Elernity Limited, (herein "we" or "us"", “ours”), including its subsidiaries and affiliates, understands the importance of protecting your personal information (the "Personal Information"). We have adopted this privacy policy (the "Policy") to explain how we collect, use, process, store and share the Personal Information that provide to us or we collect when you use our websites, software applications, games or any other services provided by us (the "Services").

We collect, use, process, store and transfer your Personal Information in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation ("GDPR") and applicable national data protection legislation ("Applicable Laws"). Wherever we talk about Personal Information below, we mean any information that can either by itself identify you as an individual or that can be connected to you indirectly by linking it to your Personal Information. We also collect, use, process, store and transfer de-identified data, whether aggregated or not, to analyse and generate reports related to usage patterns, spending habits, demographics of users, etc. As a person is not or no longer identifiable from such anonymous data, the use of such data will not be governed by this Policy.

You agree that we will engage other third parties and may transfer your Personal Information to such third parties in order to fulfil our purposes and obligations as set out in this Policy. You acknowledge that some of these third parties may be located outside the country of your residence where there may not have as strict privacy legislation as yours. We will only transfer your Personal Information to such countries if we are allowed to do so, please see section D for more information.

By downloading, accessing and/or using our Services, you consent to our collection and use of your Personal Information in accordance with this Policy, including consenting to our advertising partner’s use of your data for targeted advertising purposes as set forth in section B of this Policy. IF YOU DO NOT AGREE TO THE POLICY OR OTHERWISE HAVE ANY CONCERNS ABOUT THIS POLICY, YOU SHOULD CONTACT US FOR ASSISTANCE AND SHOULD REFRAIN FROM USING OUR SERVICES.


We collect Personal Information about you to provide you with our Services, including improving and optimising our Services, detecting unlawful use of our Services, personalising offers and processing and verifying transactions.

Depending on the type of Services you are using, we may collect the following types of information from you:

(i)Personal data
(ii)Data that you may provide to us
(iii)Data that may be provided to us by third parties
B.Use of Data

We may use your Personal Information for the following purposes:

Our Legitimate interest

We may also use your Personal Information for our legitimate interests, such as for the purposes of our compliance with Applicable Laws, to ensure information security, to prevent fraud, etc.

When we rely on a legitimate interest, we have concluded that our interests do not override your interests or fundamental rights and freedoms. You are welcomed to contact us to learn more about how we reach this conclusion.

Analytics and optimisation

We use internal analytics technologies and other automatic tracking and analytic technologies provided by third parties to collect information through automated means, such as cookies, web beacons, web sever logs, or other similar technologies in order to adapt our content to your interests as well as to provide and manage the use of the Services.


Cookies, or similar technologies, are small computer files stored on your hard drive via your web browser. Various types of cookies may be used for a number of purposes and they are placed on our websites either by us or by other third parties permitted by us. The information collected by cookies enable us to monitor site traffics and users’ interactions with other services. We may also use certain cookies that can only collect generic information in relation to browser configurations and personalize the appearance of our websites. We also use anti-cheat technologies that also use cookies as described below.

You may decline the storage of cookies by changing the configuration of your web browser. However, if you decline, the Services and/or our websites and/or certain features may not work properly. For more information on cookies, please refer to the following website: http://www.allaboutcookies.org.

(ii)Third-party analytics tools

Third-party analytics tools may use cookies or visitor action pixels to track your behaviors while you are using our Services. These tools may associate the information they collected in connection with the Services with personal information that they had independently collected on other services, as governed by their respective privacy policies. We do not collect or access any data that may be independently collected by these third parties.
We use the following third-party analytics providers and you may refer to their privacy policy at the links provided below:

Marketing and Advertising

If you choose to receive our marketing materials, newsletters and news releases, the Personal Information you have provided us with will allow us to send you messages regarding new features, updates, contests and events concerning our Services or to show you promotions, services or products that might be of interest to you in connection with the Services. You may opt out of this service at any time.
You acknowledge and agree that if you opt out of receiving interest based or targeted advertising, you may still see advertising which may or may not related to our Services, but the relevant advertising will not be targeted using your Personal Information.
We also use information about you to improve user experience and to ensure that you only see marketing materials that might be of interest to you. Our marketing partners use ads serving technologies for this purpose.

