【EasyTransfer Group】 (hereinafter referred to as "we") attach great importance to the protection of personal information and privacy of our users ("you"), and will endeavor to protect your personal information by adopting corresponding security protection measures as required by applicable laws and regulations. We wish to introduce by means of this Privacy Policy to you in a clear manner when you use our products/services. How we handle your personal information and the means we provide for you to access, correct, delete and protect such information.
【Special Notice】
This Policy is very important for you to use our products or services, so please make sure you read it carefully, fully understand it (the key contents are bolded for your special attention) and make corresponding choices before using our products or services. We will collect, use your personal information in accordance with this Policy to provide relevant products or services to you. If you do not agree to any content of this Policy, you must immediately stop using our products or services.
This Privacy Policy will help you to understand the following:
I 、How do we collect and use your personal information
II 、 How we use cookies and similar technologies
III 、 How do we share, transfer and publicly disclose your personal information
IV 、 How we protect your information
V 、 How you access and control your personal information
VI 、 Minors' information protection
VII 、 Notices and amendments
VIII 、 How to contact us
IX 、 Appendices
I 、How we collect and use your personal information
In connection with your use of our products and/or services, there are two kinds of personal information that we need or may need to collect and use:
1、You shall authorize us to collect and use such information as may be necessary for the realization of the basic functions of providing our products and/or services to you. If you refuse to provide the corresponding information, you will not be able to normally use our products and/or services;
2、You may choose to authorize us to collect and use such information in order to realize the additional functions of providing our products and/or services to you. If you refuse to provide such information, you will not be able to normally use the relevant additional functions or achieve the functional effects that we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services.
We will collect and use your personal information in order to perform the following functions of this Policy in accordance with the principles of fairness, lawfulness and necessity:
1 Help You Become Our User
After you login the website through your account, we will obtain, based on your authorization, the user ID, login name, nickname, head photo, name, bound mobile phone number, information in the system of your school that is related to you, such as school name, school number, date of birth, and other reserved information, as well as relevant information on account real-name authentication. The purpose of collecting these information is to implement the requirements of applicable laws and regulations on the real-name system, and to help you complete the operation of overseas study payment smoothly. We also want to guarantee the safety of your account and prevent security risks. If you refuse to authorize a login, you will not be able to normally use the products or services we provide. If you only need to use the website to use the to use our to Our website to browse and search to us, we provide the above information.
We may share your account information (avatar photo, nickname and other information indicated on the page) with a third party upon your consent, so that you can easily register for or log in on the third party's account or use the third party's membership service and enjoy member benefits provided by the third party. In addition, we may, based on your authorization, obtain your third party account information from a third party and bind such information with your third party account, so that you may directly log in, use our products and/or services through your third party account. We will use to the extent of Your Information to the of you to the extent as authorized by your authorization.
After your authorized login by using your account, we may display your above personal information and the operations you perform on the website by using the products or services provided by the website or affiliated companies of the website through the above account, including display of your personal information, published content, comment interaction, etc., in various services of the website.
2 Providing you with information display of goods or services
When you use our services, in order to identify abnormal status of your account, to know the suitability of products, to provide you with page displays and search results that are more suitable to your needs, we may automatically collect your usage information and store it as web log information. When you use the products or services provided on our website or client, we will automatically collect details of your usage of our services and keep them as service log, including browsing, clicking, search queries, favorites, follows, sharing information, posting information, as well as IP address, browser type, telecommunications operator, language used, access date and time.
3 Customer Service and Dispute Handling
n order to easily use the products and services we provide, promptly answer your questions arising from your use of the products and services we provide, promptly intervene in your disputes with other website users or third parties, we provide you with customer service. When you use the website services, in order to ensure your user experience, if necessary, we may proactively contact you through the mobile phone number associated with the account you login. When you seek customer service, we will collect the mobile phone number you use when contacting us or other contact information you provide at your own initiative, related order information as well as the words and call records formed during the contact process. This information is necessary to locate the service problems you provide feedback on. If you refuse to provide the relevant information, we may not be able to provide you with customer service.
4 Providing Security for You
To protect you or other users or the public from personal and property damage, to enhance the security of your use of our services, and to better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, we may use or integrate your user information, transaction information and the information shared by our affiliates and partners with your authorization or according to the law, to comprehensively judge the risks of your account and transactions, to conduct identity verification, to detect and prevent security incidents, and to take necessary record, audit, analysis and disposal measures according to the law.
