1.Special Remarks

1.1.Donner is aware of the importance of personal information to users and will protect the information personal and privacy of users in accordance with the laws and regulations applicable where we operate. For this purpose, Donner has developed the Donner Privacy Policy (hereinafter referred to as “this Policy”) and provides the following special notes: Please read carefully and fully understand this Policy before to use the Donner mobile application or our website (hereinafter referred to as “Donner”) and associated services. Users' use of, or continued use of, the products and services provided by Donner, means that users agree to relevant user information being used and processed in accordance with this Policy. If users have any objections or questions regarding the terms of this Policy, please contact Donner for comments via the contact information published in Section 9 “ Contact Us” of this Policy.

1.2.This Policy applies to all products and services provided by Donner. The data controller for this application and website is Donner, who can be contacted at room 7002 and 7003, 7th floor, Parc Digital Entertainment Industry, Greater Bay District, No. 28, Huangpu Park West Road, District Huangpu, Guangzhou (hereinafter referred to as the “Company”) will provide Internet-based products and services (hereinafter referred to as the “Service”) in accordance with the provisions of the Donner Service Agreement and the operating rules issued sometimes.

1.3.Since the Company will launch more products and services in the future, and the content of the products and services provided to users is also different, this Policy is a general privacy policy applicable to Donner. For specific products and services to be launched in the future, the Company will also develop specific privacy policies, in order to stipulate more specifically with users the policies confidentiality and the rules of the Company. Users must read and fully accept all content specific privacy policies before using the specific products and services.

1.4.Only when users confirm and accept the modified Policy, the Company will collect, use, will process and store users' personal information in accordance with the Privacy Policy modified. Users have the right to refuse to accept the modified Policy. Once users refuse to accept the modified Policy, they will no longer be able to continue to use the associated services and functions to give.

2.Collection and Use of Users’ Personal Information 

2.1.The Company collects and uses personal information provided by users in the process of use of the services or generated due to the need for products or services, in accordance with the laws and regulations and following the principles of justice, legality and necessity. If the Company intends use users' personal information for other purposes not specified in this Policy, or to use the collected information for other purposes based on specific purposes, the Company will inform the users in a timely and reasonable manner.

2.2.Donner will collect and use users' personal information in the following scenarios

2.2.1.Collection and use of users' personal information during the account registration process

Data Processing Activities Data type Legal Basis for Processing
When a user registers a service account username, password, phone number mobile or email address and social media handle, user name image, name username and personal information (if the user registers with a network ID social) When you have given your consent
When a user logs in with an account from a third-party platform (like Facebook or Google) username, nickname, avatar and information authentication When you have given your consent
When a user voluntarily adds a profile additional the user can also voluntarily provide additional personal information such as graphics, date of birth, gender, location and other information about the user as well as the user's interests on the page personal information When you have given your consent
When a user uploads content content uploaded by users to the Service may be used by others to identify users (e.g. user photos, recordings or texts containing user names, status updates, comments on content mentioning users). When you have given your consent


2.2.2. Collection and use of users' personal information in the research process

Data Processing Activities Data type Legal Basis for Processing
When a user uses the search function in Donner equipment information, log information, including words or searched phrases, browsing records and time, time and number of searches Necessary for our legitimate interests: supporting customers and other requests, operate our business


2.2.3. Collection and use of users' personal information during presentation and presentation media playback

Data Processing Activities Data type Legal Basis for Processing
When Donner provides users with viewing and reading services audio and video when promoting music and musical instrument lessons device model, device name, unique device identifier, type and browser settings, language settings, operating system and application version, connection IP address, network access method, network quality data, network information mobile network, product version number, and network log information (such as operations and service log) When you have given your consent


2.2.4. Collection and use of users' personal information in the service process operational

Data Processing Activities Data type Legal Basis for Processing
When a user initiates a complaint, claim or consultation with of Donner's customer service platform, the user's identity must be verified Account information, name, mobile number, email address and other contact information, communication information between the user and the platform customer service (including text/picture/audio/video/call recordings) and other information necessary linked to user needs When you have given your consent


