Privacy Policy

Note:

Thanks for using the online education products(hereinafter referred to as “Walnut Coding Products” or “Walnut Coding Platform”) affiliated with Walnut Coding which are developed by 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). Walnut Coding Platform includes the Walnut Coding App, the official website of Walnut Coding (domain name: www.walnutcoding.com), WeChat Official Service Accounts, and WeChat mini apps. Once you register as a Walnut Coding user, you can purchase and use Walnut Coding products and corresponding services.

Your trust is very important to us, and we are aware of the importance of your personal information to you. We will take corresponding security protection measures in accordance with the requirements of laws and regulations, and try our best to protect the security of your personal information under control. In view of this, Walnut Coding has formulated this Walnut Coding Privacy Policy (hereinafter referred to as "this Policy") and reminds you that:

This policy applies to all products and services provided by Walnut Codings. If our products or services and those of our affiliates (as defined in the Definitions section) use products or services provided by Walnut Coding but do not have a separate privacy policy, then this Policy also applies to those products or services. If we and our affiliates have separate privacy policies for the products or services they provide to you, the corresponding privacy policies will apply to those products or services.

Before using Walnut Coding products and services, please make sure that you read and thoroughly understand this Policy, especially those highlighted in bold/underlined, and start using it only after confirming that you fully understand and agree to all the terms.If you have any questions, comments or suggestions about the content of this Policy, you can contact us through the way of this policy statement.

Email:hetao-legal@hetao101.com

Telephone:4006-102-101 (Monday to Sunday at 8:00-21:30)

Part I Definition

Walnut Coding Product Service Provider: means Beijing Congming Hetao Educational Technology Co., Ltd. or its affiliates, the provider of Internet information and software technology services for Walnut Coding Products.

Affiliates: means Beijing Siming Qichuang Technology Co., Ltd., Changze Technology (Beijing) Co., Ltd. and all affiliates of Walnut Coding service providers.

Personal Information: means all kinds of information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

Sensitive personal information: refers to personal information that, if leaked, illegally provided or used, may endanger the safety of persons and property, and is highly likely to lead to damage to the reputation, physical and mental health of individuals or discriminatory treatment, etc., including personal information such as identity document numbers, personal biometric information, bank account numbers, property information, traces of travel, transaction information, and information on children under 14 years of age (inclusive) (We will prominently identify specific sensitive personal information in bold type in this policy).
Personal information deletion: refers to the act of removing personal information from the system involved in realizing daily business functions so that it remains unretrievable and inaccessible, and deleting or anonymizing personal information in the backend of Walnut Coding products.

Children: refers to minors under the age of fourteen.

Part II  Main Body of Privacy Policy

It is our pleasure to be of service to you. This policy will help you understand the following contents:

I. How we collect and use your personal information

II. How we use cookies and similar technologies

III. How we share, transfer, and publicly disclose your personal information

IV. How we store and protect your personal information

V. How we manage your personal information

VI. How we deal with the information of juvenile?

VII. How this policy will be updated

VIII. How to contact us

I.How we collect and use your personal information

The personal information we need/may need to collect and use about you in connection with your use of our products and/or services includes both of the following:

1.In order to achieve the basic function of providing our products and/or services to you, you need to authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services properly:

2. In order to provide you with additional functions of our products and/or services, you may choose to authorize us to collect and use the information. If you refuse to provide it, you will not be able to use the relevant additional features or achieve the functional effect we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services.

You understand and agree that:

We strive to maintain and improve our business functions on an ongoing basis, and as we do so, we may introduce new business functions from time to time that may require the collection or use of additional personal information or changes in the purpose or manner of use of personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with the means to choose your own consent, and collect and use it after obtaining your explicit consent. In this process, if you have any questions, comments or suggestions, you can contact us through the various contact information provided by Walnut Coding, and we will reply to you as soon as possible.

We will collect and use your personal information for the following purposes as described in this policy:

(i) Basic functions, collecting necessary information for the realization of online lecture services

1.Register member

(1)Basic member service: 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 become our member, 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)Additional member service: in the process of completing your personal information, it will help us to provide you with better member services if you can provide the following additional information: avatar, real name of the child in your custody, nickname, gender, birthday, and grade level. When you upload your photo as an avatar in your account management, you need to think carefully to avoid disclosing your sensitive personal information. 

2. Push messages, issue certificates and send objects

We may collect the real name of you or the child in your custody for the following purposes: 1) to push you notification messages containing real names; 2) to provide certificates for children.

When you purchase a course with materials or redeem items in the Walnut Mall, we need to collect your or your child's address so that we can send the materials or items to you.