In order to protect the security of your account, the security of your transactions and the security of our systems, and to meet the relevant requirements of laws, regulations and rules of our agreements, in the course of your use of our products or services, upon your authorization, we may receive and record information relating to the devices you use (including software and hardware information such as device model, operating system version, device settings, unique device identifier, and device environment) and location information relating to the devices (including GPS location and sensor information such as WLAN access point, Bluetooth and base station that you authorize).
5 Providing Other Additional Services for You
In order to provide you with more convenient, better and more personalized products and/or services, and in an effort to enhance your experience, we may collect and use your personal information in the following additional services that we provide you. If you do not provide this information, it will not affect your use of the website to browse, search, make purchases and other basic services, but you may not be able to obtain the user experience that these additional services bring to you. These additional services include:
1、Location-based personalized recommendation service: we may access your location information after your location permission is turned on, and provide you with page presentations, products and/or services that better suit your needs, such as recommending offers near you.
2、Camera/webcam -based additional services: after your camera/webcam permission is turned on, you may use this feature to scan ID for sign-in, to take photos or videos for commenting and sharing, and to recognize faces that you authorize in specific scenes.
3、Album (Picture Library/Video Library) -based picture/video access and upload services: after your album permission is turned on, you may use this feature to upload your photos/pictures/videos to achieve functions such as changing your avatar, making a comment/sharing, taking a photo, or communicating with customer service to provide proof, etc.
4、Microphone -based voice technology related additional services: after your microphone permission is turned on, you may use the microphone to achieve voice communication, or to contact customer service, or to achieve voice interaction with customer service robots. This feature can be turned off in System Permissions, and if it is turned off, you may not be able to achieve online voice interaction functions.
5、Address Book based additional services: after you turn on your Address Book permission, we may collect your Address Book information to make it more convenient for you to access contact information in your Address Book when interacting on the website, without the need for manual input.
6、Calendar based additional services: after you turn on your Calendar permission, we may collect your Calendar information to provide you with relevant records and reminders.
You understand and agree that the above additional services may require you to turn on your location (geolocation), camera (camera), photo album (picture library), microphone (voice), Address Book and/or Calendar permissions on your device in order to enable the collection and use of information relating to these permissions. You can check the status of these permissions case by case in your device settings or in the "My- Settings - Privacy - System Permissions" on our client and may decide to turn these permissions on or off at any time. Please note that, by turning on any of the permissions, you authorize us to collect and use relevant personal information for providing corresponding services to you, and once you turn off any of the permissions, you cancel your authorization, and we will not continue to collect and use relevant personal information based on the corresponding permissions and cannot provide you with corresponding services based on the permissions. However, your decision to turn off the permissions will not affect the previous collection and use of personal information made based on your authorization.
6 Miscellaneous
1、If the information you provide contains other users' personal information, you shall make sure that you have obtained legal authorization before providing such personal information to the website.
2、If we use the information for any purposes not described in this Policy or if we use the information we have collected for a specific purpose for other purposes, or if we actively obtain your personal information from a third party, we shall obtain your prior consent.
3、Exceptions to Authorized Consent
You fully understand and agree that, our collection and use of your personal information do not require your authorized consent and we may not respond to your requests for correction/amendment, deletion, cancellation, withdrawal of consent or request for information under the following circumstances:
- (1) related to national security and national defense security;
- (2) related to public security, public health and vital public interests;
- (3) related to judicial or administrative enforcement of law such as criminal investigation, prosecution, trial and judgment enforcement;
- (4) necessary to protect your or other individual's life, property and other significant legitimate rights and interests, but it is difficult to get the personal's consent;
- (5) personal information that you voluntarily disclose to the public;
- (6) collecting personal information from legally and publicly disclosed information, such as legal news reports and government information disclosure channels;
- (7) necessary in accordance with relevant agreements or other written documents entered into and performed with you;
- (8) necessary for maintaining safe and stable operation of products and/or services provided, such as finding and disposing of failures of products and/or services;
- (9) necessary for legitimate news reports;
- (10) when it is necessary for an academic research institution to carry out statistical or academic research for the purpose of public interest and the results of academic research or description are provided to external parties, the personal information involved in such results is de-identified;
- (11) other circumstances provided by laws and regulations.
You are advised that, pursuant to applicable law, we may use personal information processed without notice to and consent from you, if we use technical and other necessary measures to process personal information that render the data recipients unable to re-identify a specific individual and irrecoverable, or we may conduct de-identified research, statistical analysis and projections on the data collected to improve the content and layout of the website, to provide products or services in support of business decisions, and to improve our products and services (including the use of anonymized data for machine learning or model algorithm training).
4、If we cease to operate the website products or services, we will stop the continuous collection of your personal information in a timely manner, notify you of the cessation of operation in the form of one-by-one service or public announcement, and delete or anonymize the personal information we hold in connection with the ceased business.