2.2.5. Collection and use of users' personal information in the photo sharing process, texts and videos

Data Processing Activities Data type Legal Basis for Processing
When a user uses the commenting, sharing and sharing functions publication The above-mentioned text, image and video information provided voluntarily by the user, the photo album of the user's mobile phone with the user permission for easy sharing of videos and photos When you have given your consent


2.2.6. Collection and use of users' personal information when uploading videos and screenshot 

Data Processing Activities Data type Legal Basis for Processing
When a user logs into Donner products with mobile devices and uses the functions of uploading videos and screenshots Obtain storage permission from user's device  When you have given your consent


2.2.7. Collection and use of users' personal information when purchasing

Data Processing Activities Data type Legal Basis for Processing
When the user purchases goods or services in the products and Donner services, to help the user complete the transaction, guarantee the security of the user transaction, view order information, provide customer service, etc. Information about the goods or services in the transaction, information from recipient (recipient name), delivery address, billing address and contact number and zip code, transaction amount, order time, order number, order status, payment method, payment serial number, payment status  Performance of a contract with you

 After the user successfully places an order, if the product needs to be delivered by a third party, in order to complete the delivery and handover of goods to the user in a smooth, safe and accurate manner, the company third-party delivery company will inevitably obtain the relevant delivery information (personal information) of the user. The company promises users that it will do its best to protect the security of personal information of users and will strictly require third-party delivery companies to keep confidential user personal information.

2.2.8. Using the Tuner Feature to Collect and Use Personal Information users 

Data Processing Activities Data type Legal Basis for Processing
When a user uses the tuner function service, to analyze the sound played by the user by collecting the above information from the user, and offers a feedback on the accuracy of the sound played by the user Obtain permission to access the device's recording user (microphone), user voice information, and interaction information voice (personal information) When you have given your consent


2.2.9. Collection and use of personal information when you contact us voluntarily

Data Processing Activities Data type Legal Basis for Processing
When a user voluntarily contacts us via our "Need" function help" or by subscribing to our email User name and email address  When you have given your consent


2.2.10. Collection and use of personal information to conduct marketing, advertising or promotional


Data Processing Activities Data type Legal Basis for Processing
When a user uses the marketing and advertising services Personal information provided above  When you have given your consent

The foregoing relates to personal information collected and used by Donner. The Donner account can be directly connect to the Donner app and the Donner app account can also connect to the Donner website to access and use it.  

2.3. Collection and use of personal information when you use our mobile application

Data Processing Activities Data type  Legal Basis for Processing
When a user creates a service account user email address and account password When you have given your consent
When a user voluntarily adds an additional profile user name, gender, date of birth, nationality and what lessons instrument do you want to learn When you have given your consent
When you complete our survey for new registrants voluntary genre, if you own a Donner instrument, your favorite musical genre When you have given your consent
When using the classroom feature learning status, such as your learning progress and content of the courses to recommend courses, relevant knowledge and tips to you Necessary for our legitimate interests: supporting customers and others requests, operate our business
When using the community feature storage authorization, recording authorization, camera, dynamic publishing and dynamic interaction Necessary for our legitimate interests: supporting customers and others requests, operate our business


2.4. User information from third parties that Donner may collect indirectly.

(1) Users understand and know that the company will not be able to obtain the personal information provided to or collected by external third parties, nor will it use unconventional methods to obtain personal information without permission. If it is really necessary to collect information personal information indirectly from a third party due to commercial development needs, and that the company directly or jointly provides products or services to users, the company (or a third party) clearly indicate the source, type, purpose and method of use of the personal information shared functions, business functions and the scope of authorization and consent prior to collection. When some of the Company's products or services are provided or jointly provided by business partners third parties, in order to reasonably and necessarily carry out the activity, the company may indirectly collect information from certain business partners and user information provided by other parties when using the Company's products and/or services.

