HC Privacy Policy
Last Updated: 14May2025
HC CENTURY EDUCATION. (hereinafter referred to as“HC”, “we” ，“us” or “our”) is well aware of the significance of your personal information and will do its utmost to ensure its security and reliability.
This Privacy Statement aims to clarify what personal data we process, why we process it, who receives your data and how you can exercise your legal rights.
In this Privacy Statement, “personal data” means any information which directly identifies you as a person (like the combination of your full name and address), or can be used to identify you as a person (like a user ID connected to your identity). Similarly, “processing” refers to any operation performed on your personal data, for example the collection, storage, use, disclosure, or destruction of your personal data.
WHO ARE WE AND HOW CAN YOU REACH US?
We are HC CENTURY EDUCATION, and we are located at Selangor Puchong No.6F-2,6thFloor
With regard to your privacy, it is us who decide how and for what purposes your personal data is processed. In data protection language that makes us a so-called “data controller” (the party responsible for how your personal data is processed).
WHICH CONTENT INFORMATION WILL WE HANDLE?
1.How do we collect and use your personal information
2. How do we use cookies and similar technologies
3. How do we share, transfer or publicly disclose your personal information
4. How do we protect and preserve your personal information
5. Your rights
6. How do we handle the personal information of minors
7. How is this Privacy Policy updated
8. How can you get in touch with us
1、 How do we collect and use your personal information
You agree to provide us with the following information in the following links and authorize us to identify, record, retain and use the following information when providing services to you. At the same time, you authorize us to provide necessary information to a third party when it is needed to cooperate in providing services for you.
(1) Register as a user
When creating an account, you need to provide the following information: your name, mobile phone number, email address, the username and password you created.
During the registration process, if you provide the following additional information, it will help us offer you better service and experience: bound mobile phone number, wechat, occupation and birthday, etc. As the product service is related to actual usage, if the information provided by the user is incomplete or untrue, it may restrict or prevent the use of some functions during the usage process.
(2) Page content Display
Except as otherwise provided by law, we will provide the information you personally provide to this software, the information generated from enjoying the services of this software (including the information provided and generated before the signing of this agreement), and the information that this software queries and collects in accordance with the provisions of this article. It is used for this software and the partners entrusted by the service to provide services, recommend products, conduct market research and information data analysis for the user himself/herself.
In order to carry out internal data analysis and research, third-party SDK statistical services, and improve our products or services, we will only assess the necessity to collect some of your data within the smallest scope during your use of the software service.
We collect data based on your interactions with us and the choices you make, including your privacy Settings and the products and features you use
The data we collect includes the following contents and may correlate the information collected from your various devices:
IP Address: When you log in, we will collect the IP address of your device to determine whether you are in an abnormal login or other situations.
Device serial number: During the initialization of the SDK, we will collect your device serial number to confirm whether the operation is performed using the same device.
Terminal manufacturer and equipment model: When users encounter abnormal functions, we will collect your terminal manufacturer and equipment model to analyze the resulting problems. When users are using the functions, the functional interfaces will be adapted according to different device models.
Terminal device operating system version: When users encounter abnormal functions, we will collect the operating system version of your terminal device to analyze the resulting issues
Network status (mobile signal and WiFi signal) : When users are using the App, we will detect your network status and optimize the network download experience.
CPU and battery usage: When users encounter abnormal functions, we will collect your CPU and battery usage information to analyze the resulting issues.
System logs (READ_LOGS) : When users encounter abnormal functions, we will read the system log information generated when the program exits abnormally to solve the problem of program crashes.
When you enable the device location function and use the related services we provide based on location, we may collect and process information about your device, location, and network identity, so that you can obtain the relevant services without manually entering your geographical coordinates. We will use various technologies for positioning. These technologies include IP addresses, GPS and other sensors that can provide relevant information (such as possibly providing us with information about nearby devices, Wi-Fi access points and base stations). You can disable the location function through system authorization to stop us from collecting your geographical location information. However, after that, you may not be able to use the relevant services or functions, or may not achieve the intended effect of the relevant services.
