Privacy Agreement

Version No. 1.1

Effective Date: Aug 20 2025

Welcome to the MyBOSKER platform (Simplified Chinese name: 铂克 (Bo Ke), Traditional Chinese name: 鉑克, hereinafter referred to as the “Platform”). We highly value your privacy rights and are committed to protecting the security of your personal information and privacy in accordance with relevant laws and regulations.

This "Privacy Agreement" (hereinafter referred to as this “Agreement”) aims to explain how the platform collects, uses, stores, discloses, and safeguards the personal information you provide or generate while using the services on the platform. We deeply understand the importance of personal information to you and recognize that the proper handling of such information is our fundamental responsibility.

Before you use the services of this Platform, please read and understand all of the contents of this Agreement carefully. By starting to use this Platform, you agree to all the terms outlined in this Agreement and authorize the Platform to handle your personal information as stipulated herein.

To safeguard your right to be informed and control your information, we have specially agreed this Agreement with you to improve the transparency of our information processing and reflect our commitment to privacy protection. If you have any questions regarding this Agreement, feel free to contact us at any time.

I. Information Collection

1. While using the services of the Platform, we may collect and use the following personal information, which can directly or indirectly identify, associate, describe, or reasonably link with specific users or individuals:

2. How We Collect Information

We will only collect and use your personal information for the purposes specified in this Agreement.

You agree to allow us to collect and process your personal information within the scope of providing services to you, sending you service-related notifications, fulfilling our contractual obligations, exercising rights related to the services, and any other reasonable purposes as expressed by you when providing personal information.  

We may also collect information about internet usage, device details, software information, usage behavior, and other technical data to help us assess user scale and usage patterns, enhance service features, and identify how you use our services, allowing us to optimize your service experience and provide higher-quality, more personalized services.

If we intend to use your personal information for purposes other than those specified in this Agreement, we will notify you in a reasonable time frame through appropriate means (including but not limited to pop-up notifications, emails, or in-app messages) and seek your consent, while explaining the reasons and basis for the additional purposes.  

For sensitive personal information, we will only use it after obtaining your explicit consent; for other types of personal information, we will only use it when there is a legitimate basis, such as your authorization or the need to fulfill contractual obligations.

We may use your personal information to fulfill part of our contract with you or take actions before entering into a contract based on your request.

In certain circumstances, we may use your personal information for our own or third party legitimate interests, including preventing unauthorized access and modification of our systems, updating and enhancing our records, ensuring the confidentiality of commercially sensitive information for our operational reasons, conducting statistical analysis to assist us in managing our business, and carrying out external audits and quality checks.

In rare circumstances, we may need to use your personal information to fulfill our legal and regulatory obligations. This includes screening for financial and other sanctions or embargoes, complying with privacy, financial, and other regulations, conducting audits, or participating in inquiries or investigations by regulatory bodies. It also involves preventing unauthorized access to and modification of our systems, updating and enhancing our records, submitting statutory declarations, and undergoing external audits and quality inspections.

As our Platform continues to improve its products and services, we may introduce new features from time to time. These optimized features may involve an expansion or adjustment in the scope, purpose, and methods of collecting and using your personal information. Whenever such changes occur, we will update this Agreement and notify you through pop-up windows, in-platform announcements, emails, or other means. At that time, you will have the right to choose whether to consent to the relevant changes. If you do not consent, it may affect our ability to continue providing you with certain services or functionalities.

Specifically, we have collected and used the following types of personal information for the following reasons and in the following circumstances:

In addition to the personal information automatically collected by the system, you can also proactively provide your personal information to us through the following channels:

A. Account and Interaction Information When registering an account, using our services, or participating in interactions, you may submit information that includes identification details and user-generated content (such as personal information, posted content, and messages). Please note that content containing personal information that you publish through our services will be simultaneously shared with the Platform and the user community. We will retain necessary data in compliance with laws and regulations for the purposes of dispute resolution, customer support, and technical maintenance. We also reserve the right to take account control measures against users who violate our Terms of Service. It is vital to highlight that other users may re-store or disseminate the information you share through internal or external channels.

B. Customer Service Data When interacting with us through customer support, questionnaire surveys, online forms, Q&A section messages, or feedback submissions, the communication records, contact information, and other supplementary details you provide will be collected.

C. Transaction Records: When processing payments, we will obtain necessary transaction data such as user identifiers and transaction times.

D. Information Control Permissions: You can independently manage the sharing permissions for messages and audio-visual content through the service settings.