(2) The professional security team will strengthen the security of personal information (including the classification of sensitive information, encrypted storage of sensitive information, access control, etc.) and will protect personal information acquired indirectly by means and safeguards that do not are no less strict than those for the personal information of their own users.

2.5. Third-party SDK that Donner could use

Company may use the following third-party SDK services to provide personalized recommendations, third-party account connection service and product improvement. Service providers can collect information about your device and your internet activities. We suggest you read their privacy policies to learn more about their practices.

Third-party SDK service provider Link to privacy policy
byteplus https://urldefense.com/v3/__https://docs.byteplus.com/legal/docs/privacy-policy__;!!Nt8HgU3UPWRNOg!7NaBtNkq77in5vxCxy_12aUCb07_8VK55kbF-D7LTP-z1FOfpt9L3Arz8oGfxB9v6w$
AWS https://aws.amazon.com/privacy/
Firebase https://policies.google.com/privacy


2.6. Other lawful, reasonable and necessary collections and uses of personal information users

Please understand that subject to applicable laws and regulations, Company may collect and use personal information of users without the authorization and consent of users if the information is:

Data processing activities Data type  Legal basis for processing
To demonstrate compliance with regulatory requirements User information Necessary to comply with a legal obligation


2.7. Changes in the purpose of collecting and using personal information

Please understand that with the development of the business, the functions and services provided by Donner can be adjusted and modified. When the new function or new service is linked to the functions or services currently provided, the personal information collected and used will be directly or reasonably related to the usage scenario mentioned above. In the scenario which is not directly or reasonably related to the purpose of the usage scenario mentioned above, the company will again inform the users before collecting and using their personal information and will obtain their authorization and consent.

3. Use of cookies and similar technologies

3.1. When using Donner's products and services, the company may use cookies and similar technologies to collect certain personal information from users, including but not limited to limit, the visiting habits of the websites by the users, the information on the navigation and the user connection. For more information about the cookies we use and your choices regarding cookies, please see our Cookies Policy.

4. Storage and protection of users' personal information

4.1. Information storage

4.1.1. Storage location: In accordance with laws and regulations, personal information collected from of users will only be stored in the territory of China. Regarding personal data originating from the EEA, we comply with applicable legal requirements by providing adequate guarantees for the transfer of personal data to countries outside the EEA. Before each transmission, we analyze the transmission scenarios and the risks they may pose before deciding to transmit them. We are using standard contractual clauses as a legal mechanism to implement the cross-border transfer of your personal data ; or we implement security measures such as anonymization of data before cross-border data transfer.

4.1.2. Storage duration: We only retain users' personal information for the period necessary for the provision of Donner and related services. During the period when users do not withdraw do not, delete or cancel their accounts, the company will retain the relevant information. After removal and deletion of information, comments and related information published by the users, as well as the cancellation of the account number, the company will still retain the information above for information compliance audit purposes, but the company will retain it after having anonymized to ensure the security of relevant information.

4.2. Information Protection

4.2.1. The security of users' personal information is very important to the company. The company will strictly adhere to relevant laws and regulations and strive to take safety measures reasonable measures (including technical and managerial measures) to protect personal information from users against unauthorized access, disclosure, use and modification, and to avoid damage or loss of information.

4.2.2. The company protects the personal information provided by users with safeguards Security protection meets industry standards and prevents unauthorized access, disclosure public, use and modification of data, as well as damage or loss of data. The company will take all reasonable and practicable measures to protect personal information from users.

4.2.3. In order to avoid the occurrence of incidents, the company has set up a department specializing in the security of data and developed an appropriate early warning mechanism and contingency plan. In the event of a security incident personal information, the company will promptly inform users of the basic situation and the impact possible of the incident, measures taken or to be taken by the company, suggestions that users can follow to independently prevent and reduce risks and corrective actions to take for users, and will immediately start the emergency plan to minimize losses. The company will inform users of relevant events in a timely manner by means of push notification.