(3) Delivery Address
When users set the delivery address, they need to fill in the specific address information. The product provides a location acquisition function. In this case, we will apply for the location permission and use the user's geographical location to complete the setting operation. If refused, it will result in the inability to obtain the user's location information, thus preventing the automatic acquisition of the current address.
(4) Upload attachments
Support users to upload attachments, including files in formats such as pictures, Word, and excel. For image format, it is necessary to obtain camera and album permissions in order to take pictures or obtain appropriate image content from the album. If the file is in formats such as Word or Excel, it is necessary to obtain the storage permission of the mobile phone in order to upload the relevant document from the local mobile phone.
(5) Basic Functions
1）. Personal information setting and modification
When you use your personal profile Settings and changes, we will request authorization for camera and album permissions to upload and change your personal profile picture.
2）. Problem handling
To facilitate contact with you, help you solve problems as soon as possible, or record the solutions and results of related issues, we will retain your communication/call records with us and related content (including account information, order information, other information you provide to prove relevant facts, or the contact information you leave). If you consult, complain or offer suggestions regarding a specific order, we will use your account information and order information.
(6) Ensure transaction security
To enhance the security of your use of services provided by us and our affiliated companies and partners, we use or integrate your account information, transaction information, device information, software usage records, click records, as well as the information shared by our affiliated companies and partners with your authorization or in accordance with the law. To comprehensively identify the risks of your account and transactions, conduct identity verification, detect and prevent security incidents, and take necessary measures such as recording, auditing, analyzing and handling in accordance with the law.
(7) Online use of virtual goods
For the virtual goods within HC, including courses, audio books, e-books, and live broadcasts, we provide you with online usage functions (the online usage functions for each specific virtual goods may vary slightly, and the functions displayed within HC Academy shall prevail). You can comment, leave messages, forward, take notes, and also collect and share in the corresponding interfaces. For this purpose, We need to collect your HC account and software usage records to achieve the aforementioned functions.
Please note that the information you publicly release may involve your or others' personal information, or even sensitive personal information. Please be more cautious when sharing or even publicly sharing relevant information.
(8) Provide you with other additional functions
During your use of the software service, to ensure that you can use the product functions normally, we will only collect some of your information based on the principle of maximum necessity and minimum scope during the usage period, and apply to the system for the following device permissions of yours. Before applying, we will seek your consent. You can choose to "allow" or "prohibit" the permission application. After your application is successful, you can enter the "Settings - Permission Management" on your mobile phone at any time to turn off the corresponding permissions. Once the permissions are turned off, the related product functions may not be able to be used normally. These additional services include:
Data statistics and product optimization
To ensure your security when using our products, we only collect your hardware device information once each time you launch the App (including: The mobile phone brand, model, system version number, IMSI information, IMEI information, device MAC address, device serial number, advertising tracking identifier (IDFA), software usage record, click record, IP address, etc. are matched with the device information on the system to assess whether there is any risk in your account login. During this process, we will apply to the system for the "permission to obtain device information".
2. Obtain the information of the processes currently running in the device's memory
During live streaming and course learning, we will apply for the permission to obtain the list of currently running programs and the information of the processes currently running in memory, providing a better experience. We will apply for the floating window permission on the Android end. When users play course audio, they can display the playback progress and control the playback status.
(9) Communicate with you
We will use the collected information (your mobile phone number, email address) to communicate or interact with you directly. For example, if we or our affiliated companies detect abnormal login activities.
(10) Improve and operate HC products and services
We use the collected information to provide and improve the products and services we and our affiliates and partners offer, and to conduct necessary business operations, such as operating products or providing services, evaluating, maintaining and improving the performance of products and services, developing new products and services, and providing customer support, etc.
To improve our products and services as well as those of our affiliates and partners, we may also conduct statistics and analysis on the usage of our products. Meanwhile, HC Academy may share these statistical information with affiliated parties, partners, and the public to demonstrate the overall usage trends of our services. However, these statistical information will not contain any of your identifiable information.
