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GemPharmatech Co,. Ltd is a biotechnology enterprise established in 2017. Our preclinical services and genetically engineered animal models represent our core competitive advantage. For more information and further cooperation, please refer to the relevant product and service details section on our website. To explain how GemPharmatech (or "we" for short) collects, uses and stores your personal information and the rights you enjoy, we elaborate on relevant matters through this policy.
This policy will help you understand the following:
1. How We Collect Your Personal Information
2. How We Use Cookie and Similar Technologies
3. How We Store and Protect Your Personal Information
4. How We Use Your Personal Information
5. How We Share, Transfer and Publicly Disclose Your Personal Information
6. Your Rights
7. Updates to This Policy
8. How to Contact Us
9. Jurisdiction-Specific Terms
【Special Notice】This policy is closely related to your use of our services. Please read and fully understand this policy carefully before using our products/services, and make choices you deem appropriate. Clauses in this policy that have a significant impact on your rights and interests as well as personal sensitive information will be marked in bold and underlined to remind you of your attention. To bring you a better product and service experience, we are continuously working to improve our technology, and as a result, we may launch new or optimized functions from time to time, which may require the collection and use of new personal information or change the purpose or method of use of personal information. In this regard, we will separately explain to you the purpose, scope and method of collection of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with a way to independently choose to consent, and we will collect and use the information after obtaining your explicit consent.
If you have any questions about this privacy policy or related matters, you can contact us at any time through our online customer service system, or by calling the customer service hotline (400-9660890) and other methods.
1. How We Collect Your Personal Information
Personal information refers to all kinds of information recorded by electronic or other means that is related to an identified or identifiable natural person. This privacy policy includes: personal information (including but not limited to name, residential address, mobile phone number, email address and other relevant additional information), IP address, log information, and information you retain at other natural persons, legal persons and other organizations that legally retain your information.
Information after anonymization processing and other information that cannot identify the identity of a specific natural person or reflect the activities of a specific natural person does not belong to personal information.
We will only collect and use your personal information for the following purposes:
1.1 Circumstances Where You Must Authorize Us to Collect and Use Your Personal Information
Our products and services include some basic business functions and extended business functions. The basic business functions include the functions necessary to help you obtain laboratory mouse models and related technical services, as well as the functions necessary to ensure the normal operation of services and transaction security. We may collect, store and use the following information related to you to realize the above functions. If you do not provide relevant information, you will not be able to enjoy the products and/or services we provide. The information that must be collected for these basic business functions includes:
1.2 Circumstances Where You May Choose Whether to Authorize Us to Collect and Use Your Personal Information
In addition to the above basic business functions for which we will collect and use your personal information, our products and services also include some extended business functions. We may collect and use your personal information when you use the extended business functions. If you do not provide such personal information, you can still use the functions of the logistics and transportation management system, but you may not be able to use these extended business functions:
2. How We Use Cookie and Similar Technologies
Cookie is a mechanism that supports the server side (or script) to store and retrieve information on the client side. When you use GemPharmatech's products or services, to provide you with a more relaxed and secure access experience, we may use Cookie or similar technologies to collect and store information, during which we may send one or more Cookies or anonymous identifiers to your device. This is done to collect your information to understand your preferences, conduct consultation or data analysis, improve product services and user experience, or detect and prevent security risks in a timely manner, so as to provide you with better services. We will not use Cookies for any purposes other than those stated in this policy. You can retain or delete Cookies according to your own preferences. You can clear all Cookies saved in the software, and your relevant information will be deleted after you manually clear them.
When you first visit our website, we present a cookie consent banner showing the categories of cookies we use and their purposes. You can click 'Manage Preferences' to view detailed descriptions of each category and choose whether to enable or disable non-essential cookies. We only set non-essential cookies after obtaining your explicit consent. Strictly necessary cookies do not require consent as they are essential for the website to function properly. All consent options are off by default (not pre-ticked). You must actively opt in to specific cookie categories.
3. How We Store and Protect Your Personal Information
3.1 Information Storage Period
3.1.1 We retain your information for as long as it is needed for us to provide the Website and services and operate our business, or it is necessary to fulfill the purposes for which such information was collected.
