Privacy Policy-MicroTech Medical Inc.

Privacy Statement

INTRODUCTION

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

This Privacy Statement explains how personal data that we collect about you, through this Microtech website operated by 【MicroTech Medical (Hangzhou) Co., Ltd.】(hereinafter referred to as "Microtech", "we" or "our") based in the People's Republic of China ("China") as well as any mobile sites, applications ("apps"), widgets, conferences, events, electronic newsletters, communications or other services (collectively "Services") that link to this Privacy Statement, is handled, in particular how it is used, stored and protected, as well as the rights to which data subjects are entitled.

We intend to process your information in a manner that is fair and in line with your expectations and encourage you to read and consider the information provided in this Privacy Statement to confirm that is the case.

Once you start to use this Microtech website and Microtech Services, you mean you have fully understood and agreed this Privacy Statement and we will process your information in accordance with this Privacy Statement.

Please note that for purpose of this Privacy Statement, by using this Microtech website and Microtech Services or submitting your sensitive personal information to us, you mean you have fully understood and agreed that we may process your sensitive personal information.

Please note that for purpose of this Privacy Statement, by using this Microtech website and Microtech Services or submitting your personal information to us, you mean you have fully understood and agreed that we may share, transfer, or disclose your personal information.

Please note that for purpose of this Privacy Statement, by using this Microtech website and Microtech Services or submitting your personal information to us, you mean you have fully understood and agreed that we may transmit your personal information to other countries.

Refusal on providing consent might affect you use related Services, but will not affect you use other Services we provided.

Scope

This Privacy Statement applies to data processing activities in China, since this Microtech website are designed for providing Services in China and process data of domestic data subjects. Processing, in this Privacy Statement, refers to collecting, using, storing, processing, transmitting, providing, disclosing, or deleting.

This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies, nor does it apply to other Microtech websites, including websites operated by other Microtech affiliates, including Hangzhou Microtech Medical Electronics Co., Ltd. .

This Privacy Statement also does not apply to data processing activities specifically relating to current or former Microtech employees or applicants. The relevant Employee Privacy Statement or Applicant Privacy Statement may be requested by contacting 【*】.

This Privacy Statement also does not apply to data processing activities in context of pharmacovigilance-related activities, medical information enquiries and product complaints handling related to Microtech products.

Please note that this Privacy Statement does not apply to the information collect by accessing third-party websites or services through the services provided by MicroTech. If you decide to access a third-party website or service, you are subject to the personal information protection policy of such the third-party website or service rather than this Privacy Statement. We encourage you to carefully read the personal information protection policy and other legal statements of every website or service you visit.

This Privacy Statement will help you further understand the following specific contents:

What information do we collect about you?
How we use personal information?
How we share, entrust processing, transfer and publicly disclose your personal information?
Do we transfer personal information to other countries?
How we protect your personal information?
Your rights
How long will we keep your personal information for?
What happens if the Privacy Statement changes?
What about third-party links?
Are there special rules about children's privacy?
How to contact Microtech?

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The information we receive, collect and how we use it, depends on what you operate when visiting our website or using our Services. We collect and use non-personal information (information that does not identify you personally) differently to your personal information.

1.1 YOUR PERSONAL INFORMATION

Personal information refers to information related to an identified or identifiable natural person that is recorded electronically or otherwise, excluding anonymized information, such as your:

first and last name
address, telephone number, e-mail address or other contact information
medical device serial number
personal health information
date of birth or age
social media username or profile
interests and qualifications
IP (Internet Protocol) address when such address is associated with a specific user

We collect personal information about you in the following ways.

Information we collect directly from you.

Microtech use your personal information to perform the following functions to achieve purposes presented in the section of "HOW WE USE PERSONAL INFORMATION?".

Account registration. When you fill out a registration form for a particular service, participate in a survey, or complete a contact form, we will collect 【your name, phone number, and… information】.
Contact Forms: Websites may have contact forms where users are asked to submit personal information, such as names, email addresses, and phone numbers, for inquiries or feedback.
Solve service issues. When you contact us to solve any consumer and/or product or service issues, we will collect 【our name,… information】.
Help contract issues. When you enter into, or perform a contract with you (e.g. in case you wish to order products or services from us), we will collect 【your name, … information】.
Participate in online communities. When you participate in our online communities, including social media and blogs, we will collect 【your name, email address, and… information】.
Promote activities. When you are contacted by us with information that might be of interest to you (see further the Marketing and Education section below), we will collect 【your name, email address, and… information】.
Cookies and Tracking Technologies: Websites use cookies and other tracking technologies to collect data about user behavior,preferences, and browsing habits.
Location Data: Some websites request permission to access the user's location for location-based services or personalized content.

Microtech may also use your personal information to the extent necessary to perform the following activities, in order to achieve purposes presented in the section of "HOW WE USE PERSONAL INFORMATION? ".