(11) The collection of personal information by third-party software development kits (SDKS)
In order to enable you to receive information push notifications when using HC, share information on third-party platforms, log in with third-party platform accounts, and ensure the security of your accounts, etc., this platform integrates software development kits (SDKS) developed and provided by third-party companies. These software development kits (SDKS) need to collect some information when implementing functions, as follows:
1. By using the wechat Share SDK provided by Tencent Technology Co., LTD., we collect your device information and can share courses, live broadcasts and other content to your wechat friends and Moments.
2. Use the Alibaba Cloud Player SDK to provide audio and video playback functions.
The types of personal information collected: UUID and device model (used to identify the terminal, perform performance tuning and fault analysis), IP address (1. The server-side interface related to calling the SDK 2. Compatible for performance tuning and fault analysis)
(12) Other uses
When we need to use the information for purposes not stated in this Privacy Policy, or use the information collected for a specific purpose for other purposes, we will seek your consent in advance.
2. How do we use cookies and similar technologies
(1) Cookies
To ensure the website operates normally, we will store small data files named cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters.
We will not use cookies for any purposes other than those described in this policy. You can manage or delete cookies according to your own preferences. You can clear all the saved cookies. Most web browsers have the function of blocking cookies. But if you do so, you will need to change the user Settings yourself every time you visit our website.
(2) Website beacons and pixel tags
In addition to cookies, we also use web beacons, pixel tags and other similar technologies on our website. For example, the emails we send to you may contain click urls that link to the content on our website. If you click on this link, we will track this click to help us understand your preferences for products or services and improve customer service. Website beacons are usually transparent images embedded in websites or emails. With the help of pixel tags in emails, we can know whether the emails have been opened. If you do not wish your event to be tracked in this way, you can unsubscribe from our mailing list at any time.
(1) Share your personal information
We will not share your personal information with any company, organization or individual, except in the following circumstances:
1. Obtain your explicit authorization or consent in advance: After obtaining your explicit consent, we will share your personal information with other parties;
2. Sharing under legal circumstances: Sharing your personal information in accordance with applicable laws and regulations, legal procedures, litigation/arbitration, government mandatory orders or regulatory requirements;
3. Within the scope required or permitted by law, it is necessary to provide your personal information to a third party in order to protect your or the public's interests, property or safety from damage.
4. To protect national security, public security, and your and other individuals' significant legitimate rights and interests, it is necessary to share your personal information;
5. Provided based on academic research;
6. Provided based on social public interests that comply with laws and regulations;
7. Your personal information that you have disclosed on your own or that we can obtain from other legal public channels;
8. Sharing with Partners: To provide you with more complete and high-quality products and/or services, some of our services will be provided by partners. We may share your personal information with our partners, including personal phone number, user data ID, user student number, desensitized user name information, device model, system type, system version, Mac address, and device serial number. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and only the personal information necessary to provide you with services will be shared. At the same time, we will sign strict confidentiality agreements with our partners, requiring them to handle your personal information strictly in accordance with our instructions, this policy, and any other relevant confidentiality policies, and to take security measures. We require our partners to have no right to use the shared personal information for any other purposes. The partner may have its own independent privacy policy and user agreement. We suggest that you read and abide by the user agreement and privacy protection policy of the third party.
If you refuse our partner's collection of personal information necessary for providing services, it may result in your inability to use the services provided by that partner on this platform.
At present, our main partners are system service providers. When third-party software and hardware/system products or services are combined with our products or services to provide you with services, with your authorization, we will provide your personal information to the third-party software and hardware/system service providers, including personal phone numbers, user data ids, user codes, The desensitized user name information, device model, operating system type, system version, Mac address, and device serial number are provided for your use of the service or for us to analyze the usage of the product and service to enhance your user experience.
(2) Transfer
We will not transfer your personal information to any company, organization or individual, except in the following circumstances:
1. When obtaining your explicit consent;
2. As required by applicable laws and regulations, industry rules, legal procedures, litigation/arbitration, government mandatory orders, and regulatory requirements;
3. To protect national security, public security, and your and other individuals' significant legitimate rights and interests, it is necessary to share your personal information;
4. Your personal information that you have disclosed on your own or that we can obtain from other legal public channels.
(3) Public Disclosure
We will only disclose your personal information in the following circumstances:
Obtain your explicit consent;