3.1.2 To cooperate with people's procuratorates, public security organs and state security organs in investigating criminal acts that occur during users' use of GemPharmatech's services, and to better protect the property safety of other users, when a user deletes personal information or cancels an account, GemPharmatech will store the user's personal information in encrypted and isolated archives within the limitation period for criminal prosecution prescribed by the Criminal Law.
3.1.3 If you seriously violate laws and regulations, platform agreements, platform policies or rules during your use of our website, your illegal and breach of contract records, as well as corresponding platform credit records and personal information, will be permanently saved.
3.2 Information Storage Region
3.2.1 Your personal information collected by GemPharmatech will be stored and used in mainland China.
3.2.2 At present, GemPharmatech has no scenario of providing personal information to overseas parties. If personal information is transmitted overseas in the future, GemPharmatech will clearly inform you of the purpose of outbound personal information, the recipient, security protection measures and other information, and obtain your separate consent.
3.3 Security Protection Measures
3.3.1 GemPharmatech only retains your personal information for the purposes stated in this policy.
3.3.2 GemPharmatech will adopt security protection measures that meet industry standards, protect your personal data by establishing security management specifications for the whole life cycle of data and corresponding technical control measures, and using corresponding security technologies and management procedures, and will do its best to prevent your personal information from being leaked, damaged, lost, improperly used, or accessed or disclosed without authorization at all times.
3.3.3 GemPharmatech takes the following security protection measures to protect your personal information:
(1) Establish a layered defense system for personal data security. Dual control measures of management and technology are adopted in all links of data creation, storage, use, transmission, archiving and destruction, to avoid the risk of centralized data operation.
(2) Users' personal sensitive information is encrypted and stored, and the risk of data re-identification is reduced through data isolation measures.
(3) Use encrypted transmission protocols to ensure data transmission security.
(4) Strictly control data access permissions, and establish a complete application and approval system for sensitive data access permissions.
(5) Establish data security monitoring and security auditing to conduct comprehensive data security control.
3.3.4 GemPharmatech also adopts other security measures to protect your personal information: (1) Establish a company network and information security work leading group to coordinate and manage data security work in a unified manner, and set up a data security team under it to promote various data security activities.
(2) Promulgate and implement data security management specifications within the company, and clarify the protection standards and requirements for user data (including user personal information).
(3) Conduct project risk assessment on data security (including user personal information data) before new projects and new systems are launched.
(4) Sign confidentiality agreements with all employees, and allocate data access permissions strictly in accordance with job responsibilities.
(5) Regularly carry out information security education and training for all employees.
3.3.5 GemPharmatech actively implements domestic and international best practices for security, timely resists and addresses information security threats, and protects the security of your personal data and privacy.
3.4 Security Incident Handling
3.4.1 In response to possible security risks such as personal information leakage, damage and loss, we have issued a number of systems within the company, which clarify the classification and grading standards for security accidents and security vulnerabilities, as well as the internal handling procedures and remedial measures for the above-mentioned security accidents and vulnerabilities.
3.4.2 In the event of a security incident, GemPharmatech will timely inform you of the basic situation and risks of the incident, the measures that GemPharmatech has taken or will take, and suggestions on how you can reduce risks on your own.
3.4.3 GemPharmatech will timely notify the affected users of the security incident by means of push notifications. When it is difficult to notify users one by one, GemPharmatech will issue warning information by releasing platform announcements. Meanwhile, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
4. How We Use Your Personal Information
4.1 Your personal information will be used in the usage scenarios explicitly listed in Article 1 "How We Collect Your Personal Information" of this Policy.