4.2.4. Although the company has taken the reasonable and effective measures mentioned above and complied with the standards required by relevant laws and regulations, please understand that due to limitations techniques and possible malicious intentions, in the Internet industry, even if we do our best to strengthen security measures, it is impossible to guarantee 100% security at all times informations. However, the company will do its best to ensure the security of personal information provided by users.

4.2.5. Users are aware and understand that the communication systems and networks used to accessing the Donner Services may experience problems due to factors beyond our control. control. Therefore, the company strongly recommends users to take active steps to protect the security of their personal information, including by using complex passwords, regularly changing passwords and not disclosing their account passwords and information personal related to other people.

4.2.6. Once the user leaves Donner and related services and browses or uses other websites, services and content resources, the Company has neither the ability nor the obligation to protect the information personal information submitted by the user in mobile applications and websites other than Donner and the related services, regardless of whether connecting, browsing or using other applications mobile or website is based on the link or orientation of Donner.

5. Sharing, transfer and public disclosure of users' personal information

5.1. Except to share users' personal information so that they can use our services, or where required or permitted by laws and regulations, the company will not share information personal information of users with unaffiliated third parties. The company may disclose personal information users in the following circumstances:

(1) Within the company organization. Donner is part of the company organization, which includes numerous legal entities, business processes, management structures and technical systems. Give can share users' personal information within the organization in order to provide services to users and meet user requirements.

(2) The Company may share Users' personal information with third party service providers acting on Company's behalf to assist the Company in operating the Mobile Phone Software and Website Service. The third party may only use Users' personal information in accordance with the Company's written materials and must comply with the information security protection measures implemented by the Company. For more information, please see THIRD PARTY SERVICE PROVIDERS LIST.

(3) Circumstances where the business is attempting to be legal and compliant. The company has the right to disclose the personal information of users in accordance with applicable laws and regulations, or when the company believes that the disclosure of users' personal information is necessary to protect the company's legal rights, comply with legal proceedings, court orders, requirements of regulatory authorities, or required by any other legal process. In the event of transfer, sale or business purchase by the transferee, the business may disclose users' personal information to the future owner of the company.

5.2.In order to provide more perfect and better quality products and services to users, the company entrusts some of its services to authorized partners. The company may share certain information users with partners to provide better customer service and user experience. The company will only share users' personal information for the purposes legitimate, appropriate, necessary, specific and explicit, and will only share personal information necessary for the provision of services. At the same time, the company will enter into a strict confidentiality agreement with its partners, requiring them to process users' personal information in accordance with the company instructions, this privacy policy and all other privacy measures and relevant security. Company partners do not have the right to use the information personal data shared for other purposes. If the user refuses the company's partners to collect the personal information necessary for the provision of the service when providing the service, the user may not be able to use the third-party service on the company's platform.

5.3.With the user's consent, the company may disclose the user's personal information for specific purposes.

5.4.The company will not transfer users' personal information to any company, organization or individual unless you obtain explicit consent from users. In the event of a merger, acquisition or liquidation in bankruptcy, a transfer of personal information may be involved. In this case, the company will ask new companies and organizations holding users' personal information to continue to be bound by this privacy policy. If changes occur in the methods of collection and processing of personal information stipulated in this privacy policy, these Companies and organizations will again ask for permission and consent from users.

6. Users’ Rights to Personal Information

The Company understands users' concerns regarding personal information and is doing its utmost to better to guarantee the rights of access, rectification, deletion and withdrawal of authorization of users regarding their personal information, so that users have the ability to sufficient to protect their privacy and security. User rights include:

6.1.The right to access personal information

Users can view relevant personal information provided to the Company in accordance with the specifications (or parameters) of the products and services provided by the company, including:

6.1.1.Account Information: Users can log in to their Personal Center at any time via the relevant product pages to access their personal account information;

6.1.2.Usage information: Users can view their usage information at any time via relevant product pages;

6.1.3.Other information: If users need to obtain other personal information that does not may not be known during the visit, they can contact the company through the method provided in this Policy.