In addition, we may also obtain supplementary information through the following third-party channels:  

E. App Distribution Platforms: Services distributed through channels such as the Apple App Store, Google Play, and Chinese Android app stores may collect mobile device information after obtaining device system authorization. Note:

The Apple App Store may collect user activity data for analyzing interests and preferences.

Google Play may obtain device identification information for targeted advertising.  

Each platform can only collect specified information within the scope authorized by users.

F. Mobile Device Data: When using our services through mobile devices, app stores may transmit your username, device ID, and purchase records (excluding financial information) to us. Some mobile platforms may provide supplementary data such as push notification tokens after obtaining explicit authorization.  

II. Information Usage

We collect your information to provide you with safer, more efficient, and personalized services. Specific uses include but are not limited to the following aspects:

1. Account Registration and Identity Verification

We shall use your basic information (such as mobile phone number, email address, and verification materials) to complete account registration, identity verification, and login. This ensures the secure operation of our Platform, prevents fraudulent or malicious registrations, and combats bot accounts.  

2. Credential Display and Group Permission Management

With your authorization, we will use the information you actively submit, such as your educational background, school, and major, for the following purposes: displaying your educational and professional background on your personal page; providing other users with references to your professional background to enhance the quality of social matching; and controlling access permissions to certain groups that require identity or educational qualifications based on verification results.

3. Realization of Social and Interactive Features

We utilize your interests, background information, and behavioral records to support your interactions with other users through group chats, private messages, likes, comments, friend requests, etc.; analyze your interests and professional background to recommend groups, content, and friends that may interest you; make use of user behavioral information (such as active times and browsing preferences) to optimize the user experience and social recommendation algorithms; we also manage the text, voice, and video content you publish, conducting necessary content compliance processing (such as keyword filtering and risk content review).  

4.Implementation of Services and Compliance Management for the Educational Tutoring Module

   For Students: The university, major, and school email information you provide will be used to verify your student status, ensuring your eligibility to access the educational module and purchase courses. Based on your major, relevant course content (such as elective or skill-based courses related to your field) may be recommended.

   For Teachers: The personal information you submit, including full name, nationality, date of birth, and passport details, will be used to verify your identity and ensure that you are legally qualified to provide teaching services. Your resume, teaching information, and trial lecture video will be used to assess your teaching capabilities and for course presentation purposes (e.g., teacher profile pages) to assist students in course selection. Tax file numbers, mailing addresses, and other tax-related information will be used to fulfill cross-border tax reporting obligations. Bank account information will be used to process withdrawals of course earnings, ensuring compliant financial transactions.

5.Time Coordination for Course Booking

IP addresses collected during course bookings will be used to determine your geographic time zone. Class schedules will then be automatically adjusted and synchronized (for example, converting the teacher’s local time to the student’s local time) to prevent timing discrepancies caused by time zone differences and to ensure the seamless execution of teaching activities.

6. Personalized Content and Group Recommendations

Based on the personal information, interests, and browsing history we collect from you, we will recommend social circles, activities, or topics that may interest you. We recommend school-related groups, professional exchange communities, or users in the same field based on your educational background, verified schools, and majors. This enhances your sense of engagement, belonging, and interaction efficiency on our Platform.

7. For Data Analysis and Product Optimization

We may conduct statistical analysis of user behavior, preferences, and activity levels based on anonymized or de-identified information, which will be used for Platform product optimization, feature development, service improvements, marketing, and operational decision-making. All such analysis results will not contain identifiable information about you and will not affect your personal privacy rights.

8. For System Operations and Security Protection

We will collect device information, network status, and usage logs to diagnose system issues, prevent security risks, and guard against harmful activities such as spam, fraud, and account abuse.

9. For Customer Service and User Support

We will use your information to respond to your inquiries, complaints, and feedback; record and address the issues you report; and improve service quality. We will send you important notifications related to the service, such as function changes, system updates, account reminders, etc.  

10. For Compliance with Legal Requirements

In accordance with legal requirements, we will retain information related to network logs, authentication records, etc.; assist law enforcement or regulatory authorities in conducting investigations; implement principles such as data minimization and authorization minimization; and fulfill our legal obligations regarding your personal information.

III. Information Sharing and Disclosure

We take your information security very seriously and will not sell, rent, or provide your personal information to others in any illegal manner. Unless we have your explicit authorization or as permitted by laws and regulations, we may share or disclose your personal information within the minimum necessary scope under the following circumstances:  

1. With Your Explicit Authorization or Consent:

If you explicitly agree or actively authorize us, we will share the necessary information with the third party you designate based on your instructions.

