1. Brief Introduction

Welcome to our Website (www.nacisminhang.cn, this “Website”). This Website (defined to include any access via a web browser and any related application) is provided, owned, and managed by NACIS Shanghai (“Operator”, “School” or “we” or “us”). Operator is committed to protecting your privacy.

This Website is provided by Operator for the purpose of providing you with the latest information about School and supporting your potential or actual participation in school events and activities and enrollment consultations.. This Privacy and Cookies Policy (this “Policy”) covers information collected by Operator through this Website or directly provided by you. This Policy describes how Operator, through this Website, collects or receives any Personal Information (see below for definitions) from you or on your behalf, how Operator uses, shares, stores, discloses and protects the aforementioned Personal Information.

Personal Information refers to various information, recorded in electronic or any other form, that is related to an identified or identifiable natural person, excluding any information that has been anonymized.

2. Your Role and Responsibilities

Before using this Website, please read carefully and understand thoroughly this Policy. Please pay attention to the terms marked in bold/bold underline. You may start using this Website after confirming that you fully understand and agree to this Policy. Should you have any question, comment or advice on this Policy, please contact us through various ways provided by this Website.

You should be aware of, and have a right to know, what Personal Information is collected on this Website, how it is stored, protected, and used.

3. Your Rights and Choices

You have the right to know the Personal Information collection and storage practices of this Website.

You have the right to know how your Personal Information will be used and by whom.

You have the right to know to whom we may disclose your Personal Information.

You have the right to inquire at any time as to whether we are processing Personal Information about you, request access to, remove, or delete or port (transfer) your Personal Information, and ask that we correct or supplement your Personal Information where it is inaccurate or incomplete.

4. Privacy Policy

This Policy helps you understand the following:

A. How do we collect your Personal Information
B. How do we use your Personal Information
C. Other rules for the collection and use of Personal Information
D. How do we share and transfer your Personal Information
E. How may we sub-contract processing of your personal information
F. How may we disclose your Personal Information
G. Exceptions to prior consent for processing Personal Information
H. How may we protect your Personal Information
I. How may we store your Personal Information
J. International Transfers
K. Access, correction, deletion, and removal of Personal Information
L. How may we deal with Personal Information of minors
M. Links to Other Websites
N. Notification of Changes

A. How do we collect your Personal Information

When you use this Website, we need/may need to collect from you the following two categories of Personal Information:

1. In order to provide you with the basic functions of this Website, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our services normally;

2. In order to provide you with additional functions of this Website, you may choose to authorize us to collect and use information. If you refuse to provide the corresponding information, you will not be able to use the relevant additional functions or achieve the functional effects we intend to achieve. However, this will not affect your normal use of the basic functions of this Website.

The Personal Information we may collect from you includes basic Personal Information such as your first name, last name, title and/or email address, contact phone number(s), or other contact information that you provide to us through your use of this Website including in any of the ways explained below. We may also collect certain non-personally identifiable information upon your use of this Website, including specification of your internet browser and operating system and website browsing click data.

The specific features we will provide to you include:

a) Personal Information collected when you sign-up for email subscription of latest news and event information

Sign-up is required for email subscription of latest news and event information. To enable us to send you the latest news and information, we will collect your email address. If you refuse to provide the aforementioned information, you will not be able to sign up for this Website or receive the aforementioned news and information. Only browsing and search services are available for you.

b) Personal Information collected when you enquire about our education program/activities and school enrollment information

To enable us to contact you, learn your situation and needs, provide information you need and arrange campus visit or other activities for you, we will collect the following Personal Information about you and any student you are responsible for (as parents/guardians of such student, same below):

- first name 名字
- last name 姓氏
- nationality 国籍
- country/region of residence 居住国家/地区
- email address 电子邮箱地址
- home address 家庭住址
- WeChat ID 微信号
- primary telephone number 主要电话号码
- child date of birth 子女出生日期
- gender 性别
- ID/passport number 身份证/护照号

c) Personal Information collected when you submit school enrollment application or apply for enrollment of school program/activities

To enable us to process your application, arrange for assessment and interviews, travel and all activities relating to potential student’s enrolment in our school or existing student’s participation in school program/activities, we will collect the following additional Personal Information about any student you are responsible for: 

- current/previous school name 当前/以往学校名称
- school ID 学校ID
- medical information 医疗信息
- vaccination information, academic information 疫苗注射信息、学术信息

d) Cookies

Cookies are text files set in your Internet browser and used to store your personal preferences. Cookies will not disclose your email address or other personally identifiable information.

