1. Introduction
This Privacy Policy (hereinafter referred to as the "Policy") governs the collection, use, storage, disclosure, and protection of users' personal information by Jiangsu Yuwell POCTech Biotechnology Co., Ltd.(hereinafter referred to as "we", "us", or "the Company") through its official website (hereinafter referred to as the "Website"). We attach great importance to user privacy and data security, and commit to strictly complying with the personal information protection laws and regulations applicable in the user's jurisdiction (including but not limited to the EU General Data Protection Regulation (GDPR), Singapore's personal data protection laws, and corresponding privacy protection regulations in other jurisdictions) to effectively safeguard users' legitimate rights and interests.
Your access to, browsing of, or use of the Website and related services constitutes your full reading, understanding, and voluntary acceptance of all terms of this Policy, including our operations such as the collection, use, and storage of personal information. If you do not agree to the content of this Policy, please do not use the Website or related services.
2. Collection of Personal Information
2.1 Types of Information Collected
To provide you with highquality product information inquiry, health data management, and related service support, we may collect the following types of personal information:
1) Basic contact information: Including email addresses, phone numbers, and other contact details voluntarily provided by you for communication purposes;
2) Device and usage information: Technical data such as device model, operating system, browser type, IP address, browsing history, access time, and page stay duration when you access the Website. Such information will help us optimize website performance and user experience;
3) Healthrelated information: Blood glucose monitoring data (such as blood glucose values, Time in Range (TIR), average blood glucose levels, etc.), dietary records, exercise information, medication status, and other health managementrelated data actively uploaded or shared by you through the relevant functions of the Website;
4) Other information: Other legal and compliant personal information voluntarily provided by you during the process of consultation, feedback, service application, etc.
2.2 Methods of Collection
Voluntary provision: Personal information actively filled in and submitted by you when submitting consultations, applying for services, or participating in relevant activities on the Website;
Automatic collection: Recording relevant technical data of your access to the Website through Cookies and similar tracking technologies. You may manage or disable Cookies through browser settings, but some website functions may be affected and cannot be used normally as a result.
3. Use of Personal Information
We will use the collected personal information for the following legitimate purposes in strict accordance with the personal information protection laws and regulations applicable in the user's jurisdiction:
1) Provision and maintenance of services: Including providing core services such as product information inquiry, health data recording and analysis, generation of professional health reports, and realization of realtime mobile connectivity;
2) Optimization of products and services: Analyzing user behavior and health data (on the premise of anonymization and deidentification) to improve the quality of products;
3) Communication and service support: Responding to your consultations, complaints, and suggestions, providing technical support, and pushing information related to product updates, service upgrades, and health popularization to you with your explicit consent;
4) Compliance and security assurance: Complying with applicable laws, regulations, and regulatory requirements, preventing, identifying, and responding to fraud and security risks, and ensuring the operational security of the Website and the legitimate rights and interests of users.
4. Storage of Personal Information
4.1 Storage Location
We will assign data storage locations based on the user's actual place of residence:
1) If you are a user located within the European Union (EU), your personal information will be stored on servers within the EU that meet local data protection standards;
2) If you are a user located in Singapore, your personal information will be stored on compliant servers set up in Singapore;
3) For users in other regions, personal information will be stored on servers that comply with the personal information protection regulations of that region, ensuring that data storage meets local legal requirements.
4.2 Storage Period
We will only store your personal information for a reasonable period necessary to achieve the purposes stated in this Policy, or in accordance with the minimum storage period required by relevant laws and regulations. After the expiration of the above period, we will dispose of your personal information in a safe and reliable manner (such as encrypted deletion, anonymization, etc.) to prevent unauthorized access or abuse.
5. Disclosure and Transfer of Personal Information
Without your explicit written consent, we will not disclose or transfer your personal information to any third party, except in the following legal or agreed circumstances:
1) Transfer to our affiliated companies (such as Yuwell Group), provided that the affiliated company has undertaken to comply with this Policy and relevant privacy protection laws and only uses the information for the purpose of providing services or optimizing products;
2) Disclosure to strictly screened service providers (such as server hosting providers, technical support service providers, etc.). Such service providers may only process personal information within the authorized scope and shall assume corresponding confidentiality and security obligations;
3) To comply with applicable laws, regulations, judicial judgments, arbitral awards, or administrative regulatory requirements, or to protect the legitimate rights and interests of us, users, and the public from infringement;
Due to the need for commercial transactions such as company merger, acquisition, or asset sale, personal information may be transferred as part of the transaction assets. We will notify you in advance and ensure that the transferee continues to comply with this Policy and relevant privacy protection regulations.
6. Your Rights
In accordance with the personal information protection laws and regulations applicable in your jurisdiction, you have the following rights with respect to your personal information (the specific scope of rights shall be subject to the provisions of local laws):
1) Right of access: The right to inquire about the personal information we hold about you and the relevant processing status;
2) Right of rectification: The right to request us to correct inaccurate or incomplete personal information;
3) Right to erasure ("right to be forgotten"): The right to request us to delete your personal information in circumstances stipulated by law;
4) Right to restriction of processing: The right to request us to restrict the processing of your personal information in specific circumstances;
5) Right to data portability: The right to request us to provide your personal information in a structured, commonly used, and machinereadable format, and to transmit it to other compliant data processors;
6) Right to object: The right to object to specific processing of your personal information on legitimate grounds;
7) Right to withdraw consent: If you have previously consented to our processing of your personal information, you have the right to withdraw such consent at any time. The withdrawal of consent shall not affect the validity of information processing conducted based on legal consent prior to the withdrawal;
8) Right to complain and report: If you believe that our personal information processing activities violate relevant laws and regulations, you have the right to complain and report to the regulatory authorities.
To exercise the above rights, please contact us through the contact information provided at the end of this Policy. We will verify your identity within a reasonable period stipulated by law and respond to your request in accordance with the law.
7. Security Measures
We have established a sound data security management system and adopted technical and organizational security measures that meet industry standards to protect your personal information from unauthorized access, use, disclosure, modification, damage, or loss:
1) Technical level: Encrypted storage and transmission of sensitive data, deployment of access control mechanisms, and regular security vulnerability scanning and penetration testing;
2) Management level: Establishment of strict data access permission systems, training and assessment of employees on privacy protection, and formulation of emergency response plans for data security incidents.
Please note that both Internet transmission and electronic storage methods carry certain security risks, and we cannot guarantee the absolute security of personal information. In the event of a data security incident, we will promptly notify you in accordance with the requirements of relevant laws and regulations and take necessary remedial measures.
8. Changes to the Policy
We may revise this Policy in accordance with updates to laws and regulations, business development needs, or service adjustments. The revised Policy will be publicly posted in a prominent position on the Website, with the effective date indicated.
In case of material changes to this Policy (including but not limited to adjustments to core content such as the scope of personal information collection, purposes of use, storage methods, and methods of exercising rights), we will notify you in a reasonable manner. Your continued use of the Website and related services constitutes your acceptance of the revised Policy. We recommend that you review this Policy regularly to stay informed of the latest developments.
9. Contact Us
If you have any questions, suggestions, or complaints about this Policy, or need to exercise relevant rights, please contact us through the following methods:
Email: privacy@yuwell-poctech.com