Service Provision: Personal data is often collected to provide the services requested by users. For example, if a user creates an account on a website, their personal data may be used to customize and enhance their experience on that platform.

Communication: Organizations may use personal data to communicate with users. This could include sending transactional emails, updates, newsletters, or other relevant information.

Improving Services: Collected data can be used to analyze user behavior and preferences, helping organizations improve their products or services. This data may be anonymized or aggregated to protect individual privacy.

Personalization: Personal data can be used to tailor content and recommendations to individual users based on their preferences, behaviors, and demographics.

Marketing and Advertising: Organizations may use personal data to create targeted marketing campaigns or personalized advertisements. This can involve analyzing user preferences to deliver more relevant content.

Information we collect automatically.

We may automatically collect the following information about your use of Microtech website or Services through cookies: the type of web browser software you use (for example, Internet Explorer); the name of the domain from which you access the Internet; the Internet address of the website from which you linked directly to our website; the date and time you access our website; which pages you have visited on our website; the search terms you use; the links on which you click.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.

1.2 WHAT IS SENSITIVE INFORMATION?

Some types of personal information are sensitive information. Sensitive personal information means personal information that, once leaked or illegally used, may easily cause harm to the dignity of natural persons or grave harm to personal or property security, including information on biometric characteristics, religious beliefs, specially-designated status, medical health, financial accounts, individual location tracking, etc., as well as the personal information of minors under the age of 14.

1.3 WILL Microtech TREAT SENSITIVE INFORMATION DIFFERENTLY TO OTHER PERSONAL INFORMATION?

Microtech will only collect and process your sensitive personal information where there is a specific purpose and a need to fulfill, and under circumstances of strict protection measures. To process sensitive personal information, your separate consent shall be obtained.

We collect personal sensitive information about our users in the following ways.

Account registration. When you fill out a registration form for a particular service, participate in a survey, or complete a contact form, we will collect 【your name, phone number, and… information】.
Contact Forms: Websites may have contact forms where users are asked to submit personal information, such as names, email addresses, and phone numbers, for inquiries or feedback.
Solve service issues. When you contact us to solve any consumer and/or product or service issues, we will collect 【your name,… information】.
Help contract issues. When you enter into, or perform a contract with you (e.g. in case you wish to order products or services from us), we will collect 【your name, … information】.
Participate in online communities. When you participate in our online communities, including social media and blogs, we will collect 【your name, email address, and… information】.
Promote activities. When you are contacted by us with information that might be of interest to you (see further the Marketing and Education section below), we will collect 【your name, email address, and… information】.

1.4 NON-PERSONAL INFORMATION

Non-personal information is information that cannot identify you or be tied to you in any way. Therefore, the non-personal information that we collect through this website does not identify you as an individual person, and will not be linked to you. It may include information such as the following:

the type of web browser software you use (for example, Internet Explorer)
the name of the domain from which you access the Internet
the Internet address of the website from which you linked directly to our website
the date and time you access our website
which pages you have visited on our website
the search terms you use
the links on which you click

If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information from your computer. This information is collected from your computer's web browser. If you only read or simply click to download information on our website, we do not collect or learn your name, e-mail address, home address, or any other personal information about you. For more information about how we use cookies to collect information about visitors to our website, please click here.

1.5 WHAT DOES Microtech DO WITH NON-PERSONAL INFORMATION?

We are always looking for ways to better serve you and improve our products, services and website experience. We will use non-personal information from you to make this website more useful to visitors. We may also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:

create reports for internal use to develop programs, products, services or content
adapt or improve the information or services provided
share or sell information to third parties
provide information on how our site is used, such as "traffic statistics" and "response rates" to third parties

1.6 Exceptions to obtaining consent

However, as permitted by applicable laws, we will process your personal information without your consent under the following circumstances.

Where it is necessary for the conclusion or performance of a contract to which you are a party.
Where it is necessary for us to perform the statutory duties or statutory obligations applicable to us.
Where it is necessary for coping with public health emergencies or for the protection of the life and health of a natural person, or the safety of property.
Where such acts as news reporting and media supervision are carried out for the public interest, and the processing of Personal Information is within a reasonable scope.
Where the personal information disclosed by you or other legally disclosed Personal Information is processed within a reasonable scope in accordance with the provisions of the Personal Information Protection Law.
Other circumstances provided by laws and administrative regulations.

2. HOW WE USE PERSONAL INFORMATION?

We use the information that you have shared with us through this website and relevant Services (other than sensitive information, which is represented separately above) for the following purposes.

