Welcome to Hibay and its associated websites and software (hereinafter referred as Hibay). Hibay is managed by Silverdragon Tech PTE. LTD. Hibay deeply respects and protects the privacy of every user. Silverdragon Tech PTE. LTD places great importance on users' personal information and privacy protection. To provide you with more accurate personalized services and a safer internet environment, we establish relevant privacy policies in accordance with local laws, regulations, and technical specifications.
This policy applies to all products and services of Silverdragon Tech PTE. LTD (including but not limited to Hibay). This policy is intimately connected with the products or services you use from us. When you download, install, launch, browse, register, log in, use Hibay's products or services, we will process and protect your personal information according to the agreement in this policy. We will try to explain the technical terms involved in this policy in a simple and concise manner for your understanding.
When you use Hibay's products or services, Hibay may collect and use your related information. Therefore, through this "Privacy Policy", we hope to explain to you how Hibay obtains, uses, shares, stores, and manages this information. Please carefully read and fully understand this policy (especially the bold highlighted content) before using or continuing to use our various products and services, and make appropriate choices when necessary, according to the guidelines in this policy.
This "Privacy Policy" will help you understand the following content:
Chapter 1: How We Collect Your Personal Information Chapter 2: How We Use Your Personal Information Chapter 3: APP Application Permissions Involving Personal Privacy and Usage Explanation Chapter 4: How We Use Cookies and Similar Technologies Chapter 5: How We Share, Transfer, and Publicly Disclose Your Personal Information Chapter 6: How We Protect Your Personal Information Chapter 7: How We Store Your Personal Information Chapter 8: How to Manage, View or Delete Your Personal Information Chapter 9: Protection of Minors' Information Chapter 10: How the Policy Updates Chapter 11: Complaints and Suggestions Chapter 12: Others
Hibay may collect necessary information from you while providing services. The type of information we gather depends on the nature of the service and the functions of the service you are using. Please note that certain types of information are required for us to provide services to you. If you decide not to provide such information, or ask us to delete it, you may lose access to or be unable to use some of our services.
1.1.1 To use Hibay products or services, you first need to register an account and log in. You can choose to register an account and log in to Hibay products or services via your phone ("Account Login").
1.1.1.1 If you choose to log in through your mobile phone, you will need to provide us with your phone number. We collect this information for identity verification and recognition purposes. It also allows Hibay to associate your phone number with your Hibay account, allowing for data synchronization across different devices. If you refuse to provide your phone number, you will not be able to log in with your phone and sync your data through it. If you opt to log in using your Apple ID, you won't need to provide us with your phone number. However, after logging in, you may choose to additionally supply us with your phone number to complete your account details. Not doing so might affect the use of some Hibay products or services.
1.1.1.2 When you choose to log in to Hibay products or services through third-party accounts like Apple ID, you are agreeing to allow us to obtain information you have authorized to share from Apple and other third parties. Additionally, you agree to bind your third-party account to Hibay products or services, allowing you to directly access and use Hibay products or services and sync data across different devices. We will use the information you've shared in accordance with agreements with third parties and within the boundaries of corresponding laws and regulations. If you refuse to let Hibay obtain authorized shared information from third parties, you will not be able to register for a Hibay account or log in using your Apple ID. You'll also be unable to synchronize data using this third-party account.
1.1.2 When you participate in our questionnaires, fill out forms, or communicate with us in other ways, you accept that we will collect the information you voluntarily provide.
When you use Hibay products or services, we will collect relevant device information to provide you continuous and stable service support (like real-time data syncing). This collection also aids Hibay to continually improve its own products or services, giving you an optimal experience in using them. The collected information includes device name, model, serial number, operating system, application version and type, language setting, resolution, mobile terminal random access memory, login IP address, connection method, network quality data, mobile network information (including operator's name), and logging information (like operation and service logs).
