U-Dictionary Privacy Policy

Last Updated: 2020.09.23

Youdao (Hong Kong) Limited (“Youdao”, “we”, or “us”) has always solemnly promised to protect the privacy of users who use U-Dictionary (also “Youdao Service”) (collectively “user” or “you”). When you use Youdao Service, we will collect and use your personal data. The protection of your personal data is of great importance to Youdao within and outside Hong Kong as well as other jurisdictions including the European Economic Area. This privacy policy (the “Privacy Policy”) therefore intends to inform you about how Youdao, acting as data controller, collects and processes your personal data that you submit or disclose to us. We will also act as data processor when we process your personal data received or obtained through third-parties.

We encourage you to read this Privacy Policy carefully. If you do not wish your personal data to be used by us as set out in this Privacy Policy, please refer to V. How to Manage Your Information.

I. Personal Data that We may Collect

(I) Use of U-Dictionary through a Web Browser

We use Google Analytics on our web pages, and this in turn means that Google stores cookies on your computers and records IP addresses visited. To find out more about this, please refer to the Google Privacy Policy. You can prevent the recording of data about your use of the website by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout.

(II) Use of U-Dictionary through the mobile application

When you use the U-Dictionary App, we will collect and process information that may be directly or indirectly related to your personal identity. In both instances, such information may constitute personal data subject to this Privacy Policy.

1. Information not directly related to your personal identity:

When you use Youdao Service, we will collect and process information such as the user’s source route to monitor API calls made by applications and services that you use.

2. Information related to your personal identity:

We will collect and process information related to your personal identity. For example, when you use Youdao Service, we will collect and process your log information (including software usage records, click records, and operation logs). If you input any of the following information when you use our functions such as Camera, Grammar, Feedback etc. in U-Dictionary, we may also collect your personal information including ID number, date of birth, place of birth, gender, hobbies, personal phone number, facial features; online identification information including your email address; personal dealing records.

II. How will We Collect and Use Your Personal Information

(I) We will collect and obtain your personal information through the following ways:

1. Information provided by you. For example:

(1) information provided by you directly to us, when you 1) use functions including Camera, Conversation, Grammar Check, My Words in U-Dictionary; and 2) provide your feedback to us through U-Dictionary; 


(2) sharing information provided by you to other parties through Youdao Service, and information saved when you use Youdao Service.

2. Your information shared by other parties. information provided by you to third parties and shared by third parties to us with your consent when you log into U-Dictionary with your third-party account including Facebook and Google.3. Your information obtained by us. The information collected, summarized and recorded by us when you use Youdao Service, such as log information.

(II) We will collect and use your information for the following purposes:

1. provide services to you

The information we collect and use is necessary to provide you with Youdao Service. In case lack of relevant information, we will not be able to provide you with the core content of Youdao Service, such as:

(1) In relation to some service projects, in order to facilitate the delivery goods or services to you, you need to provide the consignee’s personal identification information, name, shipping address, postal code, consignee, contact telephone number, payment status and other information. If you refuse to provide such information, we will not be able to complete the relevant delivery service. If you order goods or services for others through Youdao Service, you need to provide the aforementioned information of the actual orderer. Before providing us with the aforementioned information of the actual orderer, you need to make sure that you have obtained their authorized consent.

(2) In order to display the order information of your account, we will collect the order information generated during your use of Youdao Service to show you and facilitate your order management;

(3) When you contact us, we may store information such as your communication/call history and conversation or the contact information you left behind in order to contact you or help you solve problems, or to document the solutions and results of the related issues.

(4) In order to confirm the transaction status and provide after-sales and dispute resolution services for you, we will collect your transactions, payment, and logistics information related to the progress of the transactions through your transaction objects, payment agents, and logistics companies selected based on such transactions, or we will share your transaction information with the above service providers. Your personal data is therefore processed for these purposes in order to provide you with and perform the services based on your engagement with us. This personal data may also be processed in order to safeguard your legitimate interests of obtaining pertinent information and other related data regarding your services and orders obtained from Youdao.

