Effective Date: April 15, 2025
This "Beibei English Privacy Policy" (hereinafter referred to as "this Privacy Policy") applies to your use of all terminal clients including the Beibei English website, Android application, and iOS application (hereinafter referred to as "our products" or "services"). This Privacy Policy describes how Beibei English (hereinafter referred to as "We", "Us", or "Our") collects, uses, shares, and protects your personal information. It will help you understand the following:
I. What Personal Information We Collect and How We Use It
II. How We Use Cookies and Similar Technologies
III. How We Share, Transfer, and Disclose Your Personal Information
IV. How We Protect Your Personal Information
V. Your Privacy Rights
VI. Children's Privacy
VII. Data Storage and International Transfers
VIII. Updates to This Privacy Policy
IX. How to Contact Us
Beibei English ("We" or "Us") understands the importance of your privacy. We are committed to protecting your personal information and maintaining your trust. We adhere to key privacy principles including lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability.
Please carefully read and understand this Privacy Policy before using our products or services. Important information about your privacy rights is highlighted in bold. By using our services, you acknowledge you have read and understood this policy.
For the purposes of this policy, "Personal Information" (or "Personal Data") means any information relating to an identified or identifiable natural person. This may include, but is not limited to: basic profile information (such as name, gender, address, region, phone number, email address); identity verification information (where required for certain features, such as copies of ID documents like passports, subject to strict necessity and security); network identifiers (such as system account details, IP address, passwords); internet activity information (login records, Browse history within our services); device information (hardware model, OS type, MAC address, installed application list [Android only, e.g., for security/compatibility checks], unique device identifiers like IMEI/Android ID/IDFA/Advertising ID/OAID); and location information (precise location if permission granted, or approximate location derived from IP address).
"Sensitive Personal Information" (or "Special Categories of Personal Data" under GDPR) refers to information that, if lost or misused, could result in harm or discrimination. This may include data revealing racial or ethnic origin, political opinions, religious beliefs, health data, genetic or biometric data, information about sex life or sexual orientation, precise geolocation data, or financial account information. **Potentially sensitive information processed under this policy might include: identity verification documents (if collected); account credentials; precise geolocation (if enabled); potentially, specific Browse history revealing sensitive characteristics.** We apply heightened security and obtain explicit consent where required by law before processing sensitive information.
(I) Account Registration and Login: When you register or log in, potentially using a mobile phone number, we collect information like your name (if provided), phone number, and verification data. We use this to create/manage your account, secure your login, enable cross-device syncing, and allow interactions (like commenting). Where phone numbers or similar identifiers are collected, they may be considered sensitive; we collect them based on service functionality and applicable legal requirements (e.g., performance of contract, legitimate interest in security). Refusing may limit account features, but anonymous Browse may still be possible. Please provide information thoughtfully.
(II) Browse and Viewing Content: When you use our services, we collect device identifiers and usage data for service personalization (e.g., remembering preferences), analytics (understanding usage patterns), and service stability.
(III) Search Function: We collect device identifiers, search terms, related Browse history, timestamps, and interactions to provide relevant results, suggest content, and improve our search features based on legitimate interests or performance of service.
(IV) Paid Product Purchases: For purchases, we collect necessary information like phone number, device identifier, and potentially payment information (processed securely by payment providers) to fulfill the transaction, verify identity, and manage your subscription/purchase record (performance of contract).
(V) Content Publishing: When you post comments or other content, we collect your identifier, potentially your phone number (for verification/account linking), and the content itself to associate it with your account, enable moderation, and comply with legal obligations regarding user content.
(VI) Feature Usage (Favorites, Follows): We collect identifiers to save your preferences like favorites or follows to your account or device, enabling you to access them later (performance of service).
(VII) Avatar Modification: If you modify your avatar, we request access to your photo library/camera and potentially file storage (read permission). We collect the photo you select. [Optional: We may collect device orientation data if essential for image processing.] This access is solely for enabling you to select, upload, and display your avatar.
(VIII) Personalized Content Recommendations: We analyze your interaction data (subscriptions, follows, views, clicks - "interaction records") to recommend content based on our legitimate interest in enhancing your experience. You can manage preferences or opt-out of personalized recommendations and associated push notifications via the [Settings] page.
