Shanghai Smartee Denti-Technology Co.,Ltd. and Smartee's affiliates (hereinafter referred to as ''Smartee'') manufacture orthodontic devices and provide related services. Smartee collaborates with medical institutions and doctors to design and distribute custom orthodontic products for patients with the European Economic Area(EEA), the UK, or Switzerland.
This privacy statement (hereinafter referred to as ''Statement'') outlines how Smartee's processes of your personal data in connection with your use of Smartee's products and services. The purpose of Statement is to explain how Smartee collects, uses, and processes your personal information, enabling you to understand the rationale behind this processing and the choices you have regarding your data. Smartee processes your personal data in accordance with the relevant EU and UK privacy and data protection laws, including but not limited to the General Data Protection Regulation (GDPR) as implemented in the UK.
1. Personal data collected
Personal data refers to any information that identifies you or can be used to identify you. The following categories of personal data may be collected when you use Smartee's products and services:
(a)Identification Data: Name, gender, identification number, profile picture;
(b)Contact Information: Mobile phone number, city, landline telephone number, email address, and contact address;
(c)Financial Data: Bank account number, tax identification number;
(d)Professional Data: License for Physician to Practice, Physician's Qualifications, educational certificates, other relevant certifications, and the name, address, phone number, email, and bank account of the clinic or hospital where you practice;
(e)Physician Assistants' Data: Only the name and mobile number of physician assistants are processed.
2. Purposes for processing personal data
Smartee will process your personal data as the data controller for the following purposes:
(a)Due Diligence: Conducting and regularly updating anti-corruption due diligence to maintain the highest standards of quality.
(b)Dispute Resolution: Handling disputes and/or litigation involving you, where applicable.
(c)Compliance: Complying with legal or regulatory obligations requiring the disclosure of information.
(d)Legal Obligations: Processing your personal data to fulfill legal obligations, such as processing invoices for administrative and tax purposes.
(e)Contract Management: Managing the contractual relationship between you and Smartee, including payment, accounting, and compliance with legal submissions to public authorities.
(f)Professional Communication: Contacting you regarding collaboration opportunities and product-related matters in your field of expertise.
(g)Expertise Evaluation: Assessing your expertise based on public sources (e.g., publications, conferences) and your previous collaborations with Smartee.
(h)Fraud Prevention: Adding your personal data to a restricted persons list if Smartee reasonably believes you have violated legal or contractual obligations related to fraud, anti-bribery, or anti-corruption. This list is used for internal Smartee Group purposes and shared with third-party suppliers and collaborators as necessary.
Smartee will process your personal data in accordance with the purposes mentioned in section (5). And in line with Smartee's legitimate interests, such as protecting its business from litigation, fraud, and corruption risks. Smartee will ensure that your privacy and fundamental rights are respected. You have the right to object to the processing of your personal data under certain conditions, as outlined in (3), (5) of section 2 and section 6 of Statement.
3. Disclosing your personal data
Your personal data may be disclosed to the following parties for the purposes listed above:
(a)Smartee and Smartee's affiliates: Within the Smartee Group of companies.
(b)Third-party Service Providers: Such as IT providers, financial services providers, governmental authorities, or other third parties for legal compliance or the protection of Smartee's and others' rights, property, and safety.
(c)Auditors and Consultants: To verify compliance with in-house and external requirements.
(d)Successors: of Smartee: In the event of a business transfer, your data may be shared with third parties acquiring Smartee's assets or business.
4. Transfer of your personal data outside the EU/UK
To fulfill the purposes outlined in Section 2, Smartee may transfer and disclose your personal data to recipients in China, including Smartee's affiliates and cloud hosting providers. Such transfer will comply with EU and UK data protection regulations. As China has not been recognized by the European Commission or UK Parliament as providing an adequate level of data protection, Smartee will implement appropriate safeguards, such as standard contractual clauses, to ensure that your data is transferred securely and in compliance with applicable laws.
5. Data security and retention
Smartee is committed to safeguarding your personal data. Appropriate technical, organizational, and physical measures will be employed to protect your data against accidental or unlawful destruction, loss, falsification, unauthorized disclosure, or access.
Smartee will retain your personal data only for as long as necessary to fulfill the purposes outlined in Statement. However, Smartee may retain your data for longer periods where required by law or regulatory obligations, or for the establishment, exercise, or defense of legal claims.
6. Your data protection rights
You have several rights regarding the personal data Smartee processes about you, including:
(a)The right to request access to and obtain a copy of your personal data.
(b)The right to request the deletion of your personal data, subject to Smartee's legal obligations to retain certain data.
(c)The right to request the deletion of your personal data, subject to Smartee's legal obligations to retain certain data.
(d)In certain circumstances, you may request the restriction of the processing of your personal data.
(e)The right to receive your personal data in a structured, commonly used, and machine-readable format and to request the transfer of this data to a third party, where technically feasible.
(f)The right to object to the processing of your data under certain circumstances.
If you wish to exercise any of these rights or have any queries, please contact Smartee using the information provided in Section 7.
7. Contact information
If you have any queries or concerns about how Smartee process your personal data, please contact us at [ info@smartee.cn].
8. Updates to Statement
Smartee's Statement may be updated periodically. Any significant updates will be communicated with you as necessary.
