英国文化教育协会儿童用户个人信息保护规则

The protection of children's personal information is of paramount importance. BC Education Consulting (Beijing) Co., Ltd. (hereinafter referred to as "we") will strictly comply with the provisions of effective laws and the "British Council Policy for the Protection of the Personal Information of Child Users" (hereinafter referred to as the "Policy") to protect child users' personal information that we collect and generate in providing our products or services. The Policy will inform the children and their guardians (hereinafter referred to as "you") about how we collect, use, store, transfer and disclose the personal information about minors under the age of 14 (hereinafter referred to as "child users"); the storage location and duration of child users' personal information and disposal upon expiration; the security measures for protecting child users’ personal information; the consequences of refusing to handle child users’ personal information; the channels and ways for you to raise concerns or complaints and report to us, as well as the means for you to correct or delete child users’ personal information. For circumstances not provided for within The Policy, or if we are unable to confirm whether the user is a child under the age of 14, the IELTS registration website "User Privacy Policy" and the British Council’s "Privacy Policy on Collection and Processing of IELTS Candidates' Personal Information in Services Subsequent to Registration" (collectively referred to as the "Privacy Policy") will also apply.

I. Special notice

If you are the guardian of a child user (hereinafter referred to as the "guardian"), please read carefully and agree to The Policy to understand how we collect, use and protect the personal information of child users. Please note that we will only process, to the extent permitted by law, the personal information of a child user under your guardianship if and only if you agree to The Policy. We appreciate your support in working with us to protect children’s personal information, educate and guide them to enhance their awareness and ability to protect personal information, and instruct, remind and request them not to disclose any personal information to any online product and service providers without your consent.

Child users under the age of 14 shall read carefully and agree to the content of The Policy with their guardians to understand how we collect, use, store, transfer and disclose the personal information of child users. A child user may continue to use our products and services if and only if the guardian consents. When a child user uses our products or services, we will assume that the guardian has consented.

We remind you that we have made particularly important provisions bold and underlined in The Policy for your ease; please read them carefully. If a guardian does not agree to the content of the relevant Privacy Policy and this Statement or does not agree to provide the information necessary for the services, our products and services may not function properly and as a result, the guardian and the child user may not be able to participate properly in the IELTS-related testing services. If you have any questions while reading The Policy, please contact us through the contact information provided under The Policy.

II. Applicable scope of The Policy

We will process the personal information of child users in the following scenarios:

1. When child users register for IELTS-related testing services, including IELTS (both IELTS on Paper and IELTS on Computer) and IELTS for UKVI (both IELTS on Paper and IELTS on Computer) IELTS Life Skills and One Skill Retake that's associated with an IELTS full test session (hereinafter referred to as IELTS), we will process their personal information;

2. To ensure that child users successfully complete their identity verification on the test day, receive their results as scheduled and enjoy the subsequent delivery of their results, we will use the WeChat mini program to seek your authorization for the collection and processing of the candidates’ personal information as stated below in this Privacy Policy, in addition to collecting the personal information from child users for the IELTS registration;

3. Other scenarios where we specifically state that The Policy apply.

III. How we collect and use child users’ personal information

While providing products or services for children, we will collect relevant personal information. Please refer to the relevant section of the Privacy Policy for the detailed purpose and scope of the personal information we collect from child users.

If we need to use a child user's personal information beyond the functions and purposes stated above, we will again inform the guardian for consent. Scenarios of using child users' personal information:

After collecting a child user's personal information, we may use the child user's personal information for the following purposes:

• To provide proper products and services for child users to the extent permitted by law.
• To report to the relevant authorities in accordance with laws, regulations or regulatory requirements.
• Other purposes with the consent of child users and their guardians.
• We may analyze and utilize the user database as a whole without disclosing the personal information of individual users. We will abide by laws and regulations and the principle of legality, propriety and necessity and take necessary security measures for the relevant information, such as de-identification or anonymization of data through technical means. We will not combine the information stored in the analytic software with any personal identity information provided by the child user in the application program.

If we need to use a child user's personal information beyond the purposes stated above, we will again inform the guardian for consent.

IV. How we store child users' personal information

We will only store child users' personal information for a necessary period for the purposes stated in The Policy and the Privacy Policy and within the retention period as specified by laws and regulations. Please refer to the relevant section of the Privacy Policy for the specific types of information and storage periods. If the above-mentioned period is exceeded, we will promptly destroy or anonymize child users’ personal information.

In principle, child users' personal information that we collect and generate in the People's Republic of China will be stored in the People's Republic of China, except for the following cases:

• Explicitly provided by laws, regulations, government rules, departmental regulations, or administrative or judicial directives;
• With your express authorization.

For the above circumstances, we will ensure the safe protection of child users' personal information in accordance with laws and regulations and The Policy.

V. How we entrust processing, sharing, transferring and disclosing child users' personal information

We strictly restrict the sharing, transfer and disclosure of child users' personal information in accordance with laws and regulations.

