ViVest Management Platform Privacy Policy

Updated on: October 25, 2023

Effective Date: October 25, 2023

Your trust is very important to us. Suzhou ViVest Medical Technology Co., Ltd. hereinafter referred to as “we”, “us” or “ViVest” attaches great importance to your privacy. We will take appropriate security protection measures in accordance with applicable laws and regulations, and make every effort to protect the security and controllability of your personal information.

In view of this, we have formulated the ViVest Management Platform Privacy Policy hereinafter referred to as “this Policy” or “this Privacy Policy”. This Policy applies to all products and services provided by ViVest. Before using any ViVest products or services, please carefully read and fully understand this Policy, and start using such products or services only after you have fully understood and agreed to this Policy.

I. Definitions

Personal Information: Refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person, either alone or in combination with other information, or reflect the activities of a specific natural person.

Sensitive Personal Information: Refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety, or may easily cause damage to personal reputation, physical and mental health, or discriminatory treatment. Generally, the personal information of children under the age of 14, including 14 years old, and information involving the privacy of natural persons are considered sensitive personal information. Specific sensitive personal information will be prominently marked in bold in this Privacy Policy.

Deletion of Personal Information: Refers to the act of removing personal information from the systems involved in daily business functions, so that such personal information remains in a state where it cannot be retrieved or accessed.

Personal Information Subject: Refers to the natural person identified by the personal information.

Anonymization: Refers to the process of technically processing personal information so that the personal information subject cannot be identified or associated, and the processed information cannot be restored. Information obtained after anonymization of personal information is not personal information.

De-identification: Refers to the process of technically processing personal information so that the personal information subject cannot be identified or associated without the use of additional information.

II. Privacy Policy

1. How We Collect and Use Your Personal Information

When you use the ViVest ViNet-100 ECG Data Management System, we will collect the personal information that you actively provide during use or that is generated as a result of your use in the following ways, in order to provide services to you and optimize our services. To ensure the normal operation of our services and to support your normal use, we will collect the following information:

Collected Information Functional Purpose Usage Scenario
Name, mobile phone number, email address, login password To support two-factor login, including one dynamic verification factor and one static verification factor, for verifying the user's identity and protecting the security of the user's account. System login

2. How We Share, Transfer and Publicly Disclose Your Personal Information

2.1 Sharing

We will not share your personal information with any company, organization or individual other than ViVest and its affiliates, except in the following circumstances:

2.1.1 Sharing with Explicit Consent: After obtaining your explicit consent, we will share your personal information with other parties.

2.1.2 We may share your personal information externally in accordance with laws and regulations, or in response to mandatory requirements from competent government authorities. For companies, organizations and individuals with whom we share personal information, we will enter into strict confidentiality agreements with them and require them to process personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

2.2 Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

2.2.1 Transfer with Explicit Consent: After obtaining your explicit consent, we will transfer your personal information to other parties.

2.2.2 We may transfer your personal information to comply with laws and regulations, mandatory government requirements, or judicial rulings.

2.3 Public Disclosure

We will publicly disclose your personal information only in the following circumstances:

2.3.1 After obtaining your explicit consent, we will disclose your personal information in a specified manner.

2.3.2 Disclosure Based on Law: We may publicly disclose your personal information where required by law, legal procedures, litigation, or mandatory requirements from competent government authorities.

3. How We Protect Your Personal Information

3.1 Protection Mechanisms

We have adopted security protection measures that comply with industry standards to protect the personal information you provide, and to prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We will use trusted protection mechanisms to prevent malicious attacks on data.

3.2 Information Collection and Storage

We will take all reasonable and practicable measures to ensure that irrelevant personal information is not collected. We will retain your personal information only for the period necessary to achieve the purposes described in this Policy, unless there are mandatory retention requirements under applicable laws. After your personal information exceeds the retention period, we will delete your personal information, or anonymize or de-identify it, in accordance with the requirements of applicable laws.

3.3 Emergency Response

The internet environment is not 100% secure, and we will make every effort to ensure or guarantee the security of any information you send to us. In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you.

We will promptly notify you of the relevant circumstances of the incident by email, letter, telephone, push notification or other means. Where it is difficult to notify personal information subjects individually, we will publish an announcement or notify your enterprise in a reasonable and effective manner. At the same time, we will also proactively report the handling of the personal information security incident to the regulatory authorities in accordance with their requirements.

4. Your Rights

In accordance with relevant Chinese laws, regulations and standards, as well as common practices in other countries and regions, we protect your rights to exercise the following rights with respect to your personal information:

4.1 Access to Your Personal Information

You have the right to access your personal information, except where otherwise provided by laws and regulations.

4.2 Correction of Your Personal Information

When you find that the personal information we process about you is incorrect, you have the right to make corrections yourself or request us to make corrections.

4.3 Deletion of Your Personal Information

You may request us to delete your personal information in the following circumstances:

4.4 Account Cancellation

Subject to the requirements of relevant laws and regulations, you may apply to cancel your account through the contact information provided in this Policy.

5. Protection of Minors

The ViNet-100 ECG Data Management System is authorized only for use by persons who have reached the legal age, and does not involve registration or use by minors.

6. Third-Party Services

When you use the “Login” function, we need to collect your mobile phone number and email address for receiving SMS messages and verification code notifications. The SMS service is technically supported by the cloud SMS service provided by Alibaba Cloud Computing (Beijing) Co., Ltd., and the email verification code service is provided by Shenzhen Tencent Computer Systems Co., Ltd.

7. Storage of Personal Information

All personal information collected and generated within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China.

8. How This Policy Is Updated

Our Privacy Policy may be revised from time to time. If such changes result in a material reduction of your rights under this Policy, we will notify you before the changes take effect by email and/or internal message and/or push notification.

9. Contact Information

If you have any questions, comments or suggestions regarding this Policy, you may contact us through the following methods:

Email: security@vivest.cn

Telephone: 0512-65730937

Address: ViVest Medical, 5th Floor, Building 2, Zone B, Phase V, Biomedical Industrial Park, No. 21 Dongyanli Road, Suzhou Industrial Park, Suzhou Area of China (Jiangsu) Pilot Free Trade Zone, China