We use necessary Cookies to make this Website work and optional Cookies to improve your user experience.

- Necessary Cookies

These Cookies are fundamental to this Website’s core functionality and cannot be switched off without blocking key features on the website or impacting security features, such as to recognize the user as valid and authenticated while accessing protected areas of the website.

- Optional Cookies

Optional Cookies we use include analytics and advertising Cookies and preference Cookies.

- Analytics and advertising Cookies

Analytics and advertising Cookies may collect information about how you use this Website including details such as the website that referred you (e.g. search engines, marketing campaigns, referring domains), webpages you have visited, the website path you navigated and the links or advertisements that you have clicked on. We use this information to improve this Website, enhance visitor experience and to make advertising messages more relevant to you and your interests. These Cookies also perform functions like preventing the same ad from continuously re-appearing.

We will also share some of this information with third parties – such as analytics and search engine providers to assist us in improving and optimizing this Website, and advertisers to promote our services by presenting ads to you on websites that are not owned or operated by us. These advertisements are solely intended to make you aware of us. We will not sell your personal information to any third parties.

- Preference Cookies

Preference Cookies may collect choices you have made in the past (such as your username, language or the region you are in) and provide you with an enhanced more personalized experience.

You may choose to accept or refuse Cookies. Where you do not refuse to accept Cookies, Cookies will be sent to your browser and stored on the hard drive of your computer. Once you choose to enter your personal information in this Website, such information may be linked to the data stored in Cookies. When you visit or revisit this Website, we may identify you and provide you with better services by analyzing the data.

You may refuse Cookies by modifying your browser settings. But may we remind you that you may not be able to use features of this Website relying on Cookies.

e) Weblogs

We use standard web logs that record basic data about people who visit this Website.

The following information is contained in these logs:

- The date and time of the visit

- The pages of the websites viewed during the visit

- The IP (Internet Protocol) address of the computer used to visit this Website (Computers automatically generate an IP address as they surf the internet. An IP address is a number assigned to you by your internet service provider so you can access the internet. IP addresses are also used to track new versus return visitors to the website or in connection with any questionnaire used on the website)

- The type of web browser used to view this Website

- The website visited immediately before coming to this Website

We do not normally seek to identify individuals from web logs, including from their IP address, and we do not disclose them to others. However, web logs may be used to identify an individual who we have reason to suspect tried to damage this Website or use it in an unauthorized way. If we have reason to believe that there has been a violation of computer security or related laws, we may share our web logs with law enforcement agencies.