3.Payment and settlement

When you purchase courses or other services on the Walnut Coding Platform, in order for you to complete the payment smoothly, you may arrange the payment 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.

4.Proving invoice

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.

5.Customer service and order processing

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 you 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.Provide you with the information public release function

You may post information publicly through the comments, forums and other information posting features we provide for you. Please note that the information you post publicly may contain personal information or even sensitive personal information of yourself, such as pictures you choose to upload containing personal information in your reviews. Please consider more carefully whether you share or even publicly share information about yourself when using our services. If you publicly post information that involves personal information about children, you must obtain the authorized consent of the guardians of the children involved before posting it. The guardians in the aforementioned cases have the right to contact us through the channels in Section 8 of this policy to request correction or deletion of the content involving children's personal information.

7.Provide you with App function for normal purposes

In order to provide you 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 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.

8.Provide you with security assurance

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 using our products / services:

1)We will obtain information about your device through your authorization, 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.

1)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.

(ii) Additional functions, information collected based on your choices

1.Additional functions based on camera permissions:When you upload 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.Additional functions based on microphone (recording) permissions:When you 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.Additional functions based on photo album permissions:When you choose to upload an avatar or assignment from an album, or send an album photo and picture to customer service or make a referral poster, we will request that photo album access be turned on. Once access is turned on, we will collect information about the photos or pictures uploaded.

4.View and change WLAN connection and status: Used to determine whether the device is online and whether the network is normal. If the network is abnormal, it indicates that the network-related functions are temporarily unavailable.

5.Read app market configuration information: When you click "Support Walnut, Encourage", we will request to open your system app store, so that you can rate and comment.

6. Preventing your phone from dormant and running foreground services: When you participate in a course, you need to use both of your permissions in order to keep the course video playing smoothly.

You understand and agree that in the scenarios described in 1 - 6 above, you 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. 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

1.Related to the fulfillment of our obligations under laws and regulations.

2. Directly related to national security and national defense security

3. Directly related to public safety, public health, and significant public interests

4. Directly related to criminal investigation, prosecution, trial and execution of judgments, etc.

5. For the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain the person's consent.

6. The personal information collected is disclosed by you to the public on your own.

7. Necessary for the conclusion and performance of a contract at your request

8. Your personal information collected from legitimate public disclosure of information, such as legitimate news reports, government information disclosure and other channels.

9. Necessary to maintain the safe and stable operation of the products or services provided, such as the discovery and disposal of product or service failures.

10. Other circumstances stipulated by laws and regulations.

II. How we use cookies and similar technologies

(i)Cookie

To ensure that the Site works properly, to make your visit easier, and to recommend content that may be of interest to you, we may store on your computer or mobile device cookies, Flash Cookies, or other local storage provided by your browser (or associated application) that typically contains an identifier, site name, and certain numbers and characters (collectively as "Cookie"). With the help of cookies, websites are able to store data such as your preferences or the items in your shopping cart.

You may modify your acceptance of cookies or refuse our cookies if your browser or browser add-on service allows you to do so; for more information, see AboutCookies.org. However, if you do so, it may in some cases affect your ability to access our site securely and may require you to change your user settings each time you visit our site.

(ii) Similar technologies as Cookie

In addition to cookies, we use web beacons, pixel tags, ETags (entity tags), and other similar technologies on our website.

For example, an email we send you may contain a link to an address that links to content on our site, and if you click on that link, we track that click to help us understand your product or service preferences so that we can proactively improve our customer service experience. A web beacon is typically a transparent image embedded in a website or email. With the help of a pixel tag in the email, we can tell if the email was opened. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.

ETag is an HTTP protocol header that is transmitted behind the Internet browser and the Internet server in place of a cookie. ETag helps us to avoid unnecessary server load, improve service efficiency, save resources, energy, and we may use ETag to record your identity so that we can gain more insight and improve our products or services. Most browsers provide users with the ability to clear browser cache data, and you can perform the appropriate data clearing operations in the browser settings function. However, please note that if you disable ETag, you may not be able to enjoy a relatively better experience with our products or services.

III. How we share, transfer, and publicly disclose your personal information

(i)Share

It is Walnut Coding’s bottom line and basic principle to respect and protect the privacy of you. Walnut Coding will not provide your personal information to third parties, except in the following circumstances:

1.With the express authorization or consent of you, we will share your personal information with other companies, organizations and individuals.