Social Media Features

You will be able to use our social media features for logging into our Services, find out if your friends play our services, and invite them to join you in these services. If you choose to use social media features in some of our Services, to create account with us using your account with certain social media platform, the social media platform will provide us with some of your Personal Information, such as, your social media platform user ID, your profile picture (to create your avatar in certain games) and the user IDs and profile pictures of your followers, friends or contacts on such social media platform. You may determine the scope and extent of Personal Information that will be provided to us by modifying your sharing settings.

Public data, including user-generated content, online forums, blogs, chat and profiles

You may communicate Personal Information when you provide or otherwise create contents by using or accessing our Services, whether as part of our product , online forums, blogs, discussion platforms, public user profiles, drive or other similar forums available as part of our Services (collectively, the "Forums"). Any Personal Information you disclose in the Forums would become public data and may be read or used by other users without your consent. If you decide to disclose Personal Information on the Forums, you will do so at your own risk and we shall not be responsible for held liable for any unauthorized use of such Personal Information by any third parties.
You may choose not to provide certain Personal Information. However, you may not be able to use certain or all features of our Services.

C.Personal Data Shared with Third Parties

We may, from time to time, engage independent subcontractors to provide us with certain services, such as sending e-mails, processing of payments, hosting of data, and providing customer support. We take reasonable contractual measures to ensure that these third parties adequately protect the Personal Information.
We do not share Personal Information with other third-parties, except as necessary for provide the Services, for our legitimate business needs, for carrying out your requests, and/or as may be required or permitted by Applicable Laws.
In particular, we engage third parties to collect and process your Personal Information on our behalf and for our benefits in order to provide the Services, including but not limited to:

We may share Personal Information that does not identify you directly, which is anonymized or aggregated, with third parties, for example to analyze trends in the use of the Services. In addition, we do not control the data sent by your web browser to third parties who receive this information in your normal course of activity on the Internet.
To safeguard your Personal Information and comply with the applicable privacy laws, we will require the third parties to sign a separate Data Processing Agreement with us, in the event that it is required under the law.

D.Location and Transfer of Your Personal Informations

The Personal Information may be hosted and processed, for the purposes of the Policy, on servers operated by trusted partners in the United States and China(in accordance with the Privacy Shield mechanism recognized by the European Commission), such as Amazon Web Services, as well as on our servers or our partners’ servers in Canada (which is a jurisdiction with an adequate level of protection recognized by the European Commission) or in Europe.
Some of our subcontractors described in Section C may be located in other countries, including outside the European Economic Area. By using the Services and the games, you agree that your Personal Information may be processed by such subcontractors in countries that may not offer the same degree of data protection as your country. We will, however, only transfer the Personal Data in compliance with Applicable Laws.
We have taken reasonable contractual measures to ensure that our subcontractors would process your Personal Information in accordance with our directions and for our purposes as set forth in this Policy. Our subcontractors are prohibited from using your Personal Information for any other purposes without your consent.

E.Retention Period of Personal Information

We keep your Personal Information for a period not exceeding what is required for the purposes for which the Personal Information is collected and in accordance with Applicable Laws.
Your data will be kept in our active database:

At the end of this period, your Personal Information will be deleted or anonymized by us, or archived in an intermediate database, if necessary, for legal, operational, or legitimate reasons, and for the legally prescribed period. The retention period may be changed upon your cancellation of or re-enrollment in the Services, or in accordance with Applicable Laws.

F.Safeguards of your Personal Information

We take different measures to secure your Personal Information. We follow generally accepted rules in the online education industry, as well as Applicable Laws, to protect any loss, destruction, alteration, or unauthorized, unlawful or abusive use of the Personal Information. We strive to use appropriate organizational and technical means to protect your Personal Information. For example, we will use encryption technologies (such as TLS, SSL), anonymization and other means to protect your personal information.
We have established a specialized management, process and organization system to ensure information security. For example, we strictly restrict the scope of personnel who can access information and require them to comply with their contractual confidentiality obligations and subject to regular audits. In the event of a data breach or other security incident of Personal Information, we will activate emergency response plan to prevent the expansion of such security incident and notify you in the form of push notifications, public announcements, etc.
However, you acknowledge that no security measures are 100% effective. To the extent permitted by Applicable Laws, we shall not be held liable for any direct or indirect loss, damages or costs sustained or incurred by you in the event of data breach or if the Personal Information is subject to unauthorized use or access.
If you have any questions regarding the security of your Personal Information, please contact us by email at: hysupport@101.com .

