with financial institutions or payment agencies for the sole purpose of completing the order payment.

(3)When you require an invoice to be issued, you are required by law to provide the following information: your name or full company name and company TAX ID information.

(4)We provide you with the ability to post information publicly. Users may post information publicly through the comments, forums and other information posting functions we provide to our users. Please note that the information you post publicly may contain personal information or even sensitive personal information about you or others, such as pictures you choose to upload containing personal information in your reviews. Please consider more carefully whether to share or even publicly share relevant information when using our services.

(5) When you contact us or submit a request for on-sales / after-sales processing, we require you to provide the necessary personal information to verify your membership status in order to protect your account and system security.

In order to facilitate contact with you, help you solve problems as soon as possible or record the solutions and results of relevant problems, we may keep the communication / call records and relevant contents between children and us (including account information, order information of purchased courses, other information you provide to prove relevant facts, or contact information you leave). If you make inquiries, complaints or suggestions about specific orders, we will use your account information and order information.

We may also use information provided by you when a child contacts customer service, and questionnaire response information sent to us when a child participates in a survey, in order to maintain the reasonable need to improve business functions.

(6)In order to provide children with information display and basic product function for taking classes on the Walnut Coding Platform, and to enhance the performance, efficiency and function of our services, we will collect the service log information generated by children in the course of browsing and using our services, including browsing, clicking to view, searching for queries, favorites, transactions, after-sales, following and sharing information, posting information, as well as IP address, browser type, telecommunications supplier, language used, date and time of access.

3.To provide users with personalized poster-related functions and security.

In order to protect your member account security, transaction security and system operation security, and to meet the relevant requirements of laws and regulations, in the process of children using our products / services.

1)We will obtain information about the device used by the child, including the device model (androidID), operating system version, International Mobile Equipment Identity (IMEI), network card address, mobile application list hardware and software, and device environment information.

Purpose and function for obtaining the information:

Ø Application list: check if the specified third-party application (WeChat) is installed, for example, the WeChat jump sharing.

Ø Device model androidID: for locating and troubleshooting user problems.

Ø Operating system version: different functions are enabled depending on the system version.

Ø International Mobile Equipment Identity (IMEI): for locating and troubleshooting user problems.

Ø Network card address: for helping users choose the right server source and speed up their network downloads.

You understand and agree that you need to authorize us the Phone Permission to allow us to read the phone status in order to obtain the aforementioned IMEI information. You may choose to refuse to authorize or turn off said permission, and your refusal to authorize or turn off said permission may affect our ability to determine and safeguard the security status of your account and use.

2)In the course of your use of our services, in addition to security purposes, in order to complete App configuration, store App cache and facilitate your uploading and downloading of images and work files, to ensure your normal use of the App, we will ask you to authorize the read and write access to cell phone storage.

You may choose to refuse authorization or turn off the above permissions. Your refusal to authorize or turn off the above permissions may affect your ability to upload and download images and work files, and the use of saving-to-local function, as well as our ability to determine and safeguard the security status of your account and use.

4.Children and guardians understand and agree that we may need to enable specific access permissions in children's devices in order to enable the collection and use of personal information to which those permissions relate.

1)When a child uploads an avatar, generates a personalized poster or sends a photo to customer service by taking a picture, we request that camera access be turned on. When the access is turned on, we will collect the above information uploaded and sent by the child.

2)When children record work or assignments, participate in live classes, or send voice messages to customer service, we request that the microphone (recording) access be turned on. When the access is turned on, we will collect the voice messages recorded by the child.

3)When a child chooses to upload an avatar or assignment from an album, or send an album photo to customer service, we will request that photo album access be turned on. Once access is turned on, we will collect information about the photos uploaded by the child.

You understand and agree that in the scenarios described in 1) - 3) above, users are required to turn on the corresponding access rights of camera, microphone and photo album in the terminal device in order to collect and use the information involved in these rights. You can check the status of the above access rights item by item in the system settings of your terminal device and can turn on or off any or all of them at any time at your own discretion.Please note that if you turn on any access, it means you authorize us to collect and use the personal information corresponding to that access to provide you with the corresponding services mentioned above, and once you turn off any access, it means you cancel or withdraw the authorization of that access, and we will no longer collect and use the corresponding personal information based on that access, nor can we provide you with the services corresponding to that access. However, it does not affect your use of other functions of Walnut Coding Platform (except for cell phone reading and writing access). At the same time, your decision to close the access will not affect the previous information collection and use based on your authorization.

If you do not want to receive commercials, lesson reminders and feedback reports from us, you can unsubscribe or turn them off by replying to prompts, turning off 'notifications' access in your device settings or any other method we offer.