II、How We Use Cookies and Similar Technologies
1 Cookie
To ensure that our websites work correctly, to provide an easier access experience for you and to recommend content to you that may be of interest to you, we store on your computer or mobile device a cookie, Flash cookie or other local storage provided by your browser (or associated application) that typically contains an identifier, a site name and certain numbers and characters (collectively, "cookie"). With the help of cookies, websites can store data such as your preferences or a record of your searching for terms.
If your browser or browser add-on allows, you may modify your acceptance of cookies or reject our cookies. For more information, see AboutCookies.org. If you do so, however, your access to our websites may be compromised in some circumstances, and you may need to change your user settings each time you visit our website.
2 Cookie Similar Technologies
In addition to cookies, we also use website beacons, pixel tags, ETags and other similar technologies on our websites. For example, an email we send you may contain a link to an address of content on our website. 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 the customer service experience.
3 Use of SDKs
To ensure the stable operation and fulfillment of the functionality of our website and enable you to use and enjoy additional services and functions, our applications may embed SDKs from Authorized Partners or other similar applications. Click to view our access to the details of our SDKs from Authorized Partners.
We perform stringent security examination of the application programming interfaces (APIs) and software tool development kits (SDKs) from which Authorized Partners access this information and agree with Authorized Partners on strict data protection measures to require them to process personal information in accordance with this Policy and any other relevant confidentiality and security measures.
III、How We Share, Transfer and Publicly Disclosure Your Personal Information
1 Sharing
We do not normally share your personal information with persons outside of the website. However, we will share your personal information with other persons in the following circumstances in order to enable us to fulfill services requests you have made, to optimize our services or in response to regulatory or judicial needs:
1、Sharing with Express Consent: Your personal information may be shared with other parties only if we have obtained your express authorization to do so.
2、Sharing under Statutory Circumstances: subject to relevant laws and regulations, for the purpose of litigation activities, or for the purpose of satisfying requirements imposed by administrative authorities or judicial authorities, we may share your personal information.
3、Sharing with Authorized Partners: We may entrust Authorized Partners to provide you with certain services or perform functions on our behalf for the purposes of collection and use of personal information as expressly set forth in this Policy. We will only share your information for legal, justified, necessary, specific and express purposes. Authorized Partners may only have access to the information necessary to perform their Duties and may not use such information for any other purpose.
Our Partners include the following types of persons:
（1）Advertising and analytics service providers: these partners will help analyze the quality and effectiveness of the services available on the website and the marketing effect of the website, and we will only provide such service providers with the anonymized information that will not identify you;
（2）The institutions and banks with qualification of onshore and cross-border payment and the overseas institutions which you want to make remittance: Such information will be shared to ensure the accuracy of your instruction to pay the tuition fee and ensure that your tuition fee can be remitted to the overseas institutions designated by you in a legal way;
4、Based on agreements: it is necessary to share with a third party in accordance with relevant agreements signed by you and us;
5、Based on reasonable business practices.
6、Based on social public interests consistent with laws and regulations, etc.
2 Transfer
We will not transfer your personal information; however, if you expressly consent to transfer or the website undergoes merger, division, acquisition or bankruptcy, we will transfer your personal information to a new entity; provided that we will require the new entity to comply with the relevant requirements of this Policy; otherwise, we will require the new entity to obtain your consent again.
3 Public Disclosure
We will not disclose your personal information publicly, except that we will disclose relevant personal information about you under the following circumstances:
1、The personal information to be disclosed as expressly agreed or required by you.
2、If we determine that you have violated laws, regulations or seriously violated relevant agreements and rules of the website, or in order to protect the personal or property safety of the website users or the public, we may disclose personal information about you, including relevant violations and measures the website has taken against you, in accordance with the laws and regulations or with your consent.
4 Exceptions of Prior Authorized Consent for Sharing, Transfer and Public Disclosure of Personal Information
Under the following circumstances, no prior authorized consent is required for the sharing, transfer or public disclosure of your personal information:
1、The information relates to national security and the security of national defense;
2、The information relates to public safety, public health and major public interests;
3、the information relates to criminal investigation, prosecution, trial and execution of judgment;
4、the information aims to protect your or other individuals' life, property and other significant legitimate rights and interests, but it is difficult to get your consent;
5、the personal information that you voluntarily disclose to the public; and
6、the collection of personal information from legally and publicly disclosed information, such as legal news reports and government information disclosure.
