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Privacy Policy

January 1, 2019

Shanghai Yutu Network Technology Co., Ltd.-Tumon (brown-mails.com) (hereinafter referred to as "we") understands the importance of personal information to you, and will make every effort to protect your personal information. 保护您的个人信息:权责一致原则、目的明确原则、选择同意原则、最少够用原则、确保安全原则、主体参与原则、公开透明原则等。 We are committed to maintaining your trust in us and abiding by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of least enough, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. . At the same time, we promise that we will take appropriate security measures to protect your personal information in accordance with the industry's mature security standards.
Please read and understand this Privacy Policy carefully before using our products (or services).

How we collect and use your personal information

Personal information refers to all kinds of information recorded electronically or otherwise that can identify the identity of a specific natural person or reflect the activity of a specific natural person, either alone or in combination with other information.
We only collect and use your personal information for the following purposes described in this policy:

(I) Provide you with online learning and online photo editing services

1. Business Function 1: Register as a User

。 In order to complete the account creation, you need to provide the following information: your name, email address, username and password created , mobile phone number used for authentication ...

If you are a business user, you need to provide additional company information to confirm the identity of the company user.

During the registration process, if you provide the following additional information, it will help us provide you with a better service and experience: job titles, education, ... However, if you do not provide this information, it will not affect the basic functions of using this service.
The above information you provide will continue to authorize us to use it during your use of this service. When you cancel your account, we will stop using and delete the above information.
The above information will be stored in the People's Republic of China. If cross-border transmission is required, we will separately obtain your authorization.

2. Business function two: product display, personalized recommendation, and sending promotional marketing information.


(2) Carry out internal data analysis and research, third-party SDK statistical services, and improve our products or services [Note: Examples]

The data we collect is based on your interactions with us and your choices, including your privacy settings and the products and features you use. The data we collect may include SDK / API / JS code versions, browsers, Internet service providers, IP addresses, platforms, timestamps, application identifiers, application versions, application distribution channels, independent device identifiers, iOS advertising identifiers Identifier (IDFA), Android advertiser identifier, network card (MAC) address, International Mobile Equipment Identity (IMEI), device model, terminal manufacturer, terminal device operating system version, session start / stop time, language location, time zone, and Network status (WiFi, etc.), hard drive, CPU and battery usage, etc.
When we use the information for other purposes not specified in this policy, we will ask your permission in advance.
When we use information collected for a specific purpose for other purposes, we will ask for your consent in advance.

How we use cookies and similar technologies

(A) Cookies

To ensure the website works properly, we store small data files called cookies on your computer or mobile device. Cookies usually contain an identifier, a site name, and some numbers and characters. Cookies enable websites to store data such as your preferences or the items in your shopping basket.
We do not use cookies for any purpose other than the purposes described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies stored on your computer, and most web browsers have a feature that blocks cookies. But if you do this, you will need to change your user settings yourself every time you visit our website. For more information on how to change your browser settings, please visit the following links:,,, and.

(2) Website beacons and pixel tags

In addition to cookies, we use other similar technologies such as web beacons and pixel tags on our websites. For example, an email we send to you may contain a click URL that links to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags in the email, we can know if the email was opened. If you do not want your activity to be tracked this way, you can unsubscribe from our mailing list at any time.

(3) Do Not Track

Many web browsers have a Do Not Track feature that can post Do Not Track requests to a website. At present, major Internet standards organizations have not yet established policies to regulate how websites should respond to such requests. But if your browser has Do Not Track enabled, all of our sites will respect your choice.

How we share, transfer, and publicly disclose your personal information

(1) Sharing

We do not share your personal information with any other company, organization, or individual, except in the following cases:
1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
2. We may share your personal information externally in accordance with laws and regulations, or in accordance with mandatory requirements of government authorities.
3. Sharing with our affiliates: Your personal information may be shared with our affiliates. We only share necessary personal information and are subject to the purposes stated in this privacy policy. If the affiliate wants to change the purpose of processing personal information, it will ask for your authorization again.
4. Sharing with authorized partners: For the purposes stated in this privacy policy, some of our services will be provided by authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. For example, companies we hire to provide third-party data statistics and analysis services may need to collect and access personal data for data statistics and analysis. In this case, these companies must comply with our data privacy and security requirements. We will only share your personal information for legitimate, proper, necessary, specific, and clear purposes, and we will only share the personal information necessary to provide the service.
For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this privacy policy and any other relevant confidentiality and security measures.

(2) Transfer

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
2. In the case of merger, acquisition or bankruptcy liquidation, if it involves the transfer of personal information, we will require new companies and organizations holding your personal information to continue to be bound by this privacy policy, otherwise we will require the company, organization Ask for your consent again.

(3) Public disclosure

We only disclose your personal information publicly if:
1. After obtaining your explicit consent;
2. Disclosure based on law: We may disclose your personal information publicly in the case of legal, legal procedures, litigation or mandatory requirements of the competent government authority.

How we protect your personal information

(1) We have used industry-standard security protection measures to protect the personal information you provide to prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We take all reasonable measures to protect your personal information. For example, when you exchange data (such as credit card information) between your browser and the Service, it is protected by SSL encryption; we also provide https secure browsing for our website; we will use encryption technology to ensure the confidentiality of data; we will Use trusted protection mechanisms to prevent data from being maliciously attacked; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will organize security and privacy protection training courses to strengthen the importance of employees in protecting the importance of personal information understanding.

