Dear User,
We are convinced the importance of personal information and are committed to safeguarding its security. This privacy policy (hereinafter referred to as ''The Policy'') outlines the scope of application, the methods by which we collect, use, share, store, protect, and manage your personal information, as well as how we handle the global transfer and processing of this information.
The Policy applies to the customized orthodontic appliances and other related products and services provided by [Shanghai Smartee Denti-Technology Co.,Ltd. and Smartee's affiliates] (hereinafter referred to as ''we'', ''Smartee'' or ''the Platform'').
For clarity, the processing of personal information we undertake for specific purposes when providing certain products or services will be governed either by The Policy or other legal documents specific to those products or services. Please review the texts applicable to those specific circumstances when using our products or services.
We will strictly adhere the principles of legality, fairness, and necessity, and comply with relevant laws, regulations, and standards. We will clearly inform you of the rules, purposes, methods, and scope of our collection and use of your personal information and will seek your consent when required. Therefore, before accessing or using the products and/or services provided by the Smartee website, please carefully read and fully understand the contents of each Clause in The Policy, especially those emphasized in bold. By clicking the ''Confirm'' or checking ''Agree'', you acknowledge that you have fully understood and accepted The Policy. Should you have any queries, comments, or proposals regarding any part of the clauses, please feel free to contact us through the details provided at the end of The Policy. We are willing to assist you.
Part 1: Definitions
1. Personal Information: Information, whether recorded electronically or by other means, that is related to an identified or identifiable natural persons. This dose not include anonymized information.
2. Affiliated Enterprises: Refers to Smartee. and any entities directly or indirectly controlled by its parent enterprise, Zhejiang Smartee Denti-Technology Co., Ltd., including but not limited to Sichuan Zhengmei Smartee Denti-Technology Co., Ltd. and Sichuan Yaqi Medical Technology Co., Ltd. These affiliated enterprises are independent legal entities.
Part 2: Privacy Policy
The Policy is organized into the following sections to help you understand the key aspects:
1. How we collect and use your personal information
2. How we use Cookies
3. How we share and publicly disclose your personal information
4. How we store and keep your personal information secure
5. How to manage your personal information
6. Protection of children's personal information
7. How your personal information is transferred globally
8. Modifications and updates to the policy
9. How to contact us
10. Supplementary clauses
1. How we collect and use your personal information
(a)Methods of Information Collection
I Information You Provide Actively
When you register an account on the Smartee Orthodontic Case Management System (including but not limited to the ERP system) as a doctor or when creating an institutional management account, you will need to provide personal information, including but not limited to: your name, gender, profile picture, phone number, WeChat ID, email, License for Doctors to Practice and other relevant qualification certificates. You may also need to provide your clinic or hospital's name, address, phone number, email, and bank account information. This information is used to create your personal account so that you can log in and use our services.
Obtaining Products and/or Services
To obtain products and/or services, you will provide us with personal information of you patients, which way include but not limited to: patient name, gender, date of birth, photos, and case information(such as diagnosis, treatment plans, photos of the patient's teeth, and images, including X-rays and STL data).
Payment and Financial Order Management
For payment processing, financial order management, and internal auditing purposes, we will collect your clinic's or hospital's payment information, including the payee's name, bank account details, and other relevant information.
Product Packaging and Delivery
We will collect and use contact information (such as names, delivery addresses, and phone numbers) of doctors, nurses, or procurement personnel, as well as the names and medical histories of relevant patients, to manage product packaging and delivery logistics.
II Information We Automatically Collect
When you visit the platform, our servers automatically log certain information, including your IP address, browser type, operating system version, access time, visited pages, device identifiers, etc. This information is used to analyze user behavior, optimize platform performance, ensure the security of our service, and compile relevant statistical data.
(b) Purposes of Using Personal Information
I Providing and Improving Services
We use your registration information and personal data to verify your identity, manage your account, provide personalized services and recommendations, and facilitate communication.
We also analyze your usage behavior and preferences to optimize the platform's functions, interface design, and overall user experience. This ensures that our services meet your needs and are continuously improved.