Unless otherwise stated in The Policy and Privacy Policy, or required by law or government departments, we will not share child users' personal information with any third party. In the meantime, we will only share child users' personal information with third parties with the prior consent of their guardians.

With the continuous development of our business, we may be engaged in mergers, acquisitions, asset transfers or similar transactions, and child users' personal information may be transferred as part of such transactions. We will inform you of related circumstances through notices and announcements and will continue to protect or require the new administrator to continue to protect child users’ personal information in accordance with laws and regulations, and standards no less stringent than those required by The Policy and Privacy Policy. In the meantime, we will conduct a security assessment in accordance with legal requirements before transferring child users’ personal information.

VI. Cross-border transfer of personal information

In view of our provision of IELTS testing services to you, child users' personal information we collect and process will be transferred to the University of Cambridge and the British Council. When transferring your personal information from the People’s Republic of China to other countries or regions, we will strictly comply with the provisions of Chinese laws and regulations and take a range of proper measures to ensure that the processing of your personal information by the overseas recipient meets the protection standards set out in Chinese laws and regulations. We will transfer your personal information across borders with your sole consent or other legal bases and conduct a security assessment of the personal information leaving the country to adequately prevent and control risks and protect your personal information. For details on the handling of personal information in any cross-border transfer, please refer to the relevant section of the Privacy Policy.

VII. Child users' personal information rights

You can exercise your personal information rights in the following ways, and we will protect such rights in accordance with relevant laws and regulations, including but not limited to:

1. Amendment to your personal information

You may request amendment to your personal information if you have submitted inaccurate information (excluding registration information for IELTS One Skill Retake, which must be consistent with the corresponding IELTS full test).

• To amend your core personal information, such as Chinese and English name, gender, ID document type, ID document number and date of birth, please contact the IELTS National Call Centre (email: ielts@mail.neea.edu.cn, Tel: 010-82345671) of the National Education Examinations Authority (hereinafter referred to as the "NEEA") with "IELTS Candidate Personal Information Amendment Form" and supporting documents.
• Before the close of registration, you can log in to NEEA IELTS registration website at any time to change your personal information other than the above-mentioned core personal information. After close of registration, if you need to change your non-core personal information, please contact NEEA IELTS National Call Centre (email: ielts@mail.neea.edu.cn, Tel: 010-82345671) with supporting documents.

2. Deletion of personal information

In case of the following circumstances, the British Council will take the initiative to delete your personal information; if it is not done, you can make a request to us to delete your personal information.

• If our processing of personal information violates laws and regulations;
• Where prior authorization is required, we collect and use your personal information without your authorization, or you have withdrawn your authorization;
• If our processing of personal information violates our agreement with you;
• If the purpose for which we collect and use your personal information has been achieved, cannot be achieved or is no longer necessary;
• If you no longer use IELTS-related services;
• If we no longer provide you with products or services.

3. Change the scope of your authorization

Where we process your personal information based on your authorization, you have the right to withdraw your authorization. Upon withdrawal of your authorization, we will no longer process the relevant personal information, and the corresponding service will not be delivered. Please note that withdrawal of your authorization will not affect the effectiveness of personal information processing activities based on your prior authorization.

4. Obtain a copy of your personal information

You have the right to obtain a copy of the personal information you submitted in the process of using IELTS-related testing services. Please make a request to our designated email address for personal information protection (CNDisclosures@britishcouncil.org). Fees may occur for this service.

For you or your potential guardians, close relatives and other authorized subjects to make the above request to the British Council or to execute your personal information rights under the laws of the People’s Republic of China, you can contact us through our designated email address for personal information protection as listed in "IX. Contact us". To verify whether you are the guardian of the child concerned, we may ask you to provide ID documents, proof of kinship and other documents for verification.

Please be advised that we will not be able to respond to your request in the following cases:

• Related to performance of our obligations under laws and regulations;
• Directly related to state security, national defense security;
• Directly related to public safety, public health and major public interests;
• Directly related to criminal investigation, prosecution, trial and execution of judgment;
• We have sufficient evidence of the subject of personal information having subjective malice or abuse of rights;
• For the purpose of safeguarding the life, property and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain prior authorization;
• Response to the individual’s request of their personal information will cause serious damage to the legitimate rights and interests of the said individual or other individuals and organizations;
• Related to trade secrets.

In addition to the above-mentioned rights, you have the rights of decision, restriction and refusal and rights related to automated decision-making over the personal information of child users. For the exercise of the above-mentioned rights, the guardian can also contact us through our designated email address for personal information protection as listed in "IX. Contact us", and we will timely respond to the rights-related request.

VIII. Application of The Policy

For circumstances not covered in The Policy, the relevant content of the Privacy Policy shall apply. When The Policy is applied, if there is a conflict between related provisions and the Privacy Policy, The Policy shall prevail.

IX. How to contact us

You can contact us in the following ways if you have any questions, comments or suggestions about the content of The Policy:

Registered address/office address: 3/F Building No. 4, 8 Dongsanhuan Beilu, Chaoyang District, Beijing

Our designated personal information protection email: CNDisclosures@britishcouncil.org