To allow you to register certain products or services, or enhance their functionality when you fill out a registration form for the service.
To resolve and track the status of any consumer and/or product or service issues when you contact us to solve any consumer and/or product or service issues.
To enter into, or perform a contract with us when you have such wish to order products or services from us.
To enable you to participate in our online communities, including social media and blogs.
To contact you with information that might be of interest to you – see further the Marketing and Education section below.
In other ways to which you consent.

Microtech may also use your personal information to the extent necessary to achieve the following purposes, so long as compatible with your rights and expectations of privacy.

For analytical purposes in order to research, develop and improve programs, products, services and content.
To allow you to create a Microtech online account. The information you provide may be used for the purposes of (i) setting up, administering and securing your account, (ii) managing password restoration and renewal and (iii) account usage. Given the scope and variety of Microtech online services that allow the creation of online user accounts, the purposes for which Microtech will use your personal information may depend on the nature of the account and why the account was established. Therefore, Microtech’s ability to use your personal information is additionally subject to the terms and conditions accessible through the account login page. For more specific information on the account usage purposes, please note that a more detailed privacy statement may be available and describe such purposes further.
To anonymize your information by removing any personal identifiers (your name, e-mail address, social security number, etc.) so that it may be used for other purposes. In this case, the anonymized information would no longer identify you and may be treated like other non-personal information. For more details please see the relevant section below.
To enforce this Privacy Statement and other rules about your use of this website.
To protect our rights or property.

Where required by applicable laws, we will ask you to "opt-in" or affirmatively consent to the processing of your personal data for a particular purpose. For example, where applicable laws so requires, we will only send you newsletters if you have subscribed to them.

2.1 DIRECT MARKETING AND EDUCATIONAL MATERIALS

M icrotech may provide you with educational materials or other information about our products and Services, as well as information about clinical trials or the products and services of others that might be of interest to you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of Microtech websites and Services.

For the personal information we collect, please see the WHAT INFORMATION DO WE COLLECT ABOUT YOU? section above.

We will ask you to " Subscribe" or affirmatively consent to the use of your personal information for the purposes of such communications, in accordance with applicable laws.

If at any time you decide not to receive any educational, commercial or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at the contact details listed below and mention "Unsubscribe" in the subject of your email. Alternatively, you may use the opt-out procedure provided in any relevant message you receive from us.

Please note that if you opt not to receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that Microtech is required by law to provide, e.g. regarding product recalls.

2.2 SURVEYS

From time to time, we may invite you to participate in a survey to determine customer satisfaction levels, identify areas of potential improvement or to carry out market research. We may send you a specific invite to participate in such a survey on the basis of our legitimate interests in conducting the survey, or on the basis of your prior "opt-in" consent to receive such communications, in accordance with applicable laws. You may opt-out of receiving any such future communications in the manner detailed in the section above.

The personal information that is collected for the purpose of the survey may include your email address, phone number, survey results, and any free-text message you may have written in the survey. For the personal information we collect, please see the WHAT INFORMATION DO WE COLLECT ABOUT YOU? section above.

We process your personal information as part of the survey for carefully considered and specific business purposes which are in our legitimate interests and which we believe also often benefit you, based on our assessment that our legitimate interests do not override your freedom and data protection rights.

The business purpose of collecting your data is to reply to survey feedback you may have provided, specifically:

Should you have indicated an issue which we need to take action to resolve
In order to gain further insight to the experience you have described
To inform you of any action we might take internally to resolve your issue or enhance your experience

3. HOW WE SHARE, ENTRUST PROCESSING, TRANSFER AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION?

3.1 Share AND Entrusted Processing

Microtech will not share your personal information with a third-party except as described in this Privacy Statement.

In the ordinary course of business, we may share some personal information with Microtech affiliates or third party companies that we hire to perform services or functions on our behalf as follows.

Consent. Where you have provided consent, we share your information, including personal information, as described at the time of consent.
Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. We may

use different vendors or suppliers to ship your products that you order on our website. In these cases, we provide the vendor with information to process your order including your name and mailing address.
use a service provider to administer certain newsletter or informational mailings that you have signed up for, and provide access to your email address for this purpose.
use a third-party application or platform to allow us to manage and keep track of our communications with you.
use a third-party application or platform to conduct surveys, which can include storage of the survey feedback.
share aggregate or de-identified information about users and their use of the Services with third parties and publicly for marketing, advertising, research, medical education, or similar purposes.

Our Affiliates. We may disclose the information we collect from you to our company affiliates to provide services relating to your personal information e.g. we may store your information on a secure server based at our affiliate’s site in Europe or the United States. If we do so, their use and disclosure of your personal information will be maintained by such affiliates and subsidiaries in accordance with this Privacy Statement. For more information on the circumstances in which we may transfer your information to other countries, please see the DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES? section below.
Statutory circumstances. We will share your personal information with the third party where your personal information is required to be shared in accordance with applicable laws, legal procedures, litigation/arbitration, government orders, requirements of supervisory authorities.

