狼友阁

Collection of Personal Information

We and our third party service providers collect Personal Information in a variety of ways, including:

• Through the Services

  • We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, or make a purchase.

• Offline

  • We collect Personal Information from you offline, e.g., when you visit our campus or other facilities, attend one of our seminars, place a request over the phone, or contact 狼友阁.

• From Other Sources

  • We may receive your Personal Information from other sources, for example:

    1. 1. publically available databases

    2. 2. joint marketing partners or other partners, when they share the information with us;

  • If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.

Use of Personal Information

We and our third party service providers use Personal Information for legitimate business purposes including:

• Providing the functionality of the Services and fulfilling your requests.

  • To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related services or communications. If you do not provide the information requested, we may not be able to provide the Services’ functionality.

  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request other information.

  • To complete your transactions, and provide you with related services or communications.

  • To send administrative information to you, such as changes to our offerings, terms, conditions and policies.

  • To allow you to send messages to another person if you choose to do so.

  We will engage in these activities to manage our relationship with you and/or to comply with any legal obligation.

• Providing you with our newsletter and/or other promotional materials and facilitating social sharing

  • To send you promotional related emails, with information about our services, offerings, new initiatives and other news about our organization.

  • To facilitate social sharing functionality that you choose to use.

  We will engage in this activity with your consent or where we have a legitimate interest.

• Analysis of Personal Information for business reporting and providing personalized services.

  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.

  • To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

  We will provide personalized services either with your consent or because we have a legitimate interest.

• Aggregating and/or anonymizing Personal Information.

  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

• For our business and operational purposes.

  • For data analysis, for example, to improve the efficiency of our Services;

  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;

  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

  • For developing new offerings, initiatives and services;

  • For enhancing, improving, or modifying our current offerings, initiatives and services;

  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;

  • For determining the effectiveness of our promotional and informational campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

  • For operating and expanding our business activities, offerings, and services, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;

  We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

Disclosure of Personal Information

We may disclose Personal Information:

• To our affiliates, owned or controlled by 狼友阁, including but not limited to affiliates in the United Kingdom and Hong Kong, for the purposes described in this Privacy Policy.

• To our third party services providers to facilitate services they provide to us.

  • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, event registration, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

• To third parties to permit them to send you promotional communications, consistent with your choices.

• By using the Services, you may elect to disclose Personal Information

  • On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

  • Through your social sharing activity. When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.

  • This can include laws outside your country of residence.

• To cooperate with public and government authorities.

  • To respond to a request or to provide information that we, in our sole discretion, believe is important or is necessary to protect our interests. These can include authorities outside your country of residence.

• To cooperate with law enforcement.

  • For example, when we respond to law enforcement requests and orders or provide information that we, in our sole discretion, believe is important.

• For other legal reasons.

  • To enforce any terms and conditions; and

  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

• In connection with a sale or business transaction.

  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings

Collection of Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device:

  • Certain information is collected by most browsers or automatically through your device. We use this information to ensure that the Services function properly.

• Through your use of the App

  • When you download and use the App, we and our third party service providers may track and collect App usage data.

• Using cookies

  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our third party service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our programs, initiatives, offerings and services are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

• Using technology to track use of services and improve the services

  • Pixel tags.Pixel Tags (also known as web beacons or clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

  • Analytics.In some instances, we may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/?partners/,and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

  • Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies. We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services.

• IP Address

  • Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

• Physical Location

  • We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, with our promotional partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our promotional partners may not be able to provide you with the applicable personalized services and content.

Additional Information

In accordance with applicable law, you may lodge a complaint with the relevant privacy or data protection regulatory authority.

LAST UPDATED: May 24, 2020