2. Based on laws and regulations, legal procedures, litigation or mandatory requirements of government authorities.
(4) Exceptions where prior authorization and consent are obtained when sharing, transferring or disclosing personal information
In the following circumstances, sharing, transferring or disclosing your personal information does not require prior authorization and consent from you:
1. Related to national security and defense security;
2. Related to public security, public health, and major public interests;
3. Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of judgments;
4. Where it is necessary to safeguard your or another individual's vital legitimate rights and interests such as life and property, but it is difficult to obtain your consent;
5. Personal information that you have voluntarily disclosed to the public;
6. Collecting personal information from legally disclosed public sources, such as legitimate news reports, government information disclosure channels, etc.
7. Where it is necessary to enter into and perform a contract at the request of the personal information subject;
8. Other circumstances as prescribed by laws and regulations.
According to the law, sharing or transferring personal information that has been de-identified and ensuring that the data recipient cannot restore and re-identify the personal information subject does not fall under the category of external sharing, transfer or public disclosure of personal information. For the storage and processing of such data, there is no need to notify you separately or obtain your consent.
4. How do we protect and preserve your personal information
(1) Shelf life
During your use of HC products and services, we will continuously retain your personal information for you. If you cancel your account or actively delete the above information, we will retain your information in accordance with the provisions of laws and regulations. After you cancel your account, actively delete the above information or exceed the retention period, we will no longer use your personal information for commercial purposes, but we may use your personal information after anonymizing it.(2) Safety Measures
1) We will strive to ensure the security of your information and adopt corresponding security technical measures such as encryption and de-identification to prevent the loss, improper use, unauthorized access or disclosure of your personal information. We will take various reasonable and feasible measures within a reasonable security level to protect the security of your personal information. For example, technologies such as SSL encryption and token authentication are adopted; Meanwhile, provide the https secure browsing method for the website itself; Use trusted data storage and protection mechanisms to prevent data from being maliciously attacked, etc.
2) We have established dedicated management systems, processes and organizations to ensure the security of your information. Such as deploying access control mechanisms and strictly limiting the scope of personnel accessing personal information, etc.
3) Implement classified management of personal information. We will take reasonable and feasible measures to do our best to avoid collecting irrelevant personal information. We will only store your personal information for the period necessary to achieve the purposes described in this policy, unless an extension of the storage period is required or permitted by law.
4) Reasonably determine the operational authority for processing personal information and regularly provide security education and training to employees.
5) Formulate and implement emergency response plans for personal information security incidents. In the event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations through email, phone, push notifications, etc. The content and impact of the security incident, the measures we have taken or will take to handle it, suggestions for you to independently prevent and reduce risks, remedial measures for you, contact information of the person in charge of personal information protection and the personal information protection working institution, etc.
(3) How long will we retain your personal information?
We will not retain your personal information for longer than necessary for the purposes for which it was collected. However, the relevant personal data may be retained under the following conditions:
When required by law.
The place where legal proceedings have occurred and are being heard.
HC CENTURY EDUCATION for commercial/operational purposes.
We will take all reasonable steps to ensure that all personal data is destroyed or permanently deleted when no longer needed, and prepare a schedule for the disposal of inactive data within 24 months.
（4）How do we ensure the security of your personal information?
We will take all reasonable and necessary precautions to protect your personal data from being misused, interfered with and lost. As well as unauthorized access, modification or disclosure. In addition, our company will protect your data in the following ways:
Register all those who are allowed to enter.
Control and restrict access as needed.
Keep appropriate records of access to and transfer of personal data.
Ensure the confidentiality of all employees in the company.
Implement an awareness plan for all employees regarding the collective responsibility for protecting personal data.
Establish physical security procedures.
Restrict third parties involved in the processing of personal data.
Personal data should not be transferred or stored using mobile devices and cloud computing services unless written consent is obtained from the top management of the company.
5. Your Rights
(1) Access your personal information
You have the right to access your personal information, except as otherwise provided by laws and regulations. If you want to exercise your data access rights, you can access them by yourself through the following methods:
Account Information - If you wish to access or edit your profile information in your account and change your password, you can do so through the "My" Personal Information page.