1.3.1 To enhance the experience and convenience of Hibay products or services, Hibay may collect personal information by requesting device permissions. If you do not agree to provide this information, you may not be able to use features related to improving user experience, and may have to manually repeat certain information while using Hibay products or services.
1.3.2 If you wish to upload your recorded material to Hibay, you can choose to authorize Hibay to access your device's microphone.
1.3.3 If you hope to realize or experience the aforementioned functions, you may need to grant Hibay corresponding access permissions on your device. You can also choose to turn off these access permissions at any time to revoke the authorization. The ways permissions are displayed and turned off may vary across different devices. Detailed instructions can be found in the guidelines provided by the device or system developers.
1.3.4 To better optimize product design through statistical data analysis, Hibay promises to anonymize and de-identify your birthday, gender, region, personal introduction, recordings in Hibay before conducting statistical analysis.
1.3.8 To recommend suitable products or services to you and fulfill the agreement between both parties, Hibay will collect your personal internet records, including browsing history, usage history, click history, learning data generated while using Hibay products or services.
1.4.1 Personal information collected by third-party payment service providers You can obtain Hibay products or services and related products and virtual products — including membership services — by paying Hibay. The aforementioned payment services may be provided by third parties other than Hibay. Hibay will not collect password information related to your payment but may acquire your third-party payment account from you or the third-party payment platform (such as Apple account, Alipay account). If you want to understand specific rules about the collection of personal information by third-party service providers, please refer to the privacy policy of the third-party payment service provider you choose.
1.4.2 Third-party service providers accessed through Hibay products or services may have their own privacy policies, which are not subject to this "Privacy Policy." Service providers may collect personal information needed to provide you services as per their privacy policies. Hibay will strive to ensure that third-party service providers comply with relevant laws and regulations when handling your personal information and will try to require them to adopt relevant confidentiality and security measures. However, Hibay cannot guarantee that they will definitely adopt such measures as per our request.
1.5.1 It is related to Hibay fulfilling its obligations under laws and regulations;
1.5.2 It directly relates to national security or defence security;
1.5.3 It directly relates to public safety, public health, or major public interests;
1.5.4 It directly relates to crime investigation, prosecution, trial, and verdict execution;
1.5.5 To safeguard the life, property, or other major lawful rights and interests of you or another person, but it is difficult
to obtain consent;
1.5.6 The personal information collected is the personal data you have disclosed to the public;
1.5.7 It's necessary to sign and execute a contract based on your requirements;
1.5.8 The personal information is collected from legal public disclosures, such as legal news reports or government
information disclosure;
1.5.9 It is necessary for maintaining the stable operation of the products or services provided, e.g., discovering and disposing
of faults with products or services.
data recipient cannot restore and re-identify the personal information does not constitute external sharing, transfer,
or public disclosure of personal information. The storage and processing of such data will not require additional
notification or your consent.
After collecting your personal information, Hibay will utilize it according to the following rules:
2.1 We use the collected personal data as agreed in this Privacy Policy and for the functioning of Hibay's products or services.
2.2 Please note that all the personal information you provide while using Hibay's products or services, unless you delete it or refuse our collection through related settings, will be continuously authorized by you for our use during the product or service usage period and before your account cancellation. However, at the time you cancel your account, Hibay will stop using and delete your personal information.
2.3 Hibay will conduct statistics on the usage of its products or services and may share these statistics with the public or third parties to display the overall usage trends of Hibay's products or services. But these statistics will not contain any of your identifiable information.
2.4 When Hibay intends to use your personal information for purposes not specified in this policy, or to use the information collected for a specific purpose for other purposes, we will actively seek your explicit consent beforehand.