(IX) Service Operation, Optimization, Security, and Advertising: To operate and improve our services, ensure security, provide customer support, and display advertising (see Section III), we collect technical data: device information (hardware details, OS, MAC address, identifiers, Android software list [e.g., for security/compatibility]), IP address, network details (method, type, quality, operator), software version, location (approximate from IP, or precise only with your explicit consent via device permissions – you can withdraw consent anytime), interaction records (Browse, clicks), and operational logs. This processing is based on performance of contract, legal obligations, and our legitimate interests in maintaining and improving our service.
A summary of key permissions potentially requested:
| Permission Area | Purpose of Use | Example Information/Permission Needed |
|---|---|---|
| Storage Access | Save downloaded content, updates, or user-selected files (e.g., avatar) | Read/Write External Storage Permission |
| Device Information | Optimize service for device, security, troubleshooting, analytics | Unique Device Identifier, OS Version, Model |
| Network Access | Connect to the internet for service functionality | Wi-Fi/Mobile Data Access Permission & Status |
| Camera/Photos | Allow user to upload photos (e.g., avatar) | Camera Permission, Photo Library Access Permission |
| Location | Provide location-based features or content (if applicable); ad relevance | Precise Location Permission (requires explicit consent) |
(X) Legal Bases for Processing (Without Consent where Law Allows): We generally process your personal information based on your consent, the necessity to perform a contract with you, our legitimate interests (provided they don't override your rights), or legal obligations. However, applicable law may permit processing without explicit consent under specific circumstances, such as:
1. To comply with a legal obligation (e.g., responding to lawful court orders or law enforcement requests).
2. To perform a contract with you or take steps at your request before entering a contract.
3. To protect the vital interests of you or another person (e.g., in an emergency).
4. For tasks carried out in the public interest or exercise of official authority (less common for private apps).
5. For our legitimate interests, such as maintaining service security, preventing fraud, analyzing usage for service improvement, unless overridden by your fundamental rights and freedoms.
6. Processing relates to personal data manifestly made public by you.
(I) Cookies: We use cookies (small data files stored on your device) to help our services function correctly, store your preferences (like language), and support features like login sessions or shopping carts (if applicable). We don't use them for unrelated purposes. You can manage cookies through your browser settings, but disabling them might impair some service functionality.
(II) Web Beacons and Pixel Tags: We may use similar technologies like web beacons (transparent images) or pixel tags in our services or emails to understand user engagement (e.g., if an email is opened, if a link is clicked) to improve our services and communications. You can usually avoid email tracking by not clicking links or disabling image loading in your email client, or by unsubscribing.
(III) Do Not Track: While there isn't a universal standard, we strive to respect "Do Not Track" signals from browsers where technically feasible.
(I) Sharing
We do not sell your personal information. We do not share your personal information with external companies, organizations, or individuals, except:
1. With Your Explicit Consent: Where you have given us clear permission to share.
2. For Legal Reasons: If required by applicable law, regulation, legal process (like a subpoena), or enforceable governmental request.
3. With Service Providers / Authorized Partners: We engage third-party companies or individuals as service providers to perform functions on our behalf (e.g., hosting, analytics, customer support, advertising). Currently, our primary advertising partner is Google AdMob. We provide them only the information necessary to perform their services and require them contractually to protect the data and not use it for other purposes.
Third-Party Service Information (Google AdMob):
Google AdMob (Advertising)
Service Provider: Google LLC
Purpose: To display advertisements within our app to help support our service.
Data Potentially Collected by Google: Device identifiers (Advertising ID - GAID/IDFA), IP address, device information, approximate location, ad interaction data. Google uses this data to serve personalized and non-personalized ads, measure performance, and combat fraud, acting as an independent controller. For more details, see Google's policies.
User Control & Consent: For users in regions like the EU/EEA/UK, we rely on your consent (obtained via a consent mechanism in the app where required) before Google collects data for personalized ads. You can manage ad personalization via your device settings ("Limit Ad Tracking" or "Opt out of Ads Personalization").
Google's Privacy Policy: https://policies.google.com/privacy and https://policies.google.com/technologies/partner-sites
We ensure sharing is secure and complies with data protection laws.