II Processing Transactions
If you make a purchase, payment, or engage in other transaction activities on the Platform, we will use the transaction information you provide (such as order details, payment method, and delivery address) to process your requests, complete payment settlements, and manage product deliveries.
III Customer Service and Support
We utilize your personal information to respond to inquiries, complaints, and proposals, providing you with customer service and technical support to resolve any issues you may encounter while using the Platform.
IV Security and Compliance
We detect and prevent fraudulent activities, security flaws, and other potential risks to ensure the safety of the platform and users. Additionally, we may use your personal information for compliance operations, such as identity verification, record keeping, and reporting, as required by laws and regulations.
V Marketing and Promotion
With your consent, we may use your personal information to send you marketing material related to the Platform's products, services, promotional activities, and offers. You may choose to unsubscribe from these information at any time.
2. How we use Cookies
We may use Cookies and other similar technologies to collect and store your browsing preferences, login status, and other information. A Cookie is a small text file sent to your device and stored in your browser when you visit the platform. You can manage the use of Cookies through your browser settings, but please note that disabling Cookies may affect certain features and your experience on the platform.
When you visit the Smartee website, we may assign one or more Cookies to your device. By accessing the Smartee website, you agree to our placing Cookies on your device.
The purposes for which the Smartee website uses Cookies include, but not limited to:
(a)Detecting the multimedia capabilities of your web browser.
(b)Tracking promotional advertisements shown to you.
(c)Storing current login and purchase information in a secure section of the website.
(d)Providing a unique identifier for your device so we can generate statistics based on website usage.
Most browsers automatically accept Cookies, and you can refuse Cookies by adjusting your browser settings. For more information about Cookies and how to modify your browser settings, refer to the ''Help'' section of your browser. If you decline cookies from the Smartee website, certain features or functionalities may be limited or unavailable.
The Smartee website may allow third parties to place Cookies to your device. When you visit the website, third parties such as analytic enterprises and business partners may use Cookies and similar technologies to collect non-personal information about your online activities. This information may be used to measure website usage and personalize advertising content. We do not have access to, or control over, the cookies or features used by these third parties, and The Policy does not cover how third parties use Cookies or their information protection practices.
Do Not Track
Many web browsers offer a ''Do Not Track'' feature that sends a request to websites to disable tracking. Currently, there are no established standard for websites to respond to such requests. However, if your browser's ''Do Not Track'' feature is enabled, all our websites will respect your choice.
3. How we share and publicly disclose your personal information
(a)Circumstances for sharing personal information
I Sharing with Affiliated Enterprises
To provide more comprehensive services and enhance the user experience, we may share your personal information with our affiliated enterprises. Affiliated enterprises are entities that have a direct or indirect controlling relationship with us, or are under common control or significant influence. We will ensure that these affiliated enterprises comply with the clauses of The Policy, maintain the confidentiality and security of your personal information, and use it solely for legitimate purposes related to the Platform.
II Sharing with Third-Party Service Providers
We collaborate with third-party service providers to enable certain functionalities and services of the Platform, such as payment processing, logistics, data analysis, and advertising. In these cases, we may share your relevant personal information with these service providers, but only to the extent necessary to fulfill the services they provide. We will enter into agreements with third-party service providers, requiring them to comply with relevant laws, regulations, and confidentiality obligations to ensure the proper protection of your personal information.
III Sharing When Legally Required or Authorized
In accordance with applicable laws and regulations, or upon request from judicial or governmental authorities, we may be required to disclose your personal information to relevant entities. For example, in situations involving litigation, investigations, or law enforcement action, we will provide the necessary information as required by law.
With your explicit consent, we may also share your personal information with other third parties. You have the right to rescind your consent at any time; however, please note that rescinding your authorization may affect our ability to provide certain services to you.
(b) Circumstances for publicly disclosing personal information
I Public Disclosure with Your Consent
If you explicitly consent to our public disclosure of certain personal information, we will disclose it in accordance with your authorization. For example, when participating in specific activities on the Platform, you may choose to publicly share some of your personal information or content.
