Privacy Policy

「21 days speak」 respects your privacy and is committed to protect the personal information that you share with us. Generally, you can browse through our website without giving us any information about yourself (except for cookies and pixel tags, as provided in this privacy policy). When we do need your personal information to provide services that you request or when you choose to use our application, an AI tool built to help you achieve English fluency (the “App” or the “Services”), or provide us with your personal information, for example when you decide to contact us for additional information, this policy describes how we collect and use your personal information.

The entity responsible for the processing of your personal data is Hangzhou Xinglu Network Information Technology Co., Ltd referred to as 「21 days speak」, “our”, “we” or “us” in this privacy policy.

Depending on your interaction with us, we collect two types of data:

“Non-Personal Data” meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification. We collect Non-Personal Data during your interaction with us, such as your date and times of interaction, means of communications, whether you have engaged with emails we sent you, etc. This data is considered as Non-Personal Data when collected on an aggregate or statistical basis, or otherwise not combined with online identifiers.

Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, in order to maintain and develop our website, App and Services including among others, to help prevent frauds, etc.

“Personal information” means any information that may be used to identify an individual, including, but not limited to, a first and last name, email address, a home, postal or other physical address, other contact information, title, birth date, gender, occupation, industry, personal interests, and other information required in order to provide a product or service you requested.

We use the Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your personal information for the following purposes. One or more legal bases may apply simultaneously.

Information for providing you with Services

We may collect and store Personal Information such as name, address, email address, telephone number, gender, birth date, and other contact information in order to provide you with Services. We may also collect and store Personal Information regarding your usage of the App, for example, the information you provide during a lesson offered by the App, the transcript of the lessons, and your voice recording during the conversation.

The basis for our collection of data is the need to carry out the above processing of information, as part of the performance of existing engagements with you.

Information for Customer Support and Inquiries

We may collect and store Personal Information, such as name, address, email address, telephone number and contact information, when you submit inquiries or requests with respect to our App and Services. We will use such information to contact you only for the purposes for which you sent the inquiry.

The basis for collection of data is the need to carry out the above processing of information for performance of existing engagements with you and our legitimate interest to conduct an effective interaction with our users which are customers and/or potential customers.

Information for the maintenance and Improvement of our website, App, and Services

We may also use your Personal Information, such as personal information regarding your usage of the App, as web server logs, IP addresses, cookies, local storage tools, pixel tags, web beacons when you send us inquiries regarding our App, Services or when you browse the website, in order to administrate and improve the App, website, or our Services, for our internal records and for statistical analysis, as set forth in this Policy.

We also use data provided by you, including conversation data, to retrain and enhance the App’s algorithms.

The basis for collection of data is the need to carry out the above processing of information for our legitimate interest to conduct such improvements and analysis, as well as for the performance of our contract with you.

Information for Marketing and Promotional Purposes

In the event you sign up to receive our newsletter or other promotional materials, or where we are permitted to do so under applicable law, we will process your contact details, such as email address, for sending you news, notices, newsletters and updates regarding our Services. In line with the GDPR we will always give you the opportunity to opt in to our mailing list and without your explicit consent we will not add you to our mailing list to receive direct marketing or market research information Our lawful basis for the processing of this data is our legitimate interests, or, in certain cases your consent.

You may withdraw your consent at any time by clicking the “unsubscribe” link which will be included in the email we will send you. You may also contact us through the below means of contact and request to unsubscribe.

Cookies, pixels and web beacons

The website and the App may also collect cookies, pixels, web beacons and other similar information collected through application tracker and analytics tools.

We use such information to assist us in securing your use of the App and to enhance the performance of our website, App and Services. Cookies are small text files sent from the server to your device. Cookies used by us do not contain personal information nor do they contain account or password information. They merely allow the App and the website to recognize that a page request comes from someone who has already logged on.

We may share website and App usage information with reputable advertising companies for targeting our banner advertisements on our website, App and other websites and Apps. For this purpose, pixel tags (also called clear gifs or web beacons) may be used to note the pages you have visited. The information collected by the advertising company through the use of these pixel tags is not personally identifiable.

If you wish to block cookies, you may do so through your browser’s and application settings. You can delete cookies that are already on your computer or local storage, and you can set your browser to prevent them from being placed going forward. However, please bear in mind that disabling cookies or local storage may adversely affect your user experience of the Service.

Information sharing and disclosure

Your personal information may be shared with other 「21 days speak」 offices or subsidiaries around the world. All such entities are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements.

「21 days speak」 may share your personal information with other companies or people under any of the following circumstances:

1. When we have your consent to share the information;
2. We need to send the information to third parties who provide services to 「21 days speak」 (such as speech recognition or speech-to-text technology), or work on behalf of 「21 days speak」 to provide you with certain customer service (we will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose);
3. In the event of sale or transfer of all or substantially all of 「21 days speak」 or any 「21 days speak」 affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
4. Where needed for corporate audits or to investigate or respond to a complaint or security threat, to prevent illegal uses of our services, to defend ourselves against third party claims and assist in fraud prevention or investigation; or
5. We will also disclose your personal information if required to do so by law, or in urgent circumstances, to protect personal safety, the public or our business.

We will not sell or otherwise transfer the personally identifiable information you provide to us at our App or website to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner, when required by applicable law.

For the above purposes, personal information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision or other safe harbor mechanism by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information.

Data Retention

「21 days speak」 stores the personal information as long as it is necessary to fulfill the purpose for which the data has been collected. This means that 「21 days speak」 deletes your personal information when such information is no longer necessary, unless we have a legitimate interest to retain such data for longer periods or are required to do so by any applicable law. Statistics which have been anonymized may be saved thereafter.

Data security

「21 days speak」 safeguards the security of the data you send us with physical, electronic, and managerial procedures, taking into consideration the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing your personal information. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet.

Third party sites

Our App and Website may contain links to other apps and websites operated by other companies. 「21 days speak」 does not share your personal information with those apps and websites and is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies. Some of these third-party apps and sites may have permission to include the 「21 days speak」 logo, even though they are not operated or maintained by 「21 days speak」. Although we choose our business partners carefully, 「21 days speak」 is not responsible for the privacy practices of apps and websites operated by third parties that are linked to our website and App. Once you have left our website or App, you should check the applicable privacy policy of the third-party website or app to determine how they will handle any information they collect from you. We may provide services based on third party applications and content tools on 「21 days speak」’s website or App. These third parties may automatically receive certain types of information whenever you interact with us on our website or App using such third-party applications and tools, based on such third parties’ privacy statements.

Changes to this privacy policy

「21 days speak」 will amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on 「21 days speak」’s website.

Our website and mobile application may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies.

You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired services.

Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about how we handle user data and personal information, feel free to contact us.

Our contact information:

Contact email: support@5starland.com