Introduction
Shanghai Henlius Biotech, Inc., its affiliates and subsidiaries (collectively, "we") attach great importance to the protection of your privacy and personal information and formulate this privacy policy (this "Policy") in order to comply with the requirements of Chinese laws, regulations and other laws on the protection of personal information. The Policy shall apply (1) when you browse and use the website and our other network resources (such as WeChat official accounts); (2) when you use our products or services; (3) when you have business cooperation or other interactions with us. The purpose of the Policy is to explain to you the method and purpose of our processing of your personal information, the type of personal information processed by us, the retention period, the channels for you to exercise your rights regarding personal information and the measures we have taken to protect personal information. We hope that you have read the Policy carefully and make sure that you have fully understood the content of the Policy.
In certain business scenarios, we may inform you how we handle your personal information in those certain scenarios by entering into an agreement with you or in a separate privacy statement or personal information notification consent form. In case of any conflict or inconsistency between the relevant content and this Policy, the relevant agreement terms, privacy statement or personal information notification consent form shall prevail in principle.
For the purpose of the Policy, "personal information" refers to all kinds of information related to identified or identifiable natural persons that are electronically or otherwise recorded, excluding information that has been anonymized.
We collect, use and protect the personal information that you provide to us in strict compliance with the laws and regulations of the PRC governing the protection of the personal information security.
The links to third party websites contained on the website are provided solely for your convenience. We have no control over the collection or use of your personal information by such websites. The Policy shall not apply to such websites. Therefore, we suggest that you carefully read the privacy policies of third parties before visiting or using their websites.
If you have any questions, comments or suggestions regarding this Policy, or any questions or concerns about what we do with your personal information, please contact us via the contact information indicated at the bottom of this Policy.
This Policy will help you to understand:
I. How do we collect your personal information?
II. How do we use your personal information?
III. How do we entrust, share, transfer and publicly disclose your personal information?
IV. Use of cookies
V. How do we provide your personal information across borders?
VI. How do we store your personal information?
VII. What security measures do we take to protect your personal information?
VIII. Your rights
IX. How do we process the personal information of minors?
X. Updates of this Policy
XI. How to contact us?
I. How do we collect your personal information?
In addition to our employees, we may process personal information of the following persons:
Based on who you are and the context in which you interact with us, we may collect personal information by the following means:
II. How do we use your personal information?
We may use your personal information for the following purposes:
III. How do we entrust, share, transfer and publicly disclose your personal information?
1. Entrust
We may entrust our business partners with the processing of your personal information for the purpose(s) described in this Policy. We enter into strict confidentiality agreements with those business partners to whom we entrust the processing of personal information requiring them to handle the personal information in accordance with our requirements, this Policy and any other relevant confidentiality and security measures.
2. Share and publicly disclose
For the purpose(s) described in this Policy, we will only share or disclose your personal information to third parties in the following circumstances:
3. Transfer
We will not transfer your personal information to any other company, entity or individual without your express consent. Further, in the event of a merger, acquisition or insolvency, we will require the new processor of your personal information to continue to be bound by this Policy or we will require the new processor to obtain your consent again.
IV. Use of cookies
During the time that you are on the website, we will place an electronic label (more precisely, "cookies") on your hard drive which enables the server to recognize your computer and track information. The cookies will not recover your personal information and you may remain anonymous to us. Information collected from the cookies is used only for internal use and to improve the website's content and the browser. If you do not wish to accept them, you may set your browser to reject cookies.
V. How do we provide your personal information across borders?
In principle, personal information that we collect and generate in the course of our operations within the territory of the PRC will be stored within the PRC. As we conduct our business and provide products and services through our resources and servers located throughout the world, under certain circumstances your personal information may be transferred overseas. As required by the PRC laws and regulations regarding the protection of personal information, we will obtain your separate consent before providing your personal information across any border. We will use lawful cross-border transfer mechanisms to transfer your personal information oversea and will take necessary actions to ensure that the oversea recipient provides the same protection to your personal information as adequate is provided within the PRC.