(2) We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for as long as necessary to achieve the purposes stated in our cost policy, unless we need to extend the retention period or as permitted by law.

(3) The Internet is not an absolutely secure environment, and e-mail, instant messaging, and communication with our users are not encrypted. We strongly recommend that you do not send personal information in this way. Please use complex passwords to help us keep your account secure.

(4) The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legitimate rights and interests, we will assume corresponding legal responsibility.

(5) After the unfortunate occurrence of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or are about to take, and you can prevent and Suggestions to reduce risk, remedies for you, etc. We will promptly inform you about the event by email, letter, phone, push notification, etc. When it is difficult to notify the individual information subject one by one, we will take a reasonable and effective way to make an announcement.
At the same time, we will proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

V. Your rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you exercise the following rights over your personal information:

(1) Access to your personal information

You have the right to access your personal information, with the exception of laws and regulations. If you want to exercise data access, you can access it yourself by:
Account Information-If you wish to access or edit the profile and payment information in your account, change your password, add security information, or close your account, etc., you can perform such operations by contacting customer service QQ: 800175404.
。 If you are unable to access this personal information via the link above, you can contact us at any time by emailing kefu@brown-mails.com .
We will provide you with other personal information generated by you when using our products or services, as long as we do not need to invest too much. 。 If you want to exercise data access, please email kefu@brown-mails.com .

(2) Correct your personal information

When you find an error in the personal information we process about you, you have the right to ask us to make a correction. You can make a correction request through the methods listed in "(1) Access to Your Personal Information".
If you are unable to correct this personal information via the link above, you can always email us at kefu@brown-mails.com .

(3) Delete your personal information

You can ask us to delete personal information if:
1. If our handling of personal information violates laws and regulations;
2. If we collect and use your personal information without your consent;
3. If our handling of personal information violates our agreement with you;
4. If you no longer use our products or services, or you cancel your account;
5. If we no longer provide you with products or services.
If we decide to respond to your removal request, we will also notify the entities that have obtained your personal information from us and request that they be deleted in a timely manner, unless otherwise required by laws and regulations, or these entities have obtained your independent authorization. When you delete information from our services, we may not immediately delete the corresponding information from the system, but we delete it when the backup is updated.

(4) Change the scope of your authorization and consent

Each business function requires some basic personal information to be completed (see "Part 1" of this strategy). For the collection and use of additional collected personal information, you can give or withdraw your authorized consent at any time.
You can do it yourself by:
Visit http://brown-mails.com/imageeditor.html for modification When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously based on your authorization.

(V) Cancellation of account by personal information subject

You can cancel your previously registered account at any time, and you can do it yourself by:
Contact customer service, floating customer service button on the right side of the homepage, manual application

After canceling your account, we will stop providing you with products or services and delete your personal information according to your requirements, unless otherwise provided by laws and regulations.
Under the premise of technical feasibility, such as data interface matching, we can also directly transfer a copy of your personal information to your designated third party according to your requirements.

(6) Constrained Information System Automatic Decision

In some business functions, we may only make decisions based on non-manual automatic decision mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us to explain and we will also provide appropriate remedies.


(7) Respond to your above request

For security reasons, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
We will respond within thirty days. If you are not satisfied, you can also complain through the following channels:
Phone: 021-61097639
For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed a reasonable limit, we will charge a certain cost as appropriate. For those that are unreasonably repetitive, require excessive technical means (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes) The request may be rejected by us.
We will not be able to respond to your request in the following situations:
1. Related to national security and national defense security;
2. Related to public safety, public health, and major public interests;
3. Related to crime investigation, prosecution and trial;
4. There is sufficient evidence to show that you have subjective intent or abuse of rights;
5. Responding to your request will lead to serious damage to the legal rights and interests of you or other individuals and organizations.

How we handle personal information of minors

Our products, websites and services are primarily for adults. Minors must not create their own user accounts without the consent of their parents or guardians.
In the case of collecting personal information of a minor with parental consent, we will only use or publicly disclose this information if it is permitted by law, the parent or guardian's explicit consent, or necessary to protect the minor.
Although local laws and customs define minors differently, we consider anyone under the age of 18 to be a minor.
If we find that we have collected personal information from a minor without first obtaining verifiable parental consent, we will try to delete the data as soon as possible.

How your personal information is transferred globally

In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China.
Because we provide products or services through resources and servers around the world, this means that, with your authorized consent, your personal information may be transferred to foreign jurisdictions in the country where you use the product or service, or Received visits from these jurisdictions.
Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is adequately protected within the People's Republic of China. For example, we may ask for your consent to the transfer of personal information across borders, or to implement security measures such as data de-identification prior to cross-border data transfer.

How this privacy policy is updated

We may make adjustments or changes to this privacy policy in due course. Any updates to this privacy policy will be posted on our website in the form of the time of the update. Except for compulsory laws and regulations or regulatory requirements, adjustments or changes The contents of this website will take effect 7 days after being notified or announced. If you continue to use any of the services we provide or visit our related websites after the privacy policy is adjusted or changed, we believe that this means that you have fully read, understood and accepted the revised privacy policy and are bound by it.

How to contact us

If you have any questions, comments or suggestions regarding this privacy policy, please contact us via:
Phone: 021-61097639

We have set up a dedicated department for personal information protection (or a personal information protection commissioner), and you can contact them through the following methods: Tel: 021-61097639

Generally, we will reply within three working days.