2. Push notifications to you

(1) Show and push products or services for you. We will send marketing information only based on your user language, provide or promote our or third parties’ following goods and services to you.

(2) Send notices to you. We may send you notices related to the service when necessary (for example when we suspend a single service, change, or stop providing a single service due to system maintenance).

If you do not wish to continue to receive messages we have pushed, you may request us to stop the push. For example: According to the SMS unsubscribe guidelines, you may request us stop sending promotional SMS messages or set up on mobile devices to stop receiving messages from us. However, except when we send messages according to the provisions of the law or the service agreement of individual services.

3. Improve our services

We may use the information collected through Youdao Service to improve our services. For example, we will use the log information we collect from your use of the Youdao Service to analyze your interests and provide you with specific content or to show you information that is relevant to you, but not universally pushed; we may ask you to participate in surveys about Youdao Service to help us improve existing services or design new services; at the same time, we may use your information for software updates.

4. Other use of anonymous information

You understand and agree that, in certain instances, upon the collection of your information, we will de-identify and fully anonymize the data through technical means, so that it no longer constitutes personal data directly or indirectly related to an individual, such as you. The de-identified information will not identify you or be related to you. In such case, we will use such de-identified information to analyze and commercialize the user database.

If we use your information for other purposes not specified in this Privacy Policy, we will ask for your consent in advance.

5. Exceptions to get authorization

According to relevant laws and regulations, collecting your information under the following circumstances does not need to get your authorization:

(1) related to national security and national defense security;

(2) related to public safety, public hygiene and material public interests;

(3) related to criminal investigation, prosecution, trial and execution of judgments;

(4) it is difficult to obtain your own consent for the maintenance of material legal rights and interests such as the life and property of the main body of the information or other individuals;

(5) the information collected is disclosed by yourself to the public;

(6) information collected from legally disclosed information, such as the channels including legitimate news reports and governmental information disclosure;

(7) necessary to sign a contract according to your request;

(8) necessary to maintain the safe and stable operation of Youdao Service, for example, discover and deal with the failure of products or services;

(9) necessary for legitimate news reports;

(10) necessary for academic research institutions to conduct statistical or academic research based on public interest, and when provided outbound results of academic research or description, the information contained in such results will be de-identified;

(11) other circumstances as stipulated by laws and regulations.

III. We will Share, Transfer and Disclose the Information

(I) Share

Except for the following circumstances, without your consent, we will not share your information with any third party other than Youdao:

1. Provide you with our services. We may share your information with our partners and other third parties in order to achieve the core functions you need or to provide the services you need, such as to provide logistics service providers with corresponding order information;

2. Maintain and improve our services. We may share your information with our partners and other third parties to help us provide you with more targeted and improved services, such as communication service providers that send emails or push notifications on our behalf;

3. To achieve the purposes described in Section II “How will we collect and use the information” of this Privacy Policy;

4. perform our obligations under this Privacy Policy or other agreements entered into between you and us and exercise our rights;

5. share with third parties including the partners who entrusts us to promote, but we will only provide such third parties with the information relating to the coverage and effectiveness of the promotion, not any information which will identify you, such as name, telephone number or email address; or we will summarize these information so that it will not identify you personally. For example, we will share your log information with Firebase Crashlytics and Youdao Analyzer to analyze your interests and improve our service.

6. To the extent permitted by laws and regulations, in order to comply with the law, protect us and our affiliates or partners, you or other Youdao users or the public interest, property or safety from harm, such as to prevent fraud and other illegal activities and reduce credit risk, we may exchange information with other companies and organizations. However, this does not include information sold, rented, shared, or otherwise disclosed for profit making in violation of the commitments made in this Privacy Policy.

7. to help you deal with your disputes or controversy with others upon your legitimate request;

8. provide your information in response to the legitimate requests of your guardian;

9. provide according to the individual service agreement signed with you (including the online signed electronic agreement and the corresponding platform rules) or other legal documents;

10. provide based on academic research;

11. provide based on the social and public interests that are in conformity with laws and regulations.