II Public Disclosure Based on Legal Requirements
In certain exceptional cases, we may be required to publicly disclose your personal information in accordance with legal or regulatory requirements. For instance, to protect public interests, maintain social order, or prevent fraud, we may publicly disclose relevant personal information as required by laws. In such instances, we will implement appropriate measures to keep your personal information secure and ensure that the disclosure complies with legal and procedural requirements.
4. How we store and keep your personal information secure
(a) Information Storage
I Storage Location
We will store your personal information on servers located in designated locations. These servers are protected by strict physical and network security measures to ensure the integrity and security of your personal information.
II Storage life
The retention period for your personal information is determined by legal requirements and actual business needs. In general, we will retain your personal information for the duration of your use of the Platform, and for a certain period following the deactivation of your account, to comply with relevant laws and regulations, resolve potential disputes, or provide follow-up services. After the storage period, we will delete or anonymize your personal information.
(b) Information Protection
I Technical Measures
We employ a range of advanced technical measures to keep your personal information secure, including but not limited to data encryption, access controls, firewalls, and intrusion detection systems. We also regularly conduct security assessments and address any identified vulnerability to ensure the security and stability of our systems.
II Personnel Management
We implement strict background checks and security training for all employees who may have access to your personal information. These employees are required to comply with confidentiality agreements and relevant laws and regulations to ensure the secure handling of your personal information. In addition, we have established strict in-house management systems and operational procedures to manage, record, and monitor access, use, and modification of personal information.
III Emergency Response
We have developed a comprehensive emergency response plan to address potential personal information security incidents. In the event of a security incident, we will promptly activate the emergency plan and take appropriate measures to address to mitigate the situation. This includes notifying the relevant authorities and affected users, and implementing steps to minimize any damage or impact.
5. How to manage your personal information
(a) Accessing and Correcting Personal Information
I Access
You have the right to access your personal information on the Platform at any time. You can log into your account to view and manage your personal information on the profile page.
II Correction
If you find that your personal information is incorrect or incomplete, you can correct or updata it on the profile page. If you are unable to make the correction yourself, you may contact our customer service personnel, and we will assist you in making the correction.
(b) Deleting Personal Information
I Conditions for Deletion
You have the right to request the deletion of your personal information. We will delete your personal information within a reasonable time under the following circumstances:
i.You no longer use our services or deactivate your account;
ii.The purposes for which we collected and used your personal information have been fulfill or are no longer necessary;
iii.When you rescind your consent for us to process your personal information (please note that processing conducted based on your prior consent remains lawful);
iv.When we unlawfully process your personal information.
II Circumstances where deletion is not possible
In certain situations, we may not be able to delete your personal information immediately, such as when:
i.We are required retain relevant information to comply with legal regulations or judicial requirements;
ii.We need to retain relevant information to ensure the normal operation and security of the platform;
iii.We need to retain relevant information to resolve any disputes with you.
In these cases, we will take appropriate measures to isolate and keep your personal information secure, ensuring it is used only for lawful purposes, and we will delete it as soon as possible within the schedule allowed by laws and regulations.
(c) Restricting the Processing of Personal Information
I You have the right to request us to restrict the processing of your personal information under the following circumstances:
i.You question the accuracy of your personal information, you can request us to suspend processing while we verify and correct it;
ii.When we unlawfully process of your personal information, but you do not consent us to deletion, and instead, request that we restrict its processing;
iii.We no longer need your personal information for service provision, but you request its retention for potential future litigation.
II Measures we will take
Upon receiving your request to restrict processing, we will mark the relevant personal information and only process it with your consent or as permitted by applicable laws and regulations. During the restriction period, we will not further process your personal information further unless you provide additional consent, or it is necessary for legitimate purposes.
(d) Data migration
I If you wish to migrate your personal information from the Platform to another platform or service provider, you can request data portability. We will provide your personal information in a structured, commonly used, and machine-readable format to you or a designated third party, to the extent that it is technically feasible.