(iii). Other Purposes

We will seek your prior consent to use information for purposes other than those set out in this Policy, or to use information collected for a specific purpose.

(iv). Exceptions where authorized consent has been obtained

Please refer to the Privacy Policy

II. How we use cookies and similar technologies

For the information on how we use cookies and similar technologies, please refer to the Privacy Policy.

III. How we share, transfer, and publicly disclose children's personal information

(i) Share

It is Walnut Codings' bottom line and basic principle to respect and protect the privacy of children. Walnut Codings will not provide personal information about children to third parties, except in the following circumstances.

1.With the express authorization or consent of the child's guardian, we will share the child's personal information with other companies, organizations and individuals for purposes that are reasonably necessary.

2.It may be necessary for us to disclose a child's personal information in order to comply with applicable laws and regulations, for the purposes of litigation, or as required by administrative or judicial authorities.

3.Personal information about children may be shared with our affiliates and/or designated service providers in order to facilitate our provision of products or services to children, to identify anomalies in member accounts, and to protect the personal property of Walnut Coding affiliates or other users or the public from harm. We will only share personal information that is necessary and subject to the purposes stated in this policy, and will again seek the authorized consent of the child's guardian if we share sensitive personal information about the child or if our affiliates change the purposes for which the personal information is used and processed.

4.Sharing with authorized partners: certain of our services will be entrusted to partners for the sole purpose of achieving the stated objectives in this Policy. We may share certain personal information about children with our partners in order to provide better customer service and user experience. Currently, the types of partners with whom we share personal information include the following:

(1)Authorized partners in the advertising, analytics services category. We do not share personally identifiable information about children with partners who provide advertising, analytics services unless we have the permission of the child's guardian. We may entrust these partners to process information related to the covering scope and effectiveness of advertisements, but we do not provide personally identifiable information that directly identifies children or we de-identify this information so that it does not identify individual children. Such partners may combine the above information with other data they have lawful access to in order to perform the advertising services or decision-making recommendations we have commissioned.

(2)Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business by providing technical infrastructure services commissioned by us, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, facilitating payments or conducting academic research and surveys. For example, when a user purchases a course with textbooks or redeems items in the Walnut Mall, we need to share your delivery address information with our delivery service providers to ensure the safe and accurate delivery of the textbooks or redeemed items, or we need to share the user's order number and order amount with third party payment providers to enable them to confirm the user's payment instructions and complete the payment.

5.We may share data with third parties through application Coding interfaces (API), software development kits (SDKs) as necessary to achieve the purposes stated in this Policy, and we will conduct strict security checks on such third parties and agree strict data protection measures with our authorized partners so that they handle personal information in accordance with our commissioning purposes, service descriptions, this Policy and any other relevant confidentiality and security measures to handle personal information. We do not permit sub-licensing by authorized partners where children's personal information is involved.

We list in the table below the types of third party SDKs we access on our website, the types of personal information they collect from users and the purposes for which they are used.

We promise that we will only share personal information about children for lawful, legitimate, necessary, specific, and explicit purposes. Companies, organizations and individuals with whom we share personal information are assessed for security and have strict confidentiality agreements with them, requiring them to handle the information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.

 (ii) Transfer

We do not transfer children's personal information to any company, organization or individual, except for the following:

1.Transfer with express consent: After obtaining the express consent of the child's guardian, we will transfer the child's personal information to other parties.

2.Transfer in accordance with the applicable laws and regulations, the requirements of legal proceedings, mandatory requirements of administrative or judicial authorities as may be necessary.

3.Transfer is in accordance with the relevant agreement with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents.

4.In the event of a merger, acquisition or bankruptcy liquidation involving children's personal information that may be transferred as part of such a transaction, we will require the new company or organization holding the children's personal information to continue to be bound by this Policy if the transfer of the children's personal information is involved, or we will require the company or organization to seek authorized consent from the children's guardians again.

(iii). Publicly Disclosing

We will only publicly disclose a child's personal information when:

1.Based on the express consent or active choice of the child's guardian.

2.If we determine that a user has violated laws and regulations or seriously violated Walnut Coding's relevant agreements and rules, or to protect the personal and property safety of Walnut Coding Platform users or the public from harm, we may disclose personal information about children, including relevant violations and the measures Walnut Coding has taken against you, in accordance with laws and regulations or with the consent of the child's guardian.