6.2.The right to correct/modify users' personal information

If users find that the personal information they provided to the company is incorrect, incomplete or obsolete, they may correct and modify this personal information.

6.3.The right to delete users' personal information

For some users' personal information, users can also actively delete the information they provided through the function pages of related products and services provided by the company. Once users delete the information, the company will delete or anonymize the information, unless otherwise required by laws and regulations.

6.4.The right to withdraw users' authorization for personal information

Certain functions of the products and services provided by Donner require authorization of the equipment of the users (including: location, camera, microphone, calendar, etc., depending on functions actually obtained by the products). Users can remove (or stop) the continued authorization of the permission at any time after authorization. Users can also permanently remove any permission to collect personal information by canceling their accounts. Users must understand that after withdrawing their authorization, the company will no longer be able to provide them with functions and services corresponding specifics. However, users' decision to withdraw permission will not affect the prior processing of personal information based on user authorization.

Opting out of email marketing

You can unsubscribe from our marketing mailing list at any time by clicking on the link unsubscribe in emails we send or by contacting us using the contact details provided below. You will then be removed from the marketing mailing list - however, we will still need to send service-related emails that are necessary for the administration and use of your account.

6.5.The right to terminate user accounts on Donner

Users may request termination of their account by following the instructions provided by the customer service platform. After terminating their account, users will no longer be able to log in and use Donner products and services with this account. The content, information, data and Records in this account will be deleted or anonymized (unless otherwise required by law and regulations). After account termination, all account data will not be restored. Please think carefully before canceling your account. Once the account is terminated with Donner, it cannot be restored.

If users have any questions when terminating their accounts, please contact the company via the contact details in article 9 “Contact Us” of this policy.

7.Provisions concerning Minors

The Company's consumer websites and mobile services are not intended for children under 13 years of age and do not knowingly collect personal information from children under 13 years of age. Please contact us if you have any concerns about the potential collection of your child's information.

8.Revision and Notification of this Policy

8.1.In the event of the following changes, the company will modify this Policy in due course:

(1) The basic situation of the enterprise has changed, such as change of ownership caused by merger, acquisition and reorganization;

(2) Changes in the scope, purpose and rules of collection and use of personal information;

(3) Changes in the subject matter, scope and purpose of providing personal information to the outside world;

(4) Changes in how users access and manage personal information;

(5) Changes in data security capabilities and information risks;

(6) Other changes that could have a significant impact on the rights and interests of users in matter of personal information.

8.2.The Company may revise the relevant provisions of this Policy from time to time (including the Privacy Policy). confidentiality of Donner). In the event of changes to the content of the clauses, the company will display the revised content on the relevant pages or will send notice of changes to the agreement to users. This guy notice will be decided by the company and sent in particular by mail, telephone, text message, mobile terminal, web page or any other legal means.

8.3.The content of the revised agreement will form an integral part of this Policy, and users must also comply with it. If the User does not agree with the revised Agreement, please immediately cease your connect and use Donner and related services. If the user logs in or continues to use Give and related services, it will be deemed to have read, understood and accepted in full the updated Policy and to be willing to be bound by the updated Policy.

9.Contact us

If users have any questions about how we process your personal data, please read this Privacy Policy first. For additional questions, please visit the customer service platform ( Contact Us ) . Please note that we take your satisfaction very seriously. If you have a complaint, please also direct it to the same channel and we will respond to you as soon as possible.

You can of course also file a complaint with the Data Protection Authority via this LINK when you have a complaint regarding the Company's use or processing of your personal data. For example, if you believe that we are not using your personal data carefully, or because you have sent us a request to access or rectify your personal data and you are not satisfied with our response or we did not respond within the deadline.