In all cases, we will not share more information than is necessary. Subject to applicable laws, we will seek separate consent (if legally required) from you and notify you of the data sharing with the third parties, including the data recipient’s identity, contact information, purpose of processing, method of processing and the type of personal information.

Companies, organizations and individuals with whom we entrust the processing of personal information are bound by strict confidentiality agreements. They are required to process personal information in accordance with our requirements, this Privacy Statement and any other relevant confidentiality and security measures.

3.2 TRANSFER

Without your consent, we will not transfer your personal information to any other company, organization or individual, except in the case of business/asset transfer, restructure, disposal, merger, spin-off or acquisition transactions where the transfer is necessary. In such cases, we will inform you of the identity and contact method of the personal information recipient as per applicable laws as well as request said recipient to comply with this Privacy Statement. If the personal information recipient changes the purposes and methods of personal information processing activities under this Privacy Statement, it shall re-obtain the consent from you.

3.3 Public Disclosure

We will not disclose your personal information to the public unless we have your consent. However, please note that subject to applicable laws, we may disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or government request.

In addition, we may use and disclose your personal information to third parties if necessary to:

enforce this Privacy Statement and the other rules about your use of this website;
protect our rights or property;
protect someone's health, safety or welfare;
comply with a law or regulation, court order or other legal process;
investigate or take action in cases of suspected fraud or illegal activities.

In addition, please keep in mind that certain areas of our website may be interactive in nature, and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those sections of the website.

4. DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

In principle, the personal information we collect and generate within the territory of China will be stored in the territory of China.

As we provide products or services through our worldwide resources, with your consent, Microtech may transmit personal information collected on this website to our affiliates or third party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Statement.

In cases where personal information is transmitted from Europe to other countries we will seek your consent and ensure that safeguards equivalent to those provided by European data protection laws are in place.

5. HOW WE PROTECT YOUR PERSONAL INFORMATION?

Security is very important to us. We also understand that security is important to you. We use industry standard measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

For example:

We protect your personal information by taking such security measures as de-identification and encryption;

We have set up strict access controls such as identity authentication, authorization management and authority authentication to protect the safe use of your personal information;

However no website or email transmission is 100% secure and we encourage you to therefore take special care in deciding what information you send or request via email, and take appropriate precautions such as keeping any usernames and passwords you use confidential.

6. YOUR RIGHTS

At any time, you may exercise your right to access, rectify, correct and, supplement, delete, any personal information relating to you, or restrict the processing of your personal information, in compliance with applicable laws.

You can require MicroTech to explain our personal information processing rules.

You also have the right at any time to object, based on your particular situation, to any use or processing of your personal information which we have based on our legitimate interests.

In case we are processing your personal information in an automated manner as part of a service to you or based on your consent then you also have the right to request a copy of your information in a structured, commonly used and machine-readable format.

Such requests can be sent to 【globalmarketing@microtechmd.com *】 or in writing to

MicroTech Medical (Hangzhou) Co., Ltd.
No.108 Liuze St.,

Cangqian, Yuhang District,

Hangzhou 311121 Zhejiang,

People’s Republic of China

Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can comply with your request.

If we have based our collection or use of your personal information on your consent then you also have the right to withdraw your consent at any time in the same way as it was given, or by sending a request in the above manner.

You may also at any time, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and request to no longer receive any promotional material as described above.

In case you are not satisfied with our handling of your request you may contact the applicable Data Protection Authority.

7. HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only keep your personal information for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Statement. For example, if you tell us that you no longer wish to receive a newsletter from us, we will immediately delete your email address from our mailing list. In case you participate in a program via our website we will delete the personal information provided as part of that program within a reasonable time after its completion.

8. WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

This Privacy Statement was last revised on November, 2023. We may change this Privacy Statement at any time and for any reason. If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this Privacy Statement each time you visit the website.

9. WHAT ABOUT THIRD-PARTY LINKS?

T his website may contain links to other websites. Some of those websites may be operated by Microtech affiliates, and some may be operated by third parties. Any access to and use of such linked websites is not governed by this Privacy Statement, but instead is governed by the privacy policies of those third party websites. Therefore whenever you leave this website we recommend that you review the privacy practices that apply to information you provide on other websites. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. Neither are we are responsible for websites operated by third parties or your business dealings with them.

10. ARE THERE SPECIAL RULES ABOUT CHILDREN'S PRIVACY?

This website and Services are not designed for children under 14.

We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 14 without the consent of someone holding parental responsibility. If you think that we have otherwise collected personal information from someone under the age of 16, please Contact Us through our website or via the contact details listed in the Your Rights section above .

11. HOW TO CONTACT MICROTECH

If you have questions or comments about this Privacy Statement, please Contact Us through our website or via the contact details listed in the Your Rights section above.

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