2. Sharing with Third-Party Service Providers:

To achieve specific functions or services, we may share your personal information with the following third parties and ensure that they adhere to strict privacy protection obligations:

2.1 Necessary Sharing

To ensure the normal operation of the Platform’s functions, we may share necessary information with the following third-party service providers:

2.2 Function enhancement

To optimize the user experience, we may integrate the following third-party SDKS:

2.3 Privacy Protection Obligations of Third Parties

We only cooperate with third parties that have data security capabilities and compliance awareness and require all third parties receiving data to adhere to data protection standards equivalent to ours. They are not allowed to use the information for purposes unrelated to the original intent.  

2.4 User Control

You can manage third-party sharing in the following ways:

Deny SDK permissions: Disable permissions for specific SDKs (e.g., location, camera) in your device settings.

3. Sharing Required by Law or for Protecting Rights:

When laws and regulations require us to provide your personal information, or in order to protect the legitimate rights of the Platform, or in emergencies for public safety or to prevent fraud, we may share your personal information with relevant departments or organizations within the necessary scope, ensuring that the sharing complies with legal regulations and minimizing the scope of the disclosed information as much as possible.

IV. Information Processing and Storage

1. Storage Method: To enhance service availability and access speed, your personal information will be stored in data centers located in Singapore. We use secure and reliable technical methods and storage facilities to store your personal information on servers that are protected by stringent physical and network security measures, including firewalls, encryption technology, and access controls, to prevent unauthorized access, disclosure, alteration, or destruction.

2. Storage Period: Your personal information will be retained for as long as is necessary to achieve the purposes outlined in this Agreement. For example, as long as your account remains active, basic information and learning records related to your account will be continuously stored; for users with canceled accounts, we will retain necessary information for a certain period in accordance with legal regulations to handle any potential follow-up issues, and after this period, the information will be permanently deleted.

3. Technical Support and Processing: The system development, function maintenance, and security technical support for the MyBOSKER Platform are provided by our associated company, Shandong Bosker Network Technology Co., Ltd., located in mainland China. As the data processor, this company carries out data processing functions under the authorization and supervision of this Platform, ensuring that processing activities comply with legal and contractual agreements.

4. Cross-Border Data Transmission: Given the technical architecture and service characteristics of this Platform, your personal information may be transmitted to regions such as mainland China, Hong Kong, Singapore, and other countries during use. We will conduct cross-border data activities in compliance with applicable laws (such as the Personal Information Protection Law of the People's Republic of China, the Personal Data (Privacy) Ordinance of Hong Kong, the General Data Protection Regulation (GDPR) of the European Union, or the Privacy Act of Australia) and take necessary measures such as contractual safeguards, encryption of sensitive information, and access control to ensure the security and transparency of the information transmission process.

V. Information Protection

Safety guarantee measures: To comprehensively protect the security of your personal information, we have meticulously established a strict and multi-level technical and management guarantee system.

1. Technology level:

Encryption technology: During the data transmission stage, encryption protocols such as SSL/TLS are employed to coat the data transmission channel with a solid layer of armor, ensuring that even if the data is maliciously intercepted during its transfer from your device to the server of this Platform, the transmitted content remains in an unreadable ciphertext state, effectively preventing data theft. When storing data, the advanced AES-256 encryption algorithm is adopted to convert your personal information into complex ciphertext form and store it in the server. Only authorized systems and personnel holding specific decryption keys can restore it to the original data in compliance with security rules, thereby eliminating the risk of illegal tampering of the data during storage.

Network security equipment: It is critical to deploy high-performance firewalls to conduct real-time monitoring and filtering of all data traffic entering and leaving the network of this Platform, blocking external illegal network access and malicious attacks, such as common DDoS attacks, SQL injection attacks, etc. Simultaneously, in combination with the Intrusion Detection System (IDS) and the Intrusion Prevention System (IPS), it analyzes abnormal behaviors and attack characteristics in network traffic in real time. Once a potential threat is detected, it immediately triggers an alarm and takes corresponding defense measures, such as automatically blocking suspicious connections and adjusting network access policies, to safeguard the network security of this Platform.