(iv). Exceptions to prior authorized consent for sharing, transfer, and public disclosure of personal information

Please refer to Privacy Policy

 IV. How we store and protect your personal information

(i). Store

1.Storage Territory

Personal information about children collected and generated in the course of our operations in the People's Republic of China is stored in the PRC, except for the following cases:

1）Explicitly defined in the applicable law.

2）Obtain express authorization from the child's guardian.

3）Your personal initiative such as cross-border transactions via the Internet.

In such cases, we will ensure that the personal information of children is adequately protected in accordance with this Policy and the relevant legal and regulatory requirements.

2.Storage Period

We will take reasonable and practicable steps to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purposes described in this Policy, unless there are mandatory retention requirements by law, such as the E-Commerce Law of the People's Republic of China, which requires that information about goods and services and transactions be retained for a period of not less than three years from the date of completion of the transaction. And our criteria for determining the aforementioned period include.

（1）To fulfil the purpose of the transaction in relation to you, to maintain the corresponding transaction and business records, and to respond to any inquiries or complaints that you may have.

（2）Guaranteeing the safety and quality of the services we provide to you.

（3）Whether you agree to a longer retention period.

（4）Whether there is any other special agreement on the retention period.

After a child's personal information has exceeded beyond the retention period, we will delete or anonymize the child's personal information as required by applicable law.

(ii). Protect

1.We will take all reasonable and feasible measures to protect the personal information of children. Walnut Coding uses SSL security certificate, SSL can establish an encrypted channel between the client (e.g. browser, app) used by the member and the web server, all data transmitted on the network will be encrypted first, and then decrypted when the transmission reaches the destination, so that even if the data packet is intercepted during the transmission, it will be difficult to decrypt the content. Taking a member visits Walnut Coding through a browser as example, SSL technology automatically activates the browser to display the "lock" security symbol, and the page beginning with "https" in the address bar means that an SSL security encryption channel has been established between the browser and the web server, so that the credit card number, transaction password and other confidential information entered by the member online will not be viewed, stolen or modified during the network transmission. For more details, please refer to "Account Security-SSL Security Certificate". We have designated a person responsible for the protection of children's information, set strict access rights to information, adopted the principle of minimum sufficient authorization for staff who may have access to children's information, and taken technical measures to record and control the behavior of staff handling children's information to avoid illegal copying and downloading of children's personal information.

2.We will take all reasonably practicable measures to comply with the principle of necessity in collecting information, and we will only retain your personal information for the period of this Policy statement, unless required by law or regulation.

3.We acknowledge that the Internet environment is not 100% secure, and we make every effort to ensure or warrant the security of children's personal information. If our physical, technical, or managerial safeguards are breached, resulting in unauthorized access, public disclosure, alteration, or destruction of information, resulting in damage to your legal rights, we will bear the corresponding legal responsibility.

Please make sure that the guardians and children keep the account number, password and other identification elements of the Walnut Coding Platform in a safe place. When users use Walnut Coding Products, they will be identified by their account numbers, passwords and other identity elements. If guardians and children disclose the aforementioned information, they may suffer losses and may adversely affect themselves. If guardians and children discover that account numbers, passwords and/or other identification elements may be or have been leaked, please contact us immediately so that we can take prompt action to avoid or mitigate the relevant damage.

4.We have formulated emergency response plans for children's information security incidents and regularly organize emergency response training and emergency drills for relevant internal personnel to enable them to master their job responsibilities and emergency disposal strategies and protocols. In the unfortunate event of a child information security incident, in accordance with the requirements of laws and regulations, we will promptly inform children and their guardians of: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for children and their guardians to prevent and reduce risks on their own, and remedial measures for children and their guardians, etc. We will promptly inform children and their guardians of the incident by pushing notifications on the app, sending emails/short messages, etc. When it is difficult to inform them one by one, we will take reasonable and effective ways to release relevant warning information. We will also take the initiative to report the disposal of children's information security incidents in accordance with the requirements of regulatory authorities. If the legitimate rights and interests of children and their guardians are damaged, we will bear the corresponding legal responsibility. At the same time, we will also take the initiative to report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.

V. How we manage children's personal information

(i). Access to children's personal information

You have the right to access your personal information, except for the exceptions provided by law and regulations. If you wish to access your personal profile information in your account, you can do so on the App by clicking on "My" / "Personal Center" -click on your head portrait / "Modify Personal Information" / "Edit" to access your personal information.

If you are unable to access this personal information through the above link, you can call Walnut Coding customer service at 4006-102-101 (Monday to Sunday 8:00-21:30) and operate through human customer service.

We will respond to your access request within 15 days.

(ii). Correct children's personal information

1.Account information: If you want to edit your personal profile information in your account, you can do it in the App by clicking "My" / "Personal Center" -click your head portrait / "Edit Profile" / "Edit" to modify your account information.