f) Device Information

We may also collect certain information that your mobile device sends when you use our services or access this Website, like a device identifier, user settings and the operating system of your device. Information collected about your mobile device and internet connection may include the device’s unique device identifier, IMEI number, IP address, operating system, browser type, browser language, referring/exit pages and URLs, mobile network information, and the device’s telephone number. Tools, applications, and widgets that we enable you to download to enable you to use the services on any mobile devices, may store information on your mobile or other devices. These tools may transmit personal information to us to enable you to access your user account and to enable us to track use of these tools. Some of these tools may enable you to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement, and as otherwise described in this Policy or in other notices we provide. We may send you email messages with a "click-through URL" linked to the content of our website. When you click onto one of these URLs, you will pass through our server before arriving at the destination webpage. We may track this click-through data to help us determine your interest in the subject matter and measure the effectiveness of our user communications. You can avoid being tracked simply by not clicking on any links or images in the email we send you.
当您使用我们的服务或访问本网站时,我们也收集您的移动设备发送的某些信息,如设备标识符、用户设置和您设备的操作系统。我们所收集的有关您的移动设备和互联网连接的信息可能包括:唯一设备标识符、IMEI号码、IP地址、操作系统、浏览器类型、浏览器语言、引用/退出页面和URLs、移动网络信息和该设备的电话号码。我们能让您下载工具、应用程序和小程序,以使您能够在任何移动设备上使用服务,该工具、应用程序和小程序会在您的移动设备或其他设备上储存信息。该等工具会向我们传输个人信息,以使您能够访问您的用户帐户,并且让我们能够追踪这些工具的使用情况。部分工具允许您该将报告和其他信息发送至您的邮箱。我们会使用您传输给我们的个人或非识别信息来增强这些工具、开发新的工具、提高质量以及本政策或我们提供的其他通知中所述的其他事项。我们将给您邮箱发送“click-through URL”链接到我们的平台内容。当您点击其中一个URL网址时,您将在到达目标网页之前通过我们的服务器。我们会跟踪这些点击数据,帮助我们确定您对主题的兴趣,并评估我们的用户沟通的有效性。只要不点击我们发送给您的电子邮件中的任何链接或图像,你就可以避免被追踪。

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of unauthorized activities.

We combine and use non-personal information (aggregated data) from our web logs and other technologies to study how this Website is being used. We will periodically analyze this aggregated data and use what we learn to make improvements to this Website. In addition, we may share this aggregated data (which does not contain any information which can identify an individual) with our partners to assist them in better designing school platforms.

For purpose of this Policy, “your Personal Information” as used in this Policy refers to Personal Information of you and/or any student you are responsible for, as the case may be.

B. How do we use your Personal Information

We acquire, hold, use, and process your Personal Information in order to provide, maintain and administer your sign-up information, to provide you with information on our education program/activities, to arrange campus visit, to arrange for assessment and interviews and other activities relating to the potential student’s enrolment or existing student’s participation in school program/activities, based on your Personal Information and based on your explicit consent and for the legitimate operation purposes outlined in this Policy.

a) Use for our administrative purpose

We also may use your Personal Information for our administrative purposes, such as to ensure normal school operation in terms of students management, measure interest in and/or develop this Website, ensure internal quality control, comply with regulatory requirements, including prevent potentially prohibited or illegal activities.

Operator may use your Personal Information for other purposes for which we have a legitimate interest, such as contacting you for any future education program/activities, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

b) Use of de-identified or anonymized information

Operator may use your Personal Information and other information about you to create anonymized and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our services, this Website, or other analysis we create related to our products and services. Anonymized and/or aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the products or services. Anonymized and aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Operator and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you or any student you are responsible for. We may use and disclose this anonymized, de-identified and/or aggregated information in any way permitted by applicable law.

C. Other rules for the collection and use of Personal Information

1. If the information you provide contains the Personal Information of other users, please ensure that you have obtained proper authorization before providing such Personal Information to this Website.

2. If we use your Personal Information for other purposes not specified in this Policy or use your Personal Information collected for a specific purpose to achieve other purposes, your consent will be obtained in advance.

3. If we collect your Personal Information indirectly from a third party, we will use our best efforts to ensure such third party acts in compliance with the applicable laws and regulations when collecting such Personal Information. We will use protection measures no less than those measures we apply to protect our own user's Personal Information to protect your Personal Information obtained indirectly from a third party.

4. If we cease our business operation, we will cease collecting your Personal Information promptly, and delete or anonymize the Personal Information we possess related to the operation ceased.

D. How do we share and transfer your Personal Information

We will not share or transfer your Personal Information with companies, organizations, and individuals other than Operator, except in the following cases:

a) Sharing information with our strategic alliance partner

After obtaining your separate consent, we may share your Personal Information to our strategic alliance partner to analyze your situation and needs, provide information you need, produce analysis reports and support the Nuo De An Da bilingual schools in optimizing school marketing and admissions activities as well as their daily operation.