2. Management:

Data security management system: Establish a complete data classification and grading management system. Based on the sensitivity and importance of personal information, divide it into different levels, and formulate differentiated access permission storage strategies and security protection measures for data of different levels; develop a strict data access approval process. Any employee who needs to access your personal information must submit a detailed access application in advance, stating the purpose, time and scope of access. Only after passing multiple rounds of approval can they perform access operations within the prescribed authority and time. The entire access process will be recorded in detail for subsequent auditing and traceability nhanced Protection for Sensitive Information Collected in the Educational Module

Sensitive information, such as teachers’ passport details, tax file numbers, and bank account information, as well as students’ school email addresses, is subject to reinforced protection measures:

   Such information is accessible only to strictly authorized personnel responsible for compliance review and financial settlement, with all access fully logged and traceable.

   Data is stored in isolated, encrypted partitions using stronger encryption algorithms (e.g., RSA-2048) than those applied to ordinary information, and undergoes regular security audits

   Tutors’ tax and bank account information is used solely for the platform’s tax reporting and earnings disbursement purposes. It will not be used for any other service scenarios. Upon termination of services, such information will be retained only for the legally required period and then securely deleted.

Emergency response to data leakage: Although we have taken numerous preventive measures, in the event of a data breach or similar security incident, we will immediately initiate our emergency response plan. Affected users will be promptly notified about the nature of the incident, its scope, potential risks, and the actions we are taking to address the issue. We will also report the incident to the relevant regulatory authorities and cooperate with investigations, aiming to minimize the impact and loss as much as possible.

Cross-border data security measures: To ensure data privacy during cross-border data transmission, we take measures in three stages. Before transmission, we classify and categorize the data based on sensitivity and apply different levels of protection for different classifications; we conduct comprehensive privacy impact assessments, considering the necessity of the transmission and potential risks; we carry out compliance reviews, adhering to the laws and industry standards of both the data source and destination countries; we rigorously assess the privacy protection capabilities of our partners and require them to provide relevant security certifications. During transmission, we encrypt the data using algorithms like AES and RSA, employ secure transmission protocols such as HTTPS and FTPS to ensure transmission security, strictly control access through multi-factor authentication, and anonymize or de-identify the data. After transmission, we ensure the security of data storage by using secure storage devices and systems, regular backups, and access controls with auditing mechanisms; we set up continuous monitoring and auditing systems to address anomalies in a timely manner.

VI. Your Rights

VII. Changes to the Agreement

1. Notification of Changes: We are at the liberty to make changes to this Agreement based on updates to laws and regulations, business development needs, or other reasonable grounds.

If changes are made to this Agreement, we will announce the specific content and effective date of the changes through prominent positions on the MyBOSKER Platform, such as pop-up windows on the homepage or in-platform notifications.

For significant changes, we will also ensure that you receive timely notification through SMS reminders sent to your registered mobile phone number or emails sent to your reserved email address.

2. Effective Date: The revised Agreement will officially take effect on the date indicated in the announcement. If you continue to use the MyBOSKER Platform services after the revised Agreement takes effect, it will be deemed that you have fully read, understood, and agreed to the content of the revised Agreement. If you do not agree to the content of the revised Agreement, you have the right to stop using the Platform's services.

3. User Responses To safeguard your legitimate rights and interests, before the changes to this Agreement take effect, you can consult with our customer service channels on the Platform at any time regarding any questions about the changes to this Agreement. We will arrange professionals to provide you with detailed answers. In case that you decide to stop using the Platform's services, we will handle your personal information properly in accordance with relevant laws, regulations, and the provisions of this Agreement, including but not limited to deleting or anonymizing it, to ensure the security of your personal information.

VIII. Dispute Resolution

1. Governing Law: Any disputes or claims arising from this this Agreement are governed by the laws of Hong Kong, without regard to its conflict of law principles.

2. Dispute Resolution: Any dispute, controversy, difference or claim arising out of or relating to this Agreement, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The law of this arbitration clause shall be Hong Kong law. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in Chinese.

IX. Other Terms

1. Any matters not covered in this Agreement may be supplemented by a separate agreement signed by both parties, which shall have the same legal effect as this Agreement. In case of any conflict between the supplementary agreement and this Agreement, the supplementary agreement shall prevail.

2. This Agreement shall take effect from the date you register your account or first use the services of this Platform and shall remain valid until you cease to use the services of this Platform.

3. Thank you for your trust in the MyBOSKER Platform. We will continue to strictly protect your privacy and provide you with high-quality services. For any questions, please feel free to contact our customer service.