We will only share your information for legitimate, justifiable, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share the information, we will sign strict confidentiality agreements with them and ask them to process information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

(II) Transfer

1. We may conduct mergers, acquisitions, asset transfers or similar transactions, and your information may be transferred as part of such transactions. We will ask new companies and organizations that hold your information to continue to be bound by this Privacy Policy. Otherwise, we will ask the company and organization to ask you for authorization again.

2. With your explicit consent, we will transfer your information to other parties.

(III) Disclosure

We will disclose your information only under the following conditions and in compliance with industry-standard security measures:

1. disclose your designated information in the manner to which you explicitly agree according to your needs;

2. Where it is necessary to provide your information in accordance with the requirements of laws and regulations, mandatory administrative enforcement or judicial requirements, we may disclose your information in accordance with the type of information requested and the manner of disclosure. In compliance with laws and regulations, when we receive the above request for disclosure of information, we will require the recipient to show corresponding legal documents, such as subpoenas or investigation letters. We firmly believe that the information required to be provided by us should be as transparent as possible to the extent permitted by law. We have carefully reviewed all requests to ensure that they are legally valid and are limited to the data that law enforcement agencies have obtained for their specific legal purposes.

IV. How will we keep, save and protect the information

We retain your information only during the period required by the purposes described in this Privacy Policy and within the time limits required by laws and regulations.

The information we collect above are safely stored on servers which belong to Youdao. These servers are located in Singapore. We will not sell the information we collect. Only with your express consent will we collect and transfer such data to the servers outside your country, if you want to opt out, please refer to V. How to Manage Your Information. We will take the following measures to protect your information:

(I) Data Security Technology Measures

We will adopt industry-standard security protection measures, including the establishment of reasonable system specifications and security technologies to prevent unauthorized access and modification to your information, avoid the damage or loss of data. Web services use a variety of encryption technologies. For example, in some services, we will use encryption technology (such as SSL) to protect your information, adopt encryption technology to encrypted storing your information, and isolate via isolation technology. In the use of information, such as information display, information-related computing, we will use a variety of data desensitization technologies to enhance the security of information in use, and use strict data access control and multiple identity authentication technologies to protect the date from being used illegally.

(II) Other Security Measures Adopted by Us to Protect the Information

We manage and regulate the storage and use of information by establishing a data classification hierarchy, data security management rules, and data security development regulations.

We conduct comprehensive data security control through information access confidentiality agreements, monitoring and auditing mechanisms.

Strengthen security awareness. We also hold security and privacy protection training courses to strengthen employees’ awareness of the importance of protecting information.

(III) We only allow Youdao employees and partners who need to know the information to access to your information, and set strict access control and monitoring mechanisms for this purpose. We also require that all personnel who may have access to your information perform the corresponding confidentiality obligations. Failure to perform these obligations may result in legal liability or suspension of cooperation with Youdao.

(IV) We will take all reasonably practicable steps to ensure that no unrelated information is collected.

(V) The internet is not an absolutely secure environment, and the methods used to communicate with other users, such as e-mail, instant messaging, social software or other service software, cannot be determined to be fully encrypted. We recommend that you use complicated passwords when using such kinds of tools and carefully protect your Information security.

(VI) The internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protective facilities are destroyed, resulting in unauthorized access to information, public disclosure, alteration, or destruction, and your legitimate rights and interests are damaged, we will inform you of such failure as soon as possible and use our best efforts to restore the reasonable integrity of the facilities.

(VII) Dealing with Security Incidents

When communicating with third parties or purchasing goods and services through Youdao Service, you will inevitably disclose your information to the counterparty or potential counterparties, such as contact information or postal address. Please protect your information and provide it to others only when necessary.