G.Your Rights and Choices on Your Personal Information

For Services which you have created an account with us, you can access, modify, update and delete any Personal Information at any time by logging into the relevant Service and adjusting your account settings.
If you wish to contact us regarding the processing of your Personal Information, or to have access to it in an electronic format, correct it, erase it, change how we process it (if applicable), or withdraw your consent (if applicable), or transfer them to another online provider (where technically possible), you may email us athysupport@101.com . Please note that the withdrawal of your consent shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.
In the case of an email request, you agree to provide us with your contact information, the subject of the request and the Personal Information in question for our further action. We reserve the right to ask you for any information about you to confirm your identity.
Please note that if you choose to delete your Personal Information, you will no longer have access to the Services associated with your internal and/or external identifier.
We reserve the right to reject deletion requests if there is a legal obligation on us to retain the Personal Information due to legal claims or as required by any Applicable Laws.
Your request will be processed within thirty (30) days of receipt, with the understanding that we reserve the right as permitted by Applicable Laws to extend this period to two months due to the complexity and number of requests.
You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

Most of our Services (including some of our games) are not directed to children under the age of 13 (“Controlled Services”). WE DO NOT KNOWINGLY COLLECT, SOLICIT, MARKET TO OR REQUIRE THE PERSONAL INFORMATION BELONGING TO CHILDREN. IF YOU ARE 13 YEARS OLD AND LESS, OR BELOW THE MINIMUM APPLICABLE AGE IN COUNTRIES WHERE THIS AGE IS GREATER THAN 13 YEARS, DO NOT SEND YOUR PERSONAL INFORMATION TO US AND DO NOT USE SUCH CONTROLLED SERVICES. If we obtain actual knowledge that we have collected data from a Children, we will promptly delete it, unless we are legally obligated to retain such data.
Some of our Services are suitable for users under the age of 13 (or under age of 16 in Europe or below the minimum applicable age in your country) (“Children”), including but not limited to (“Unrestricted Services”). We strongly recommend the parents and/or legal guardians of the Children, to read this Policy thoroughly to understand how we will collect, use, store, share and protect Children’s data in connection with the Children’s use of our Unrestricted Services.
We may require the parents’ and/or legal guardians’ personal information to create any user accounts for their Children to access to our Unrestricted Services. Such information may include user name and email address.
We collect information as detailed in this Policy for the purpose of providing Unrestricted Services and other purposes as described in this Policy. If you are not a minor but is under the legal age in your country, we require you have your parents and/or legal guardians’ instructions in you uploading, sharing or disclosing any Personal Information while using our Services or provide the same to other users of the Services and you acknowledge that your parents or legal guardians may be liable for all activities of you.
Parents or legal guardians who are concerned about our use of data are welcomed to contact us at hysupport@101.com
I.Third party services

Our Services may contain advertisements or links to third-party websites such as Twitter, Facebook and/or YouTube. The presence of these links on our Services does not constitute an approval, an authorization or an affiliation with the websites in question. If you click on these links or use the services of a third party, you will leave our Services and you must consult the privacy policy of the website in question before sharing your Personal Information.
Certain products and/or services are offered to you as part of our Services in partnership with third parties and you may be required to provide Personal Information to them in order to register and access their products or services. The identity of these third parties will be indicated at the time of registration. If you choose to register, you will transmit your Personal Information to these third parties and their use of your Personal Information will be subject to their privacy policies.
We are not responsible for the use of your Personal Information by such third parties and we cannot guarantee that they have the same level of data protection policy as us.

J.Conditions of use of our Services

The terms of this Policy are incorporated into our End User Agreement which you may refer to at the following link: https://class.101.com/about/agreement.html

K.Changes to the Policy

We reserve the right to change the Policy at any time. If we change the Policy, we will communicate the changes to you through the landing page or other similar page under the Services, or any other appropriate means, for example, by email or with a pop-up notice in our games or on your account page, so that you will be fully informed of such changes. Any changes to the Policy will take effect thirty (30) days after such changes have been communicated to you. Your continued use of our Services will be deemed as an acceptance of the changes to the Policy.


If any part or provision of this Policy is prohibited or deemed to be void or unenforceable, that part or provision shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.

M.Governing Law

This Policy shall be governed by, and construed in accordance with, the laws of Hong Kong Special Administrative Region (“Hong Kong”). Any dispute, controversy, difference or claim arising out of or relating to these Terms and Conditions, 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 seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.

N.Communicate with Us:

If you have any questions or concerns regarding this Policy, please contact us using information as follows: Email Address: hysupport@101.com