Neusoft Medical-Personal Information and Privacy Protection Policy

Personal Information and Privacy Protection Policy

Neusoft Medical Systems Co., Ltd. (hereinafter referred to as "Neusoft Medical or us") greatly respects the protection of users' personal information and privacy. Neusoft Medical always complies with the laws and regulations on personal information and data protection formulated and issued by China, European Union and other relevant countries/regions (including Personal Information Protection Law of the People's Republic of China, Data Security Law of the People's Republic of China, General Data Protection Regulation of EU, etc). When you use the products and services provided by Neusoft Medical, we will protect your personal information and privacy according to the standards and measures set forth in this Personal Information and Privacy Protection Policy (hereinafter referred to as the "Policy"). This Policy contains provisions on our collection, storage, use, sharing and protection of your personal information. We hope to clearly introduce to you the way we handle your personal information through this Policy. Therefore, we suggest that you read this Policy completely to help you understand how to protect your privacy. Please read and understand this Policy carefully before you use our products and/or services. If you have any questions about this Policy, you can contact us through the contact information published in this Policy. By using our products or services, you have fully understood and agreed to what we have set out in this Policy. If you do not agree with all or part of this Policy, please stop using our products or services immediately. After we update this Policy, if you continue to use our products or services, you have fully understood and agreed to the updated content of this Policy.

1. Scope of application

It is Neusoft Medical's unremitting pursuit to provide users with better, superior and more personalized products and services. We also hope that our products and services can be more convenient for your daily operation. This Policy applies to all products and services provided by Neusoft Medical. This Policy also applies to all products and services provided by Neusoft Medical's websites (including but not limited to Neusoft Medical's official website and official wechat), online sales platforms, applications (apps), remote service platforms, telephone, email, offline activities and other channels) that are owned by, participated in or organized by Neusoft Medical or that have not yet established independent privacy policies. In particular, this Policy does not apply to products or services provided to you by other third parties.

2. Personal information we may collect

We will only collect the following types of your personal information (but not the anonymized information) through various legal channels for the purposes stated in this Policy. Some of the personal information we collect may be sensitive personal information. We will only process your sensitive personal information if there is a specific purpose and sufficient need to do so and strict protection measures are taken. When processing your sensitive personal information, we will obtain your individual consent. (1) Company name, company information, contact person, company license, telephone number, email, address; (2) Equipment information and related additional information; (3) name, sex, age or other proof of identity; (4) Personal health and physiological information (including medical image information, medical test reports, etc.); (5) The user name and password you may choose to set up an account on our website or application platform; (6) Information collected during activities or actions sponsored by us that you have participated in or participated in; (7) Other personal information necessary to provide relevant services to you.

3. The purpose for which we collect and use personal information

We will only collect and use your personal information for the following purposes. When we use your personal information for other purposes not set forth in this Policy, or use information collected for a specific purpose for other purposes, we will seek your prior consent as required by applicable law. (1) Provide services and support for your purchase and use of our products or services, including but not limited to providing installation and debugging services, customer after-sales services, remote service support, etc.; (2) To promote our products or services to you; (3) Contact you for business contact; (4) Compile statistical data, conduct internal audits, conduct data analysis and research, and improve products and services; (5) Academic training, academic research, clinical trials and other activities; (6) Verify your identity; (7) Maintain our online services; (8) To better understand the interests of the customers who use our services; (9) To provide security for you; (10) Comply with our legal and regulatory obligations, etc.