When obtaining your separate consent above, we will provide you with name of our strategic alliance partner, processing method to be used and the type of personal information shared. We will also provide you with the contact information of our strategic alliance partner for you to access, correct, update or request removal of any of your Personal Information that has been transmitted to our strategic alliance partner, or exercise your other rights in terms of your Personal Information as provided in this Policy, or raise any question regarding the transmission and storage of your Personal Information or request more information relating to the above.

b) Share with or transfer to third party your Personal Information

We may only transfer your Personal Information to or share your Personal Information with, third parties after obtaining your separate consent.

c) Exception

Where merger, acquisition or bankruptcy liquidation, or other situations involving mergers, acquisitions, or bankruptcy liquidation occurs for the Operator, and the Personal Information is therefore transferred, we will request the company or organization possessing your Personal Information to be sequentially bound by this Policy and inform you of the name and contacts of such company or organization in a timely manner. Otherwise, we will request such company or organization to obtain your consent again.

E. How may we sub-contract processing of your personal information

We may authorize partners, such as vendors and service providers, to process data on our behalf. In such case, we will provide your Personal Information only for the legitimate, justified, necessary, specified, and explicit purpose stated in this Policy to support your participation or potential participation in our education program/activities and to permit us to provide services related to those activities. The types of service providers to whom we entrust Personal Information include, but are not limited to, service providers for: (i) provision of IT and school operation related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) students enrollment related activities; and (v) in connection with the provision of this Website. Operator has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

F. How may we disclose your Personal Information

We will only disclose your Personal Information in the following cases:

With your explicit consent, we may disclose your Personal Information to public

If we determine that you have violated applicable laws and regulations or seriously violated the relevant agreements and rules of this Website (if any), or to protect the personal and property safety of this Website users or the public from infringement, we may disclose your Personal Information (including the relevant violations and measure taken by this Website against you) in accordance with and to the extent permitted by, applicable laws or regulations.

G. Exceptions to prior consent for processing Personal Information

Under the applicable laws and regulations, we may process your Personal Information without obtaining your prior consent in the following circumstance:

Related to our fulfillment of obligations under laws and regulations

Directly related to national security and national defense security

Directly related to public safety, public health, and major public interests

Directly related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and enforcement of judgments

To protect your or other individuals’ substantial legal rights and interests such as life and property where it is difficult to obtain your consent

Your Personal Information is disclosed to the public on your own

Personal Information collected from the public domain such as news reports, government information disclosure and other channels

Necessary for signing and fulfilling relevant agreements or other written documents with you

Other circumstances stipulated by applicable laws and regulations

You may wish to note, under applicable laws, in the case that we take technical measures and other necessary measures to process Personal Information so that the data recipient cannot restore and re-identify specific individuals, there is no need for us to obtain your consent separately before sharing, transferring, and publicly disclosing such data.

For avoidance of doubt, processing of personal information in this section includes the collection, storage, use, processing, transmission, provision, disclosure and deletion, etc. of personal information.

H. How may we protect your Personal Information

Protection for you as our user is essential to our business. Maintaining a secure network and server system is in the best interests of our users and our partners. We process and store your Personal Information using industry standard physical, technical, and administrative safeguards to secure such Personal Information against foreseeable risks such as unauthorized use, access, disclosure, destruction, and modification. While we will use reasonable efforts to create a secure, safe, and reliable Website, the confidentiality of any communication or material transmitted to or from this Website over the internet cannot be guaranteed.

We have complied with applicable laws and regulations and taken appropriate and necessary measures required by laws and regulations for purpose of data security.

The security of your Personal Information is also, in part, your responsibility. We do not accept liability for unintentional disclosure.

I. How may we store your Personal Information

The information you provide to us may be archived or stored periodically by us according to backup processes and will only be retained for as long as is required for the purposes for which it was collected, to provide our products and services to you, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

J. International Transfers

After obtaining your separate consent and fulfilling the obligations as required by law we may share your Personal Information with overseas entities, which includes but not limited to store any Personal Information we receive from you on our servers located outside China.

You should be aware that not all countries offer the same standards of data protection and personal information privacy as those that may apply where you reside. However, your Personal Information will always be treated and used by us in accordance with this Policy.