You may obtain more information about cross-border transfers of personal information and oversea recipients through the contact methods referred to in this Policy.
VI. How do we store your personal information?
We will retain your personal information for the minimum period necessary. If the above period has expired, we will promptly delete your personal information or anonymize your personal information. Our criteria for determining the period for which personal information shall be retained include:
VII. What security measures do we take to protect your personal information?
In accordance with the requirements of relevant national standards, we take industry-standard security and precautionary measures to protect the personal information you provide from unauthorized access, public disclosure, use, modification, destruction or loss of data. However, you shall also have the responsibility to make sure that the computer and other equipment you use has sufficient security and safeguards to prevent disclosure of your personal information.
VIII. Your rights
In accordance with the requirements of the personal information protection laws and regulations of the PRC, we guarantee that you exercise the following rights in respect of your personal information:
If you wish to exercise your rights with respect to personal information, you may contact us through the contact information listed in this Policy and we will respond to any request subject to the requirements of relevant laws and regulations. When you exercise the above rights, we may verify your identity to safeguard the security of your personal information.
Shanghai Henlius Biotech, Inc., its affiliates and subsidiaries (collectively, "we") attach great importance to the protection of your privacy and personal information and formulate this privacy policy (this "Policy") in order to comply with the requirements of Chinese laws, regulations and other laws on the protection of personal information. The Policy shall apply (1) when you browse and use the website and our other network resources (such as WeChat official accounts); (2) when you use our products or services; (3) when you have business cooperation or other interactions with us. The purpose of the Policy is to explain to you the method and purpose of our processing of your personal information, the type of personal information processed by us, the retention period, the channels for you to exercise your rights regarding personal information and the measures we have taken to protect personal information. We hope that you have read the Policy carefully and make sure that you have fully understood the content of the Policy.
In certain business scenarios, we may inform you how we handle your personal information in those certain scenarios by entering into an agreement with you or in a separate privacy statement or personal information notification consent form. In case of any conflict or inconsistency between the relevant content and this Policy, the relevant agreement terms, privacy statement or personal information notification consent form shall prevail in principle.
For the purpose of the Policy, "personal information" refers to all kinds of information related to identified or identifiable natural persons that are electronically or otherwise recorded, excluding information that has been anonymized.
We collect, use and protect the personal information that you provide to us in strict compliance with the laws and regulations of the PRC governing the protection of the personal information security.
The links to third party websites contained on the website are provided solely for your convenience. We have no control over the collection or use of your personal information by such websites. The Policy shall not apply to such websites. Therefore, we suggest that you carefully read the privacy policies of third parties before visiting or using their websites.
If you have any questions, comments or suggestions regarding this Policy, or any questions or concerns about what we do with your personal information, please contact us via the contact information indicated at the bottom of this Policy.
This Policy will help you to understand:
I. How do we collect your personal information?
II. How do we use your personal information?
III. How do we entrust, share, transfer and publicly disclose your personal information?
IV. Use of cookies
V. How do we provide your personal information across borders?
VI. How do we store your personal information?
VII. What security measures do we take to protect your personal information?
VIII. Your rights
IX. How do we process the personal information of minors?
X. Updates of this Policy
XI. How to contact us?
I. How do we collect your personal information?
In addition to our employees, we may process personal information of the following persons:
- Visitors and users of our website;
- Healthcare Professionals;
- Investigators of clinical trial institutions and personnel of contract research organizations in clinical trials;
- Subjects of clinical trials and their relatives;
- Consumers/patients and their relatives using our products or services;
- Staff of business partners (including vendors, distributors, partners, etc.); and
- Our applicants.