Please be aware that, pursuant to applicable laws, in the event that we use technical measures and other necessary measures to process personal information that render the recipient of such information unable to re-identify a specific individual and impossible to recover such processing, the sharing, transfer and public disclosure of such processed data shall not be required without notice to you and your consent.
IV、How do we protect your personal information?
1 We have taken reasonable and practical security measures in compliance with industry standards to protect your information and protect personal information from unauthorized access, public disclosure, use, modification, damage or loss. For example, data is exchanged between your browser and servers under the SSL protocol encryption protection; we use encryption technology to improve the security of personal information; we use trusted safeguards to protect personal information from malicious attacks; we place access controls to ensure that only authorised personnel have access to personal information; and we provide security and privacy training to raise employees' awareness of the importance of protecting personal information.
2 We have an advanced data security management system in place which focuses on data and revolves around the life cycle of data. We enhance the security of the entire system from a multi-dimensional perspective in terms of organisational development, system design, personnel management and product technology.
3 We will take reasonable and practicable measures to endeavor to avoid the collection of irrelevant personal information. We will retain your personal information only for as long as is necessary to achieve the purposes stated in this Policy, unless there are retention requirements imposed by law, such as the Electronic Commerce Law of the People's Republic of China requiring retention of information relating to goods and services and transactions for at least three years from the date of completion of transactions. Our standards to judge the aforementioned retention period include:
1、Completing the purposes of transactions relating to you, maintaining relevant transaction and business records and responding to any inquiry or complaint you may have;
2、Ensuring the safety and quality of services we provide you;
3、Whether you agree to a longer retention period;
4、Whether there are other specific agreements regarding the retention period.
After the retention period of your personal information expires, we will delete or anonymize your personal information as required by applicable laws.
4 Please acknowledge and understand that the Internet is not an absolutely secure environment. When using the website's service, we strongly recommend that you do not send your information by any communication methods that are not recommended by the website.You can build connections and share information through our service. We strongly recommend that you assist us in safeguarding the security of your account in a secure manner with complex passwords. If you find that your personal information is disclosed, please let us know at once at the contact information provided in this Privacy Policy, so that we can take any necessary action.
5 Please note that, the information that you voluntarily share or even publicly share when using our service may involve personal information or even personal sensitive information of you or others.Please consider more carefully whether you share or even publicly share relevant information in using our service.
6 We will update and publicize relevant information such as security risks and personal information security impact evaluation reports from time to time, which you may obtain through bulletin published in the website.
7 If a personal information security incident occurs, we will inform you in accordance with the requirements of the laws and regulations: basic information and possible impacts of the incident, measures we have taken or will take in response thereto, suggestions for prevention and reduction of the risk at your own discretion and remedial measures against you, etc. We will inform you of the incident by mail, letter, telephone, push notice and other means. When it is difficult to inform personal information subjects one by one, we will publish an announcement in a reasonable and effective way. Meanwhile, we will also report the responses to personal information security incidents in accordance with the requirements of regulatory authorities.
V、 How You Access and Control Your Personal Information
In order to facilitate you to access and control your personal information and protect your right to revoke what you have agreed to, we have set up corresponding functions in the products or services offered on the website. You will use the following functions to access and control your personal information:
1 Access to Your Personal Information
Except as otherwise provided by laws and regulations, you have the right to access your personal information:
1、Account Information: You can access your personal data, account information, payment information, account binding information, etc.
2、Search and Browse Information: You can access or clear your search history, view and modify interests, and manage other data from the web.
Please note that after you delete relevant information, we will not display your deleted information in your website interface, and we will, in accordance with the requirements of applicable laws and regulations, store the information until the expiration of the statutory period, after which the information will be deleted or de-identified as soon as possible.
2 Correct or Supplement Your Account Information
Where there is any need to correct or supplement relevant personal information in your account number, you may make corresponding operations in the website.
3 Deleting Other Personal Information
You can clear your search information, information about items you have visited, and information about contents you have posted, etc., in the manner listed in "Access to Your Personal Information".
You may request us to delete personal information in the following situations:
1、If we collect or use personal information in violation of the law;
2、If we collect or use personal information without your explicit consent;
3、If we collect or use personal information in serious violation of the agreement with you;
4、If you no longer use our products or services, or you voluntarily deregister your account;
5、If we permanently no longer provide products or services to you.
After verifying your individual identity, we will delete your personal information within a reasonable time. At the same time, we will use our best efforts to notify the persons who have obtained personal information from the website to delete the relevant information in a timely manner. After you or we assist you to delete the relevant information, we may not be able to immediately delete the corresponding information from the backup system due to applicable laws and security technology. We will securely store your personal information and segregate it from any further processing until such time as the backups can be erased or rendered anonymous.