2.It may be necessary for us to disclose your 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. Your personal information may be shared with our affiliates and/or designated service providers in order to facilitate our provision of products or services to you, 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 your sensitive personal information 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 some of your personal information with our partners in order to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific and explicit purposes. Our partners do not have the right to use the personal information we share for any other purpose.

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 your personal information 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 your personal information or we de-identify this information so that it does not identify you. 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：

(ii)Transfer

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

1.Transfer with express consent: After obtaining your express consent, 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, we will require the new company or organization holding your personal information to continue to be bound by this Policy if the transfer of personal information is involved, or we will require the company or organization to seek authorized consent from you.

(iii). Publicly Disclosing

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

1.Based on your express consent or active choice.

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 your personal information, including relevant violations and the measures Walnut Coding has taken against you, in accordance with laws and regulations or with your consent.

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

Your prior authorized consent is not required for the sharing, transfer, or public disclosure of your personal information in the following cases:

1.Related to the fulfillment of our obligations under laws and regulations;

2. Directly related to national security or national defense security;

3. Directly related to public safety, public health, and significant public interests;

4. Directly related to criminal investigation, prosecution, trial and execution of judgments, etc.;

5. For the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain your consent;

6. Personal information that you disclose to the public on your own;

7. Personal information collected from legitimate public disclosures, such as legitimate news reports, government information disclosure and other channels.

Please be aware that, in accordance with applicable law, if we take technical measures and other necessary measures to process personal information in such a way that the recipient of the data cannot re-identify a specific individual and cannot recover it, the sharing, transfer, or public disclosure of such processed data does not require separate notification to you and your consent.

IV. How we store and protect your personal information

(i). Store

1.Storage Territory

Personal information 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 your express authorization.

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

In such cases, we will ensure that your personal information 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 your personal information has exceeded beyond the retention period, we will delete or anonymize your personal information as required by applicable law.

(ii)Protect

1.We will take all reasonable and feasible measures to protect your personal information. 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.

4. After the unfortunate occurrence of personal information security events, we will inform you in a timely manner in accordance with the requirements of laws and regulations: the basic situation of the security event and the possible impact, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement.

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 your personal information

(i). Access to your 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 your 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. After you voluntarily cancel your account, we will stop providing services to you, delete your personal information or anonymize it as required by applicable law, except as otherwise provided by law or regulation.

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

You 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 VIII 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.

In the following cases, we will not be able to respond to your request in accordance with the requirements of laws and regulations.

1. Related to national security, national defense security;

2. Related to public safety, public health, and significant public interests;

3. Related to crime investigation, prosecution, trial and execution of judgment, etc.;

4. Where there is sufficient evidence of subjective malice or abuse of rights by the subject of personal information

5. Response to your request will lead to serious damage to the legitimate rights and interests of you or other individuals or organizations

6.Involving commercial secrets.

VI. How we deal with the information of juvenile?

We presume that you have the appropriate civil capacity in the context of electronic commerce activities. If you are a juvenile, we ask that you ask your parent or other guardian to read this policy carefully and to use our services or provide us with information with the consent of your parent or other guardian.

Once we identify you as a child user through real person authentication, we will notify your guardian and ask your guardian to agree to the rules for the collection and use of children's personal information. Where we collect personal information from children with the consent of their parents or guardians to use our products or services, we will only use, share, transfer or disclose this information as permitted by law or regulation, as expressly agreed by the parent or other guardian, or as necessary to protect the child.

If you are a parent or other guardian of a child, you will be deemed to have consented to our collection of personal information about that child by providing us with personal information about the child in your custody or allowing that child to use the Walnut Coding Platform. Please read this policy carefully before providing us with personal information about the child in your custody or allowing the child to use our services. If you discover 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 via the contact information in Section VIII.

VII.How this policy will be updated

This Policy is subject to change as laws and regulations are introduced or amended. We will not limit your rights under this Policy without the express consent of yourself.

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).

Significant changes referred to this policy include but are not limited to:

1. Significant changes in our service model, such as the purpose of handling personal information, the type of personal information handled, the way personal information is used, etc.

2. Significant changes in our control rights and other aspects, such as changes in the controller of information caused by mergers and acquisitions, reorganizations, etc.

3. Changes in the main recipients of personal information sharing, transfer or public disclosure.

4. Significant changes in your rights to participate in the handling of personal information and the manner in which they are exercised.

5. Changes in the department responsible for handling personal information security, contact information and complaint channels of us.

6. The personal information security impact assessment report indicates the existence of high risk.

VIII. 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@www.walnutcoding.com.

2.If you find that your 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 users’ personal information, you can contact him/her through Walnut-legal@hetao101.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