4. How do we collect information

4.1 We collect information in order to provide you with better, superior and more personalized products and services. We collect information in the following ways: (1) The information you provide to us; (2) information that allows us to collect from you or other sources; (3) Information automatically obtained from the equipment you use to connect to Neusoft Medical services; (4) Information collected during your use of the product or service; (5) The reply information you sent to us when you participated in the questionnaire survey; (6) Information collected by us during your interactions with Neusoft Medical's affiliated parties and partners. 4.2 Except under the above circumstances, we will collect and use your personal information only to the extent necessary to achieve the purpose set forth in this Policy, in accordance with the provisions of this Policy and in accordance with the principles of legality, legitimacy and necessity to the extent permitted by applicable laws. 4.3 We will try our best to avoid collecting and processing personal information that is not related to our business. We will not actively collect any personal information from you or any natural person from your channel. If the information you provide contains the personal information of natural persons, you need to ensure that you have obtained legal authorization. 4.4 All personal information provided by you during the use of our products or services will continue to be authorized by us for the duration of your use of our products or services unless you request to delete or restrict or refuse to be collected by us. 4.5 You acknowledge and understand that if you refuse to provide the information necessary to use the products or services, you will not be able to use the products or services, but this will not affect your use of other products or services. 4.6 We may obtain from third parties the personal information you authorize to share. We will, according to the agreement with the third party, confirm the legitimacy of the source of personal information, and on the premise of complying with relevant laws and regulations, use your personal information provided to us by the third party authorized by you. 4.7 We will not collect or use your personal information without your prior consent, except in the following cases: (1) necessary for the conclusion and performance of the contract to which you are a party; (2) necessary for the performance of statutory duties or obligations; (3) necessary for responding to public health emergencies or for protecting the life, health and property safety of natural persons under emergency circumstances; (4) conduct news reporting and supervision by public opinion for the public interest, and process personal information within a reasonable scope; (5) In accordance with the provisions of the reasonable scope of processing of your own or other legally disclosed personal information; (6) Other circumstances provided for by laws and administrative regulations.

5. How do we share, transfer and publicly disclose your personal information

5.1 Share We will not share your personal information without your express consent or authorization, except as described below or as stated at the time of collecting the information. (1) Sharing under legal circumstances: We may share your personal information according to the provisions of laws and regulations or the requirements of administrative or judicial institutions; (2) Share your personal information with Neusoft Medical's affiliates: We will only share necessary personal information in accordance with this policy for legal, legitimate, necessary, specific and explicit purposes; (3) Sharing with service providers or partners: We may share your personal information with our service providers or partners for the purpose of external processing and to provide you with products or services. However, we will only share your personal information necessary to provide products or services in accordance with this policy for legal, legitimate, necessary, specific and explicit purposes. Our service providers or partners have no right to use the personal information we share for any other purpose. In the case of item (2)(3) above, we will seek your individual consent. We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information and require them to handle personal information in accordance with this Policy and any other relevant confidentiality and security measures. 5.2 transfer We will not transfer your personal information to any company, organization or individual except in the following cases: (1) Obtain your express consent or authorization in advance; (2) In case of merger, division, dissolution or bankruptcy, if personal information needs to be transferred, we will inform you of the name or contact information of the new company, organization or individual holding your personal information, and require the new company, organization or individual holding your personal information to continue to be bound by this Policy. 5.3 Public disclosure We will only publicly disclose your personal information under the following circumstances. We will inform you of the purpose of this public disclosure, the type of information disclosed and the sensitive personal information that may be involved, and we will comply with the requirements of relevant laws and regulations for disclosure: (1) after obtaining your express and separate consent; (2) In accordance with the provisions of laws and regulations, or in accordance with the mandatory requirements of competent government departments. 5.4 Under the following circumstances, we do not need to obtain your prior authorization to share, transfer or publicly disclose your personal information: (1) necessary for the conclusion and performance of the contract to which you are a party; (2) necessary for the performance of statutory duties or obligations; (3) necessary for responding to public health emergencies or for protecting the life, health and property safety of natural persons under emergency circumstances; (4) conduct news reporting and supervision by public opinion for the public interest, and process personal information within a reasonable scope; (5) In accordance with the provisions of the reasonable scope of processing of your own or other legally disclosed personal information; (6) Other circumstances provided for by laws and administrative regulations. In addition, in accordance with laws and regulations and national standards, sharing and transferring anonymized personal information and ensuring that the data receiver cannot recover and re-identify the subject of personal information does not belong to the external sharing, transfer or public disclosure of personal information.

6. Storage of information

We will legally continue to keep your personal information collected during the provision of products or services. We will arrange the storage period appropriately according to the types of personal information. When your personal information exceeds the storage period, we will delete your personal information or anonymize your personal information unless otherwise stipulated by laws and administrative regulations regarding the retention period of specific information.