4 Withdraw or Change Your Authorization
You can set and modify the mobile phone authorization which is allowed for the client of the website to access through the tips in the website settings. If you are unable to set your authorization directly, you may modify it through contacting the our customer service. Please note, however, that with respect to certain types of personal information, such as information necessary for realizing the basic functions of the website or information necessary for us to perform our obligations stipulated by laws and regulations, we may not be able to respond to your request for change of scope of authorization. Your withdrawal or change of your authorization shall not affect the previous collection and use of personal information based on your authorization.
5 Cancel Your Account
If you need to cancel your account, you may log in to the website and cancel your account according to the account cancellation process of the website, or contact our customer service for consultation.
6 Responding to Your Request above
For security purpose, you may have to provide a written request or otherwise prove your identity. We may ask you to verify your identity before we process your request.
We will provide a reply within 15 days. If you are not satisfied, you may also make a complaint through the website customer service.
As a matter of principle, we shall charge no fee for your reasonable requests; however, we will charge a fee for repeated requests beyond a reasonable amount in our discretion. We may refuse to provide information that is not directly related to your identity, that duplicates your identity for no reason, that requires excessive technical measures (for example, it is necessary to develop a new system or fundamentally change a current practice), that brings risks to others' legitimate rights and interests or that is impractical.
According to the requirements of laws and regulations, we will not be able to respond to your request if:
• The information relates to the national security and the security of national defense;
• The information relates to public safety, public health or major public interests;
• The information relates to criminal investigation, prosecution, trial and enforcement of judgment;
• There is sufficient evidence to prove that the person disclosing the information has subjective malice or abuses his/her rights;
• Responding to your request will cause serious damages to your legitimate rights and interests or those of other individuals or organizations;
• Trade secrets are involved.
VI 、How We Deal with Information of Minors
In e-commerce activities, we assume that you have the corresponding capacity for civil conduct.If you are a minor, we request that your parent (s) or legal guardian (s) read this Privacy Policy carefully and that your parent (s) or legal guardian (s) consent before using our services or providing us with our information.
If a minor's personal information is collected for the use of our products or services with the consent of the minor's parent (s) or legal guardian (s), we will only use, share, transfer or disclose the information as permitted by law or regulation, as expressly consented to by the parent (s) or legal guardian (s), or as necessary for the protection of the minor.
If you are the parent or other guardian of a minor, please note whether the minor is using our services with your authorization. If you have questions about the personal information of a minor, please contact us via the contact details included in this Privacy Policy.
If we become aware that a minor's personal information has been collected without verifiable parental or legal guardian consent, we will seek to delete the relevant data as soon as possible.
VII 、Notices and Amendments
Our Privacy Policy is subject to change. We will not restrict any of your rights under this Privacy Policy without your explicit consent. We will post any changes to our Privacy Policy on a dedicated page. With respect to major changes, we will provide more conspicuous notices (including notices published on the websitewebsite and even pop-up window instructions to you).
Material changes referred to in this Policy include but are not limited to:
• Material changes in our service model. Such as the purpose of handling personal information, the type of personal information handled and the method of use of personal information, etc.;
• Material changes in our control right and other aspects. Such as change in information controller due to merger, acquisition, restructuring, etc.;
• Changes in the main object of personal information sharing, transfer or public disclosure;
• Material changes in your rights to participate in the processing of personal information and the method of exercising such rights; and
• Personal information security impact assessment reports indicate that there is a high level of risk.
VIII 、websitewebsitewebsite How to Contact us
You can contact us in the following ways and we will reply to your request within 15 days. You can contact us by email [cs@easytransfer.co.in] if you have any suggestion or other question related to privacy protection.
IX、 Appendix
• Personal information: refers to all information recorded electronically or otherwise, which, independently or in combination with other information, can identify the identity of specific natural persons or reflect the activities of specific natural persons.
• Personal sensitive information: refers to the personal information that, once disclosed, illegally provided or misused, may endanger the safety of person and property, and may easily lead to damage to personal reputation, physical and mental health or discriminatory treatment. Personal sensitive information that may be involved in this Privacy Policy includes: personally authenticated information (ID numbers, PAN), personal biometric information, bank accounts, property information, whereabouts and tracks, transaction information, information on minors under the age of 14 (inclusive), and other personal information.
• Deletion of Personal Information: refers to the act of deleting personal information from the systems involved in the realization of daily business functions so that such information remains in a status not retrievable or accessible.
• websiteWebsite: Easy Transfer referred to in this Privacy Policy shall refer to the Service websitewebsite operated by EasyTransfer Technology Co. Ltd.