3.1.1 Reading and writing external storage
Permission explanation: cache learning data, download course cover images, etc. Declaration code of permission: WRITE_EXTERNAL_STORAGE，READ_EXTERNAL_STORAGE
3.1.2 Phone Access, Reading Device Information
Permission Explanation: This permission is only used to obtain IMEI code for user activity, retention data statistics, or to troubleshoot necessary network connection issues. Permission Declaration Code: READ_PHONE_STATE
3.1.3 Microphone
Permission Explanation: During usage, sound recording is utilized to facilitate spoken dialogues. Permission Declaration Code: RECORD_AUDIO
3.1.4 Device Information (OAID, MAC Address, IP Address, IMEI, IDFA, IDFV)
Permission Explanation: The above device information is read for user activity and retention data statistics.
You can refuse to supply the above mentioned information to us. However, without providing the requested information, some features of our service may not be accessible or usable.
To ensure the implementation of related functions and the secure, stable operation of the Hibay APP, Hibay may integrate development kits (SDKs) provided by third-party software for the intended purposes.
Hibay will strictly monitor the SDKs of our partners that collect information to ensure data security.
Hibay lists the relevant third-party SDKs integrated into our directory.
Please note that due to version upgrades and policy adjustments, third-party SDKs might modify their data processing types; please refer to their officially published guidelines for details.
Some third-party SDKs, for the sake of functionality, may continue to collect related data when the APP is in silent mode or running in the background. For detailed information, please refer to the section on third-party SDKs in the privacy policy.
3.2.1 Sensors Data SDK
Function: Data statistics and analysis Permissions: Read device identifiers, read MAC address, view network connection, view WLAN connection Collected data types: Device identity data (OAID, MAC address, IP address, IMEI, IDFA, IDFV), network status information Privacy policy link: https://www.sensorsdata.cn/market/privacy_policy.html
3.2.2 MicrosoftCognitiveServicesSpeech-iOS
Function: Convert text content to speech Collected data types: View network connections, network status information Privacy policy link: https://aka.ms/privacy
3.2.3 AmplifyPlugins/AWSS3StoragePlugin
Function: Speech upload Collected data types: View network connections, network status information, user-submitted audio information (with consent) Data collection method: To ensure data integrity, this SDK will upload user's voice data when the app is running in the foreground and triggered by the user. Privacy policy link: https://aws.amazon.com/cn/privacy/
3.2.4 Sentry
Function: Collect app error information and performance data for optimization to improve user experience Collected data types: View network connections, network status information, device identity data (Android ID, OAID, MAC address, IP address, IMEI, IDFA, IDFV) Data collection method: To ensure data integrity, this SDK will collect the above-mentioned data while the app is running in the foreground, in silent mode, or in the background. Privacy policy link: https://sentry.io/privacy/
3.2.5 WeChat Open Platform SDK
Function: Provide WeChat third-party login feature, assist users to share information to WeChat, etc. Permissions: Read and write external storage, read device identifiers, view network connection, view WLAN connection Collected data types: Device identity data (Android ID, OAID, MAC address, IP address, IMEI, IDFA, IDFV), network status information Privacy policy link: https://weixin.qq.com/cgi-bin/readtemplate?lang=zh_CN&t=weixin_agreement&s=privacy
3.2.6 Tencent Cloud Speech Recognition SDK
Function: Convert user's speech into text for analysis Collected data types: View network connections, network status information, user-submitted audio information (with consent) Data collection method: To ensure data integrity, this SDK will collect user's spoken pronunciation and convert it into text when the app is running in the foreground and triggered by the user. Privacy policy link: https://cloud.tencent.com/document/product/1093/87621
3.2.7 Google Sign-In for iOS
Function: Provide Google third-party login feature Collected data types: read device identifiers, view network connection, view WLAN connection Data collection method: Device identity data (Android ID, OAID, MAC address, IP address, IMEI, IDFA, IDFV), network status information Privacy policy link: https://policies.google.com/privacy
3.2.7 Facebook for iOS
Function: Data statistics and analysis Permissions: Read device identifiers view network connection, view WLAN connection Collected data types: Device identity data (OAID, MAC address, IP address, IMEI, IDFA, IDFV), network status information Privacy policy link: https://www.facebook.com/privacy/policy
4.1 To better provide you with our products or services, Hibay utilizes several automatic data collection tools, including Flash Cookies and Embedded Web Links. With these technologies, Hibay can track your learning progress in real-time and understand your preferences, thereby offering you a more premium, personalized user experience. Hibay will not use the above technologies for any purpose beyond those stated in this policy. Please understand that some services of Hibay can only be implemented by using the aforementioned technologies. If your device or relevant programs allow, you can disable or delete these technologies by altering settings or visiting the provider's webpage. However, this action may affect your use of Hibay products or services.