7. Your personal information protection

To ensure the security of your personal information, we strive to take a variety of reasonable physical, electronic and management security measures to protect your information and protect your information from unauthorized access, public disclosure, use, tampering, damage or loss. We also take strict management of employees who may have access to your information, including but not limited to taking different authority control according to different positions, signing confidentiality agreements with them, monitoring their operations and other measures. In spite of the aforementioned security measures and compliance with the standards required by relevant laws and regulations, please understand that due to technical limitations and possible malicious means, the security of your personal information may be threatened and may be lost, stolen, tampered with or used by unauthorized third parties. In case of adverse personal information security events, we will promptly inform you and take necessary measures according to the requirements of laws and administrative regulations. If you find that your personal information is leaked, please contact us immediately through the contact information of this policy, so that we can take necessary measures.

8. About Cookies

When you visit the Neusoft Medical Platform website, we may store certain information on your computer in the form of "Cookie", which is a small text file placed on your computer by the web server. "Cookie" cannot be used to run programs. The purpose of using Cookies is to provide you with a convenient time saving feature, but it does not mean that we automatically gain access to any personal information about you. You can choose to accept or reject the "Cookie".

9. You can exercise the right

9.1 To the extent prescribed by applicable law, you have the right to exercise the following rights with respect to your personal information: (1) Access to and copy your personal information; (2) Restrict or refuse us to process your personal information; (3) Change the scope of your authorized consent to processing your personal information at any time, or withdraw your authorized consent (your decision to withdraw your consent or authorization will not affect the previous personal information processing based on your authorization); (4) If you find that your personal information processed by us is inaccurate or incomplete, request to correct or supplement your personal information; (5) Request to delete your personal information under the following circumstances (If we decide to respond to your deletion request, we will delete or anonymize your personal information as required by applicable laws and regulations. If the storage period prescribed by laws and administrative regulations has not expired, or it is technically difficult to delete your personal information, we will stop processing it except for storage and taking necessary security protection measures); ①The purpose of personal information processing has been realized, cannot be realized, or the information is no longer necessary to realize the purpose of processing; ②You no longer use our services; ③We stop providing services, or the retention period of personal information expires; ④You withdraw your consent to the processing of your personal information; ⑤We collect and use your personal information without your consent; ⑥We process your personal information in violation of laws, administrative regulations or our agreement with you; ⑦Other circumstances prescribed by laws and administrative regulations. (6) Request us to explain your personal information processing rules. 9.2 You can contact us through the contact information of this policy and make your request. 9.3 Under the following circumstances, according to the requirements of laws and regulations, we will not be able to respond to your request: (1) Those related to the performance of our obligations under laws and regulations; (2) Those directly related to national security and national defense security; (3) those directly related to public security, public health or major public interests; (4) those related to criminal investigation, prosecution, trial and enforcement of judgments; (5) There is sufficient evidence that you have subjective malice or abuse of rights; (6) To protect your or other personal life, property and other major legal rights and interests, but it is difficult to get the consent of the person; (7) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations; (8) involving trade secrets; (9) Other circumstances prescribed by laws and regulations.

10. Protection of minors

10.1 We will not intentionally collect the personal information of minors. If you provide the personal information of minors, please obtain the consent of their guardians before doing so. The definition of "minors" shall be determined in accordance with the applicable laws of this Policy. 10.2 We attach great importance to the protection of minors' personal information. In cases where information about minors is collected with the consent of parents or other guardians, we will only process information about minors where it is permitted by law, the express consent of parents or other guardians or is necessary for the protection of minors.

11. Amendments to this Policy

Neusoft Medical has the right to modify and interpret this Policy. We will update this Policy at any time and publish it. The updated content will take effect from the date of publication. Please visit us regularly for timely understanding.

12. Application of law

This Policy is governed by the laws of the People's Republic of China. Any dispute arising therefrom shall be settled by both parties through negotiation. If no agreement can be reached through negotiation, you agree that the people's court in the place where our legal address is located shall make a ruling.

13. Complaint organization

If you are not satisfied with the manner or content of our privacy policy that meets your concerns and expectations, you may complain to the statutory Authority.

14. Contact Information

We have set up [Personal Information Protection Person]. If you have any questions, suggestions or comments regarding this policy or matters related to your personal information, please contact us in the following ways. Contact Email Address:nms-lad@neusoftmedical.com Contact address: No.177-1, Chuangxin Road, Hunnan District, Shenyang, China Effective Date: March 2023.
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