In order to cope with possible risks such as information disclosure, damage and loss, we have formulated a number of systems to clarify the classification and grading standards for security incidents and security vulnerabilities and the corresponding processing procedures. We also set up a specific emergency response team for security incidents. According to the requirements of the security incident handling regulations, we will initiate security preplans for different security incidents, conduct stop loss, analysis, positioning, formulate remedial measures, and trace and crack with relevant departments jointly.

Upon the occurrence of unfortunate information security incidents, we will promptly inform you in accordance with the requirements of laws and regulations: the basic information and possible impact of security incidents, the measures we have taken or will take, and recommendations on your own precautions and risk reduction, remedial measures for you and so on. At the same time, we will promptly inform you of the incident-related situation by email, letter, telephone, push notification, etc. When it is difficult to notify the information subject one by one, we will issue a notice in a reasonable and effective manner. Meanwhile, we will also voluntarily report the disposal of information security incidents in accordance with regulatory requirements.

Please understand that due to technical limitations and risk prevention limits, even if we have strengthened our security measures as much as possible, we cannot always guarantee 100% security of the information. You need to understand that the system and communication network used by you to access to Youdao Service may have problems due to circumstances beyond our control.

V. How to Manage Your Information

(I) Access, Rectify, Update, Object and Delete

We encourage you to rectify, update and modify your information to make it correct, more accurate and effective. You can access your information through Youdao Service, and complete by yourself or request us to modify, supplement or delete according to management of corresponding information. We will use appropriate technical methods to ensure you can access, update, correct and delete your own information or other information provided when using Youdao Service as much as possible.

When accessing, updating, correcting and deleting the above information, we may ask you to do identity verification to keep your information secure. Upon making a request to access, update, correct or delete your personal data, we will assess whether there is any rule or exception under the applicable laws that may enable us to object to your request, and inform you of this decision.

In case you have any question or request to access, rectify, update, modify and delete your data, you can contact us pursuant to the means explained in Section IX below.

(II) Cancellation

Subject to the conditions specified in the service agreement in relation to single Youdao Service and the provisions of relevant national laws and regulations, your account for such single Youdao Service may be cancelled or deleted. After the account is cancelled or deleted, all service information and data related to such account and such single service will be deleted or processed according to the service agreement in relation to such single Youdao Service.

(III) Change the Scope of your Consent

Some information is required to use Youdao Service, but the provision of most other information is on your decision or consent. Where the processing of personal data is based on your consent, you can always select whether or not to disclose the information. You can change the scope of your consent to us to continue to collect the information or withdraw your consent by means of withdrawing it, deleting information, turning off device functions and so on. You may also withdraw your consent by contacting us pursuant to the means explained in Section IX below.

After you withdraw your authorization, we are unable to continue to provide you with the service corresponding to the withdrawal of the consent, and will not process your corresponding information. However, your decision to withdraw your consent will not affect the information processing previously based on your consent.

(IV) Sensitive Information

Certain information may be considered being sensitive information because of its particularity, such as your race, religion, personal health and medical information, as well as identification documents, personal biometric information, property information, traces, information of minors, etc.

Please note the content and information provided or uploaded by you on Youdao Service (such as photos or information about your social activities) may reveal your sensitive information. You need to carefully consider whether to use Youdao Service to disclose your sensitive information. When you do so, we will understand that you give your explicit consent to Youdao to process such sensitive information.

You agree that your sensitive information will be treated in accordance with the purposes and manner described in this Privacy Policy.

VI. Third Party Services We Use

In addition to the Services we provide directly, we also use third party service providers (collectively referred to as “Third Party Services”) who operate their own privacy policies. The Third Party Services will also collect and process your information. If you want to manage your information collected through Third Party Services, please refer to their privacy policies.

(I) Third Party Services We Use

Google Analytics-------for the collection of anonymous analytical data to help us better understand how our customers and users use our Services. You can prevent the recording of data about your use of the website by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout.

(II)Third Party SDKs(Software Development Kit) We Use:

Firebase Crashlytics-------a lightweight, realtime crash reporter that helps us track, prioritize, and fix stability issues that erode our app quality. You can visit its privacy policy to manage your information at https://policies.google.com/privacy.