For the personal information of you generated during your use of our products or services, as long as we do not require excessive investment, we can provide it to you upon your application.
(2) Correct your personal information
When you find that the personal information we process about you is incorrect, you have the right to request us to make corrections. You can submit a correction request through the methods listed in "(1) Accessing Your Personal Information".
(3) Delete your personal information
You can request us to delete your personal information at any time. You can contact us through the contact information provided in this policy to make a deletion request.
If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal information from us to delete it in a timely manner, unless otherwise stipulated by laws and regulations, or these entities have obtained your independent authorization.
When you delete information from our service, we may not immediately remove the corresponding information from the backup system, but we will delete it when the backup is updated.
(4) Alter the scope of your authorization and consent
Withdraw consent
If you want to change the scope of authorization, you can modify it through the Settings of the HC product.
When you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawal of consent or authorization, nor will we process your relevant personal information. However, your decision to withdraw consent or authorization will not affect the processing of your personal information that was carried out based on your consent or authorization previously.
2. Push Settings
During the process of providing services, we may require you to activate device permissions: notification, camera, and mobile phone number access permissions.
You can choose to turn off some or all of your permissions at any time in the "Settings" function of your device, thereby refusing us from collecting your corresponding personal information. The display and disabling methods of permissions may vary across different devices. For specific details, please refer to the instructions or guidelines provided by the device and system developers.
(V) The personal information subject cancels the account
If you need to cancel your HC account, you can contact us through the methods provided in this policy and request the cancellation of your HC account. After verifying your identity information, we will provide you with the account cancellation service.
After you cancel your account, we will stop providing you with products or services and delete your personal information as per your request, except as otherwise provided by laws and regulations.
(6) Be informed in advance that HC has ceased operations
HC is willing to always be by your side. If the operation of HC's products and services is forced to cease due to special reasons, we will notify you in advance by Posting an announcement within the HC product, sending you an email or other appropriate means that can reach you, and will stop collecting your personal information. At the same time, we will delete or anonymize the personal information we hold about you in accordance with the law.
6. How do we handle the personal information of minors
Our products, websites and services are only for adults. Minors are not allowed to create their own user accounts without the consent of their parents or guardians.
Although local laws and customs may define children differently, we consider anyone under the age of 18 as a non-adult. Where we collect personal information of minors with the consent of their parents or guardians, we will only use or disclose such information when permitted by law, explicitly agreed to by the parents or guardians, or when it is necessary to protect the minors. If we find that we have collected personal information of minors without obtaining verifiable consent from their guardians in advance, we will take measures to delete the relevant content as soon as possible. If guardians find that we have collected personal information of minors without their consent, please contact us and submit relevant materials for us to verify your identity. We will review it as soon as possible and try to delete the relevant data as soon as possible.
7. How is this Privacy Policy updated
To provide you with better services, we may adjust or change this Privacy Policy from time to time. We will publish any changed privacy policy on this page and remind you to read it again through appropriate means such as pop-up Windows, push notifications, red dot prompts, emails or text messages, and will apply again to obtain your authorization and consent.
For major changes, we will also provide more prominent notifications (we will explain the specific changes to the privacy policy through methods including but not limited to emails, text messages or special prompts on browsing pages, etc.).
The major changes referred to in this policy include but are not limited to:
(1) There have been significant changes in our service model. Such as the purpose of processing personal information, the types of personal information processed, and the way personal information is used, etc.
(2) We have undergone significant changes in terms of ownership structure, organizational structure, etc. Such as changes in ownership caused by business adjustments, bankruptcies, mergers and acquisitions, etc.
(3) The main objects of personal information sharing, transfer or public disclosure change;
(4) There are significant changes to your rights regarding the processing of your personal information and the ways to exercise them;
(5) When the department responsible for handling personal information security, contact information or complaint channels change;
(6) When the personal information security impact assessment report indicates a high risk;
(7) Other changes that may have a significant impact on your personal information rights and interests.
CHANGES TO THIS PRIVACY STATEMENT
We may update this Privacy Statement from time to time to reflect our new processes, new technologies, and legal obligations. We are committed to keeping you informed of any changes to our privacy practices, so we encourage you to review this privacy statement to keep updated.