2.Change the bound cell phone: You can log in the Walnut Coding App to perform this operation or through the manual customer service, the operation method in the App is: click "My" - "Settings" - "Change cell phone number ".

(iii). Delete children's personal information

You may make a request to us to delete personal information in the following cases:

1.If our processing of personal information violates laws, regulations or agreements.

2.If we collect and use your personal information without your consent.

3.If you no longer use our products or services, or if you cancel your account.

If we decide to respond to your request for deletion, we will also simultaneously notify the entities from which we have obtained your personal information that they are required to delete it promptly, unless otherwise required by law or regulation, or unless those entities have your independent authorization.

When you delete information from our service, we may not immediately delete the corresponding information in our backup system, but we will delete it when the backup is updated.

If we stop operating Walnut Coding products or services, we will promptly stop collecting your personal information, notify you of the stop of operations in the form of a notice, and delete the personal information held. If personal information of children is involved, we will also inform their guardians of the discontinuation of operation in a timely manner.

The optional ways for you to propose the deletion of personal information are as follows.

1)Use the account cancellation function that comes with the Walnut Coding App to initiate a cancellation request.

2)Call Walnut Coding Customer Service at 4006-102-101 (Monday to Sunday 8:00-21:30) and operate through human customer service.We will respond to your deletion request within 15 days.

(vi).Change the scope of authorization for which you have agreed to personal information permissions

Each business function requires some basic personal information in order to be completed. You may give or withdraw your authorized consent for the collection and use of additional collected personal information at any time.

You can change the authorization scope of the agreed personal information permissions by: Application Permission Management - Walnut Coding, authorize and deauthorize the corresponding permissions by turning on or off the corresponding permission settings, in order to change the authorization scope of the agreed personal information permissions.

If you have any questions, please call Walnut Coding Customer Service at 4006-102-101 (Monday-Sunday 8:00-21:30) and ask for human customer service for details. We will reply to your request within 15 days.

When you withdraw your authorization consent, we will no longer process your personal information in the appropriate manner. However, your decision to withdraw your authorization consent will not affect the processing of your personal information that we have previously carried out on the basis of your consent.

(v). Request account cancellation

Users can cancel their accounts through the App by clicking on "My" - "Settings" - "Cancel Account" in the App. After you voluntarily cancel your account, we will stop providing services to you and delete or anonymize your personal information as required by applicable law, except as otherwise provided by law or regulation.

(vi). Obtain a copy of your personal information

If you need a copy of your personal information, you can contact us at Walnut Coding customer service number 4006-102-101 (Monday to Sunday 8:00-21:30), after verifying your identity, we will provide you with a copy of your personal information in our service (including basic information, identity information,, address and phone number of the recipient) except as otherwise provided by law or regulation or as otherwise agreed in this policy.

(vii). Restrain automated decision making of information systems

In some business functions, we may make decisions based solely on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you have the right to seek an explanation from us and we will provide appropriate remedies.

(viii). Response to your request above

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will respond within 15 days. If you are not satisfied, you may also initiate a complaint through the contact information in Section VII of this policy.

In principle, we do not charge for your reasonable requests, but a certain fee for repeated requests that exceed reasonable limits will be charged by us at our discretion. We may deny requests for information that is not directly related to your identity, that is unwarrantedly repetitive, or that requires excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), that poses a risk to the legal rights of others, or that is impractical.

VI. How this policy will be updated

This Policy is subject to change as laws and regulations are introduced or amended. We will not limit a child's rights under this Policy without the express consent of the child's guardian.

We will post changes to our Privacy Policy on a dedicated page. For major changes, we will also provide more prominent notifications (including through onsite push notifications).

VII. How to contact us

If you have any questions, comments or suggestions about the content of this policy, you can contact us through the following ways, and we will respond to your request within 15 days.

1.If you have any questions, comments or suggestions about the content of this Policy or children's personal information, you can contact us by calling Walnut Coding customer service at 4006-102-101 (Monday to Sunday 8:00-21:30) , or emailing to : security@Walnut101.com.

2.If you find that your child's personal information may have been leaked, you may report your complaint in the manner described above.

3.We have designated a person responsible for the protection of children's information, You can contact him/her through Walnut-legal@Walnut101.com, office address: 5th and 11th floor, Yinke Building, No. 38 Haidian Street, Haidian District, Beijing.

If you are not satisfied with our response, especially if you think our personal information processing behavior has harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with the Beijing Haidian District Court.

Effective: September 8, 2021