(II) Transfer
We will not transfer your personal information, except:
1. With Your Explicit Consent.
2. Business Transfers: In connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of the transaction. We will ensure the receiving entity respects this Privacy Policy or obtain your consent.
(III) Public Disclosure
We only publicly disclose personal information:
1. With Your Explicit Consent.
2. For Legal Reasons: Where required by law or valid legal process.
(IV) Sharing, Transfer, Disclosure Without Consent (Legal Bases): As outlined in Section I.X, processing (including sharing/transfer/disclosure) may occur without consent where permitted by law based on legal obligations, vital interests, performance of contract, legitimate interests, or related to publicly available data.
(I) Security Measures: We implement technical and organizational measures aligned with industry standards (e.g., SSL/TLS encryption, HTTPS, data encryption, firewalls, access controls, staff training) to safeguard your personal information against unauthorized access, disclosure, alteration, loss, or destruction.
(II) Data Minimization and Retention: We collect only necessary information and retain it only as long as needed for the purposes stated in this policy, or as required/permitted by law (e.g., for account maintenance, service provision, legal compliance, dispute resolution). We then securely delete or anonymize it.
(III) User Responsibility: Please use strong passwords and protect your account credentials. Be cautious about sharing information via unencrypted channels like email.
(IV) Security Limitations: While we take reasonable precautions, no system is impenetrable. In the event of a security breach impacting your data, we will take appropriate steps and notify you and regulators as required by law.
(V) Incident Notification: If a breach occurs, we will promptly inform you as required by law, outlining the nature of the breach, potential impact, measures taken, and mitigation steps you can take. Notifications may occur via email, in-app message, etc. We also report to regulatory authorities as required.
Depending on your location and applicable law (such as the GDPR in the EU/EEA/UK or the CCPA/CPRA in California), you have certain rights regarding your personal information. We are committed to enabling you to exercise these rights. You can often manage your data and preferences directly within the [Settings] or [Profile] section of our app, or by contacting us (see Section IX). Your rights may include:
Please contact us to exercise any applicable rights.
(VI) Responding to Requests: We will respond to your requests after verifying your identity and within the timeframe required by applicable law (e.g., typically within one month for GDPR requests, 45 days for CCPA requests, potentially extendable as permitted). Reasonable requests are generally free, but we may charge a fee or refuse requests that are unfounded, excessive, or restricted by law.
Exceptions: Please note that these rights are not absolute and may be subject to legal limitations (e.g., fulfilling legal obligations, protecting others' rights, ongoing investigations).
Our services are not primarily directed to children. We do not knowingly collect personal information from children under the age of 13 (or under 16 in the EU/UK, or the relevant minimum age in other jurisdictions) without verifiable parental consent. If you believe we have inadvertently collected information from a child below the relevant age threshold without consent, please contact us immediately so we can delete it.
(I) Data Storage: Your personal information may be stored and processed on servers located in various countries around the world, potentially including [Specify primary region(s), e.g., the United States, Europe, Singapore] where our facilities or service providers are located.
(II) International Transfers: If you are located in the European Economic Area (EEA), UK, or Switzerland, please note that we may transfer your personal information outside of these regions. When we do so, we ensure appropriate safeguards are in place to protect your data as required by applicable law, such as by using Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions, or relying on your explicit consent where appropriate. Please contact us if you require more information about the safeguards used for international transfers.
(III) Storage Period: We retain personal information only for as long as necessary to fulfill the purposes outlined in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements (See Section IV.II for more details).
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will post the updated policy here and indicate the "Effective Date" at the top. For significant changes, we will provide more prominent notice (e.g., via in-app notification or email) and may seek your affirmative consent if required by law, especially for changes that materially alter how we use your data or affect your rights. Your continued use of our services after the effective date constitutes acceptance of the revised policy, subject to any explicit consent requirements.
If you have questions, comments, suggestions about this Privacy Policy, or wish to exercise your privacy rights, please contact us:
Email: [email protected]
We will endeavor to respond to your inquiries and requests in a timely manner, typically within the timeframe mandated by applicable law (e.g., within one month for GDPR requests, 45 days for CCPA requests, subject to legally permitted extensions), after verifying your identity.