Sharing
5.1 Hibay will strictly adhere to relevant laws and regulations and keep your personal information confidential. We will not share your personal information with others except under the following circumstances: 5.1.1 With your explicit consent or authorization; 5.1.2 In compliance with a lawful request from your guardian; 5.1.3 In accordance with agreements signed with you (including electronically signed agreements and platform rules) or other legal documents; 5.1.4 As described in this Privacy Policy, Hibay may share your personal information with affiliated companies based on your corresponding authorization. However, Hibay will only share necessary personal information, bound by the objectives outlined in this Privacy Policy. If an affiliate intends to change the purpose of processing personal information, they will seek your explicit consent. 5.2 As for companies, organizations, and individuals with whom Hibay shares personal information, we will make reasonable efforts to ensure they abide by relevant laws and regulations when handling your personal information, and require them to adopt relevant confidentiality and security measures to safeguard your personal information.
Transfer
5.3 Hibay will not transfer your personal information to any company, organization, or individual except in the following circumstances: 5.3.1 With your explicit consent or authorization; 5.3.2 In accordance with agreements signed with you (including electronically signed agreements and platform rules) or other legal documents; 5.3.3 During significant changes such as mergers, acquisitions, bankruptcies, reorganizations, if personal information transfer is involved, Hibay will require the new entity possessing your personal information to continue fulfilling the responsibilities and obligations under this Privacy Policy. Should the transferee need to change the purpose of using personal information, we will require them to obtain your explicit consent beforehand.
Public Disclosure
5.4 Hibay will only publicly disclose your personal information under the following circumstances and with adequate industry-standard security measures in place: 5.4.1 At your request, we will disclose the personal information you specify in the way you explicitly agree to; 5.4.2 We may publicly disclose your personal information according to laws, regulations, mandatory requirements from administrative or judicial authorities. When Hibay receives such disclosure requests, we will require the requesting party to provide relevant legal documents, such as subpoenas or investigation assistance letters. Hibay will scrutinize each disclosure request to ensure compliance with related legal provisions. Within the extent permitted by laws and regulations, Hibay will use encryption protection for documents containing disclosed information. 5.5 You should be fully aware that under the following circumstances, Hibay can share, transfer, or publicly disclose your personal information without seeking your consent: 5.5.1 It's related to Hibay's obligation to comply with laws and regulations; 5.5.2 It's directly related to national security or defense security; 5.5.3 It's directly related to public safety, public health, and significant public interests; 5.5.4 It's directly related to criminal investigation, prosecution, trial, and execution of judgement; 5.5.5 When it’s necessary to protect the significant legal rights and interests of you or other individuals, but difficult to obtain your consent; 5.5.6 The personal information subject discloses it to the public; 5.5.7 Your personal information collected from legally public disclosed sources, such as legitimate news reports, government information disclosure channels.