K. Access, correction, deletion, and removal of Personal Information

You may contact us through the contact information posted on the main page of the Website to:

access, update, correct or remove your Personal Information you have provided to us. 

ask us to provide you with information about and copies of your Personal Information that we keep.

address any concern of your Personal Information or ask questions or provide comments about privacy. In such case, please include your contact information, the name of this Website or service at issue, and a detailed description of your request or privacy concern.

ask questions regarding this Policy or request more information on our privacy practices.

file complaints regarding this Policy or its implementation. 

Please Note:

Although we make good faith efforts to provide users with access to their Personal Information, there may be circumstances in which we are unable to provide access or delete certain information, including but not limited to where the information: contains legally privileged information, must be maintained according to law, would compromise others’ privacy, mandatory/necessary information required for receiving education or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Non-identifiable information in our databases will not be deleted. Like all responsible website, we maintain backup files as a protection against natural disasters, equipment failures, or other disruptions. Backup files protect you and us because they lessen the risk of loss of valuable data. Removing a record from our principal files does not remove that record from any of the backup systems. It may take up to 6 months before all information in a backup record is completely erased through the normal recycling of backup files. In the meantime, as long as backup records exist, they receive the same privacy and security protections as our other records.

All requests received from you under this Policy will be processed in line with applicable local laws.

a) Your Choices

You can always choose not to provide information. However, if you choose not to provide information, you will not be able to use any of the services that require you to sign up or apply for.

Where you have consented to our processing of your Personal Information, you may withdraw that consent at any time and opt out of further processing by following the instructions in this Policy. This will not have an impact on the information that has been collected, used or disclosed previously. Even if you opt out, we may still collect and use non-personal information regarding your activities on our website.

You can change the scope of your consent to collect and process your Personal Information. However, please note that for some categories of Personal Information, such as information necessary to realize the basic functions of this Website or information necessary for us to fulfill our obligations under laws and regulations, we may not be able to respond to your request to change the scope of consent.

You can request to delete your sign-up information.

Important Note: If you desire to correct, amend or delete your Personal Information that was provided to us by third parties (and not directly by you), you may contact us to access, correct, or remove your information from our files. However, we also recommend that you contact the third-party website operators or other entities to whom you have provided such information under such third parties’ privacy policies, as we do not control and are not responsible for those practices or privacy policies.

b) Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

c) Responding to your requests

To protect the security of your account, when you make the above request to us, we may first request you to verify your identity (such as asking you to provide a request in writing or other means) before processing your request.

We will respond to the above request you made within a reasonable time.

For your reasonable request, we will not charge fees in principle. However, for repeated requests of which the frequency exceeds reasonable limits, we will charge a certain fee as appropriate. We may refuse requests for information that is not directly related to your identity, request for unreasonable repeated information, or request requiring excessive technical means (for example, need to develop a new system or change existing practices fundamentally), or request bringing risks to the legitimate rights and interests of others, or unrealistic request.

L. How may we deal with Personal Information of minors

Protecting the privacy of minors is especially important. This Website is not intended for or designed to attract minors. Users under the age of 18 or the age of legal majority in their country should not submit information to this Website. If a child has provided us with Personal Information, the parent or guardian of that child should contact us if they want this information deleted from our files.

M. Links to Other Websites

This Website may contain links to other third-party websites. You should carefully review the privacy policies or notices and practices of other websites, as we cannot control or be responsible for their privacy policies, notices, or practices. For links to other company web properties, please review those privacy terms as well as they may differ from those on this Website.

N. Notification of Changes

As we provide more information and services on this Website and as privacy laws and regulations change, we may need to revise or update this Policy from time to time. We will always change the "Last Updated" date on this Policy to reflect when it was last revised. However, we will always continue to protect your Personal Information according to the law and as described by our current Policy.

Additionally, before we use your Personal Information for any new purpose not originally consented to by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where your consent for the processing of your Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.

This Privacy Policy was last updated on November 1st, 2021.