II Please note that data migration may be subject to certain restrictions, such as:
i.Legal limitations: Certain laws and regulations may restricti on the cross-border transfer of personal information or its transfer to specific third parties. We will comply with these legal requirements during data migration process.
ii.Technical feasibility: While we will make every effort to ensure a smooth transfer, compatibility issues between different platforms and systems may pose technical challenges. In such cases, we will communicate with you to find an nappropriate solution.
(e) Objecting to the Processing of Personal Information
I In certain situations, you have the right to object to our processing of your personal information, particularly when we process it based on legitimate interests or public interests, and you believe that such processing significantly impacts your personal rights. You can submit your objection in the following ways:
i.Contact our customer service and specify the reasons for your objection and the processing activities involved;
ii.When receiving marketing information or notifications based on your personal information, follow the prompts in the message to unsubscribe or object.
II We will respect your objection and cease processing the relevant personal information upon receiving your request, unless we have compelling legitimate grounds to continue processing or if it is necessary to protection your or others' vital interests, or to comply with legal procedures. In such cases, we will explain the reasons for continuing the processing.
(f) Rescinding Consent
I If you have previously consented to our processing of your personal information, you may rescind that your consent at any time. You can do so in the following ways:
i.Access the privacy settings in your account and rescind consent for specific processing activities;
ii.Contact our customer service to inform us of the scope of the consent you wish to rescind.
After rescinding consent, we will no longer process your personal information based on that consent. However, please note that rescinding consent does not affect the legality of the processing activities conducted prior to rescindment. Additionally, some services may rely on the processing of your personal information. Rescinding consent may result in limitations on your ability to use certain features or service. We will clearly inform you of any such implications when you rescind your consent.
6. Protection of Children's Personal Information
I We place great importance on protecting children's personal information. The Platform is primarily intended for adults. If we discover that we have unintentionally collected personal information from children without appropriate authorization, we will promptly delete the information and ensure it is not used for any other purposes.
II If you are the guardian of a child and have concerns regarding our collection, use, or storage of your child's personal information, please contact us immediately. We will work with you to find a solution in accordance with relevant laws and regulations to ensure your child's personal information is properly protected.
7. How your personal information is transferred globally
I As our business operates globally, your personal information may be transferred between countries or regions. We will ensure compliance with applicable laws, regulations, and relevant standards during the cross-border transfer of personal information, and we will implement appropriate security measures to protect your data.
II Before transferring your personal information to another countries or regions, we will assess the level of personal information protection provided in the recipient's countries or regions. We will ensure that the recipient has sufficient measures in place to protect your personal information securely. This may include establishing data transfer agreements or adopting standard contractual clauses to ensure that your personal information is protected at a standard equivalent to domestic protection during cross-border transfers.
III If you have any queries or concerns about the global transfer of your personal information, please feel free to contact us. We will provide detailed information about the transfer process and the measures in place to protect your personal information.
8. Modifications and updates to the policy
I We may modify or update the policy periodically due to changes in laws and regulations, business development, or other reasonable grounds. We will publish the revised policy on the Platform and notify you in advance through appropriate means, such as announcements on the Platform homepage or notifications sent to your registered email address.
II Please review the policy regularly to stay informed about our latest measures regarding personal information protection. If you continue to using the Platform's service after the revised policy take effect, it will be deemed that you accept the changes. If you do not agree to the revised policy, you may choose to stop using our services and delete your personal information as outlined in the policy.
9. How to contact us
I If you have any queries, comments, proposals, or complaints regarding the policy or our processing of your personal information, you can contact us through the following means:
Email: [info@smartee.cn ]
II We will respond to your inquiries or complaints within 15 days and aim to resolve the issues you raise as quickly as possible.
10. Supplementary clauses
I We reserve the exclusive right to interpret the Policy. If any clause in the policy is found to be invalid or unenforceable, this shall not affect the validity or enforceability of the remaining clauses.
II The Policy constitutes the entire agreement between you and us regarding the processing of personal information. Unless otherwise specified in the policy, matters not covered here will be governed by relevant laws and regulations and our other clauses.