Based on who you are and the context in which you interact with us, we may collect personal information by the following means:
- Your personal information provided to us voluntarily by you
- The personal information collected by us independently through such channels as our website
- Personal information we collect from vendors or business partners
- Personal information we collect from publicly available sources
II. How do we use your personal information?
We may use your personal information for the following purposes:
- Operating and managing website and other internet resources, providing consulting and information services;
- Researching, developing, providing and continuously improving our products and services;
- Conducting and managing daily business;
- Academic interaction with healthcare professionals;
- Recruiting and human resource management;
- Internal compliance management and audit; and
- To fulfill the requirements of relevant laws and regulations, for example, monitoring and reporting adverse events for purposes of performing drug quality management responsibilities, providing medical information and dealing with product complaints, etc..
III. How do we entrust, share, transfer and publicly disclose your personal information?
1. Entrust
We may entrust our business partners with the processing of your personal information for the purpose(s) described in this Policy. We enter into strict confidentiality agreements with those business partners to whom we entrust the processing of personal information requiring them to handle the personal information in accordance with our requirements, this Policy and any other relevant confidentiality and security measures.
2. Share and publicly disclose
For the purpose(s) described in this Policy, we will only share or disclose your personal information to third parties in the following circumstances:
- Sharing or disclosing your personal information with external parties after obtaining your express consent;
- Sharing your personal information among affiliates and subsidiaries;
- Sharing your personal information with vendors or business partners (such as conference service providers, travel service providers, data service providers, banking or insurance institutions, other professional service organizations, etc.); and
- Disclosing your personal information to the extent that it is permitted or required by laws and regulations or for the purpose of assisting with investigations by judicial or law enforcement authorities.
3. Transfer
We will not transfer your personal information to any other company, entity or individual without your express consent. Further, in the event of a merger, acquisition or insolvency, we will require the new processor of your personal information to continue to be bound by this Policy or we will require the new processor to obtain your consent again.
IV. Use of cookies
During the time that you are on the website, we will place an electronic label (more precisely, "cookies") on your hard drive which enables the server to recognize your computer and track information. The cookies will not recover your personal information and you may remain anonymous to us. Information collected from the cookies is used only for internal use and to improve the website's content and the browser. If you do not wish to accept them, you may set your browser to reject cookies.
V. How do we provide your personal information across borders?
In principle, personal information that we collect and generate in the course of our operations within the territory of the PRC will be stored within the PRC. As we conduct our business and provide products and services through our resources and servers located throughout the world, under certain circumstances your personal information may be transferred overseas. As required by the PRC laws and regulations regarding the protection of personal information, we will obtain your separate consent before providing your personal information across any border. We will use lawful cross-border transfer mechanisms to transfer your personal information oversea and will take necessary actions to ensure that the oversea recipient provides the same protection to your personal information as adequate is provided within the PRC.
You may obtain more information about cross-border transfers of personal information and oversea recipients through the contact methods referred to in this Policy.
VI. How do we store your personal information?
We will retain your personal information for the minimum period necessary. If the above period has expired, we will promptly delete your personal information or anonymize your personal information. Our criteria for determining the period for which personal information shall be retained include:
- Applicable laws, regulations and other relevant provisions;
- The period of time needed for us to provide services, maintain business relations or interact with you; and
- The period of time needed for us to perform relevant agreements or fulfil the purposes described in this Policy.
VII. What security measures do we take to protect your personal information?
In accordance with the requirements of relevant national standards, we take industry-standard security and precautionary measures to protect the personal information you provide from unauthorized access, public disclosure, use, modification, destruction or loss of data. However, you shall also have the responsibility to make sure that the computer and other equipment you use has sufficient security and safeguards to prevent disclosure of your personal information.
VIII. Your rights
In accordance with the requirements of the personal information protection laws and regulations of the PRC, we guarantee that you exercise the following rights in respect of your personal information:
- Have the right to know and make decisions regarding the processing of your personal information;
- Access or copy your personal information;
- Correct or supplement your personal information;
- Delete your personal information;
- Request for explanation of rules regarding processing of personal information; and
- Change the scope of your consent or revoke your consent.
If you wish to exercise your rights with respect to personal information, you may contact us through the contact information listed in this Policy and we will respond to any request subject to the requirements of relevant laws and regulations. When you exercise the above rights, we may verify your identity to safeguard the security of your personal information.