6.1 Hibay highly values the security of personal information and will take all reasonably feasible measures to continuously protect your personal information against unauthorized access, alteration, or disclosure. 6.1.1 Hibay has adopted industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonably feasible measures to protect your personal information. For example, we use SSL encryption to protect data exchanges between your mobile device and Hibay's products or services; we use trusted protection mechanisms to safeguard data against malicious attacks. 6.1.2 Hibay only allows relevant personal information to be accessed by personnel who have a need to know, for which stringent access controls and monitoring mechanisms are established. Hibay requires all personnel who may come into contact with your personal information to fulfill their confidentiality obligations. Failing to fulfill these obligations might lead to legal liability or termination of their legal relationship with Hibay. 6.2 Hibay will take all reasonably feasible measures to ensure no irrelevant information is collected. 6.3 Please understand that due to technological limitations and various potential malicious methods, despite our utmost efforts to strengthen security measures, we can't always ensure 100% absolute security for your information. You should be aware that the systems and communication networks you use to access Hibay's products or services may experience problems due to factors beyond our control, under which circumstances we will lawfully do our best to help solve the problem. 6.4 In the unfortunate event of a security incident, we will inform you in accordance with legal and regulatory requirements: the basic situation and possible impact of the security event, the measures we have taken or will take, recommendations for you to prevent and mitigate risks on your own, etc. We will also promptly communicate the incident details via email, letters, calls, push notifications, or other appropriate ways; if it's challenging to notify subjects individually, we will issue a public announcement in a reasonable and effective way.
Retention Period
7.1 During the usage of Hibay products or services, Hibay will continuously retain users' personal information. 7.2 Hibay commits to storing your personal information only for the legally required or reasonable necessary period. Information like logs, records backup, etc., are stored for 60 days after you cancel your account (or the minimum period required by law if it applies), and transaction information is retained for three years from the date of transaction completion or 180 days after you cancel your account (whichever is longer). After these periods, we will delete or anonymize your relevant information. Location of Storage 7.3 Currently, there is no scenario where we provide personal information abroad.
Hibay highly respects the rights you have over your personal information. We guarantee your rights to access, rectify, delete, and manage your personal information.
Accessing and Amending Your Personal Information
8.1 Except where otherwise stipulated by laws and regulations, you have the right to exercise your access rights. When you find discrepancies in your personal information that we process or when you have any other amendments or supplementations, you also have the right to request us to correct them or to do so on your own. The ways in which you can exercise your access and correction rights include but are not limited to: 8.1.1 If you wish to access or amend your account information used in Hibay's products or services, you can do so through our products or services (you may edit, cancel, etc., by clicking on the account). 8.2 You have the right to know the identity or type of third parties who obtain your personal information through Hibay. You can gather insights about these third parties' identity or type via Chapter 1 and Chapter 4 of this policy.
Deleting Your Personal Information and Revoking Previously Approved Authorization
8.3 In the following circumstances, you can request Hibay to delete your personal information: 8.3.1 If Hibay's handling of personal information violates relevant laws and regulations; 8.3.2 If Hibay collects or uses your personal information without your consent; 8.3.3 If Hibay's processing of personal information breaches your agreement or the law; 8.3.4 If you no longer use Hibay's products or services, or if you have canceled your relevant account; 8.3.5 If Hibay no longer provides products or services to you. 8.4 You have the right to revoke your previous consent to Hibay for collecting and using your personal information. Once you revoke your consent, we will no longer process your relevant personal information. However, your decision to revoke your consent will not impact any personal information processing activities performed based on your previous authorization. 8.5 You may withdraw your specific consent for us by deleting the related personal information.
Account Cancellation
8.6 You have the right to cancel your account registered in Hibay products or services at any time. You can cancel your account in "Account - Cancel Account". 8.7 Please be aware that cancelling your account of Hibay related products or services is an irreversible operation. After cancellation, we will stop providing you with products or services and delete your personal information under this account unless otherwise stipulated by laws and regulations.