Facebook-------provides us with the ability to interact with the Facebook Platform for integration with Facebook if and when you choose to log in with your Facebook account. You can visit its privacy policy to manage your information at https://www.facebook.com/about/privacy.

Admob-------shows ads that are based on your information and interest to you. You can visit its privacy policy to manage your information at https://policies.google.com/privacy.

Google play service auth------- provides us with the ability to interact with the Google Platform for integration with Google if and when you choose to log in with your Google account. You can visit its privacy policy to manage your information at https://policies.google.com/privacy.

Inmobi-------shows ads that are based on your information and interest to you. You can visit its privacy policy to manage your information at https://www.inmobi.com/privacy-policy/.

Appsflyer-------helps us to distinguish different users, installs and other events that are associated with a media source via clicks and impressions. You can visit its privacy policy to manage your information at https://www.appsflyer.com/privacy-policy/.

Google Billing-------enables you to pay for pay for our VIP services. You can visit its privacy policy to manage your information at https://policies.google.com/privacy.

YouTube-------helps us to play YouTube videos directly in U-Dictionary. You can visit its privacy policy to manage your information at https://policies.google.com/privacy.

Suntone-------helps us to provide you with the follow-up reading and score functions in U-Dictionary. You can visit its privacy policy to manage your information at https://www.isuntone.com/index.html.

Youdao Ads-------shows ads that are based on your information and interest to you. You can visit its privacy policy at http://shared.youdao.com/dict/market/youdaoInc-v2.1/index.html#/CN. Although this service is provided by our affiliate, we will use our best efforts to comply with our information isolation policy to make sure your information is safely collected, stored and processed.

Youdao Analyzer-------helps us analyze your log information to provide better services. You can visit its privacy policy at http://shared.youdao.com/dict/market/youdaoInc-v2.1/index.html#/CN. Although this service is provided by our affiliate, we will use our best efforts to comply with our information isolation policy to make sure your information is safely collected, stored and processed.

VII. Age Limit

We recommend that any minor who participates in online activity should obtain prior consent from parents or his/her legal guardian (“Guardian”). We will protect information about minors in accordance with relevant national laws and regulations.

We encourage parents or Guardians guide the minors to use Youdao Service. We recommend minors encourage their parents or Guardians to read this Privacy Policy and advise minors to seek parental or Guardian’s consent and guidance before submitting information.

Where the processing of personal data of a minor is based on the legal basis of “consent”, a minor must not use Youdao Service for any purpose without first obtaining Guardian’s consent to this Privacy Policy. We do not knowingly process personal data from any minor without such consent. If you believe we have any personal data from any minor under your guardianship, please contact us via the contact information set forth in Section IX, we will promptly investigate (and remove, if applicable) such Personal Information.

VIII. Notice and Amendment

We may revise the terms of this Privacy Policy as appropriate and such modifications form part of this Privacy Policy. For major changes, we will provide more noticeable notices, and you may choose to stop using Youdao Service. In such case, if you continue to use Youdao Service, you agree to be bound by this Privacy Policy as revised.

Any amendment will put your satisfaction in the first place. We encourage you to review our Privacy Policy each time you use Youdao Service.

We may publish service-related announcements when necessary (for example, when we suspend certain service due to system maintenance). You may not be able to cancel these announcements that are related to the service and that are not in the nature of promotion.

Finally, you must be obligated to keep your account and password confidential. In any case, please take care of such information safely.

IX. How to Contact Us

If you have any complaints or reports about the security of online information, or if you have any questions, comments or suggestions about this Privacy Policy and matters regarding your information, and any questions regarding this statement or Youdao's privacy practices, please contact Youdao’s coordinators. The email address is udictionary01@gmail.com.

If you have any issues with or concerns regarding the processing of your personal data by Youdao, you also have the right to lodge a complaint with a competent data protection authority.