Restricting Automated Decision-making
8.8 In cases where Hibay makes decisions solely based on automated decision-making mechanisms, such as information systems and algorithms, and these decisions significantly impact your lawful rights and interests, you have the right to ask Hibay for an explanation, and Hibay will also provide appropriate remedies. Obtaining Personal Information Copies 8.9 Upon your request, Hibay can provide you with copies of your personal information held by Hibay (such as basic personal information). You can submit your request through customer service or the contact methods stated in Chapter 11 of this "Privacy Policy". Responding to Your Above Requests 8.10 If you have any questions about Hibay's mentioned methods for accessing, correcting, deleting your personal information, withdrawing consent, cancelling accounts, and restricting automated decision-making methods, you can contact us through customer service or the contact methods stated in Chapter 11 of this "Privacy Policy". 8.11 For your reasonable requests, Hibay will not charge fees in principle, but for repeated requests beyond a reasonable limit, Hibay may charge certain costs accordingly. For requests that are groundlessly repetitive, require too much technical means, pose risks to the lawful rights of others, or are very impractical, Hibay may refuse them. 8.12 We may not be able to respond to your request in the following situations: 8.12.1 Directly related to national security and defense security; 8.12.2 Directly related to public safety, public health, and significant public interests; 8.12.3 Directly related to criminal investigation, prosecution, trial, and judgment execution; 8.12.4 If there is evidence that you have malicious intent or abuse of rights; 8.12.5 Responding to your request would seriously harm the lawful rights of other individuals or organizations; 8.12.6 Involving trade secrets.
Complaint Mechanism
8.13 Hibay has established a complaint management mechanism, including tracking processes. To secure account and property safety, Hibay may verify relevant information with you. Hibay will reply to your feedback as soon as possible after receiving it, no later than 30 days. If you are not satisfied with the response, you can lodge a complaint again by contacting Hibay customer service.
9.1 Hibay attaches great importance to the protection of minors' information. If you are a minor under the age of 18, you should carefully read this "Privacy Policy" and use Hibay products or services under the guardianship, guidance, and consent of your guardian. 9.2 If you/your guardian disagrees with any content of this "Privacy Policy", you should immediately stop using our products or services. 9.3 If you are the guardian of a minor and have any questions about the minor's use of our products or services or the user information he/she provides to us, please contact us promptly. We will protect the confidentiality and security of minor users' information according to relevant laws and regulations and the provisions of this policy. If we find that we have collected personal information from minors without prior verifiable parental consent, we will attempt to delete the data as soon as possible.
10.1 If the following changes occur in Hibay products or services, Hibay will timely revise this "Privacy Policy": 10.1.1 The business functions involved in Hibay products or services change, leading to changes in the purpose, type, and usage of personal information processing; 10.1.2 Significant changes in your rights to participate in personal information processing and how to exercise them; 10.1.3 The contact methods for the department responsible for handling your personal information security at Hibay change; 10.1.4 Other changes that may affect users' personal information security or privacy rights occur. 10.2 After revising the "Privacy Policy", Hibay will publish the latest version on the related interface of Hibay products or services and notify users in a reasonable way such as pop-up windows and push notifications, so that users can understand the latest version of the "Privacy Policy" in time. 10.3 Without your explicit consent, Hibay will not reduce the rights you enjoy based on this "Privacy Policy". 10.4 Unless specifically stated otherwise, the revised "Privacy Policy" takes effect from the date of publication.
11.1 If you have any questions or suggestions about this Privacy Policy during your use of Hibay products or services, or if you believe that your personal information has not been protected as stipulated in this Privacy Policy, you may contact us in the following ways. We will sincerely address your complaints and suggestions within fifteen working days.
1. You can contact us through the in-app Help & Feedback - Submit Feedback, or via the email hello@mojohi.com
12.1 Any disputes arising from this Policy and our handling of your personal information could be resolved by appealing to a People’s Court with jurisdiction. 12.2 If you believe that our handling of personal information has infringed upon your legal rights and interests, you can also lodge a complaint with relevant government departments. 12.3 The publication of this Privacy Policy on Hibay or the provision of products or services to you signifies the effectiveness of this Privacy Policy. This Privacy Policy becomes invalid when Hibay ceases operation or permanently stops providing products or services.
Silverdragon Tech PTE. LTD