4.2 Your personal information may be used in the following scenarios that are directly or reasonably related to the purposes stated in the "How We Collect Your Personal Information" clause:
4.2.1 When GemPharmatech provides services, it is used for user services, security prevention, fraud monitoring, archiving and backup purposes, so as to improve the security of the services provided to you by GemPharmatech; it is used to prevent, detect and investigate fraud, as well as acts that endanger security, are illegal, or violate the platform agreements or rules signed with GemPharmatech, so as to protect the legitimate rights and interests of you, other GemPharmatech users, GemPharmatech and other bona fide third parties;
4.3 You are fully aware that GemPharmatech does not need to obtain your authorization and consent to collect, use and provide the following information to third parties:
4.3.1 Information related to GemPharmatech's performance of obligations stipulated by laws and regulations;
4.3.2 Information related to national security and national defense security;
4.3.3 Information related to public security, public health and major public interests;
4.3.4 Information related to criminal investigation, prosecution, trial and execution of judgments, etc.;
4.3.5 Information necessary for protecting the major legitimate rights and interests such as the lives and property of you or other users, but it is difficult to obtain your consent;
4.3.6 Your personal information that you voluntarily disclose to the public;
4.3.7 Your personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
4.3.8 Information necessary for signing and performing contracts in accordance with your requirements;
4.3.9 Information necessary for maintaining the safe and stable operation of the provided products and/or services, such as discovering and handling faults of products and/or services;
4.3.10 Information necessary for legitimate news reporting;
4.3.11 Information necessary for public interests or necessary for statistics or academic research conducted on the basis of public interests by state organs, public institutions, academic research institutions or subjects authorized by such units, and when the research or described results are provided to the public, the personal information contained in the results is de-identified;
4.3.12 Acts you commit in violation of legal provisions, the GemPharmatech User Service Agreement;
4.3.13 Complaints and report information made by other users against you;
4.3.14 Data analysis conducted by GemPharmatech based on the personal information of you and other users and the conclusions drawn therefrom;
4.3.15 Other information that does not belong to personal information according to law.
4.4 For the use of your personal information beyond the purposes stated in Article 1 "How We Collect Your Personal Information" of this Policy and the scope specified in this Article, GemPharmatech will inform you again and obtain your explicit consent.
5. How We Share, Transfer and Publicly Disclose Your Personal Information
5.1 Sharing
5.1.1 Except for the following circumstances and otherwise agreed in this Policy, without your consent, GemPharmatech will not share your personal information with any third party:
(1) To achieve the purposes specified in Article 1 of this Policy on the information that must be collected to realize the basic business functions of GemPharmatech, and only by sharing your personal information can the services you need be provided;
(2) To handle disputes or controversies between you and others (under statutory circumstances: in accordance with the provisions of laws and regulations, the needs of litigation dispute resolution, or the requirements legally put forward by competent administrative and judicial organs);
(3) To judge whether your account or transaction is secure;
(4) Reasonable purposes necessary for complying with applicable laws and regulations, safeguarding social public interests, or protecting the personal and property safety or other legitimate rights and interests of GemPharmatech, users of GemPharmatech and employees;
(5) If you violate relevant legal provisions, the GemPharmatech User Service Agreement or platform rules, it is necessary to disclose your personal information to a third party;
(6) Necessary personal information obtained according to legal procedures by administrative supervision organs and criminal investigation organs for investigating crimes, or necessary personal information obtained according to legal procedures by administrative organs and judicial organs;
(7) Performing GemPharmatech's obligations and exercising GemPharmatech's rights under the GemPharmatech User Service Agreement or this Policy, as well as other circumstances that GemPharmatech deems necessary to disclose in accordance with legal provisions, the GemPharmatech User Service Agreement.
5.1.2 Except for the circumstances specified in this Policy where GemPharmatech provides your personal information to a third party, if GemPharmatech needs to provide your personal information to a third party based on other circumstances, GemPharmatech will separately obtain your consent in the form of confirmation of the agreement, text confirmation action in specific scenarios, etc. in accordance with the requirements of laws and regulations.
5.1.3 Unless otherwise agreed in this Policy, without going through statutory procedures or obtaining your consent, GemPharmatech will not provide your personal information to any third-party institution or individual. For companies, organizations and individuals with whom GemPharmatech shares personal information, GemPharmatech will strive to sign confidentiality agreements with them, requiring them to comply with the agreements and take relevant security measures to protect your personal information.
5.2 Transfer
With the continuous development of GemPharmatech's business, we and our affiliated parties may carry out changes such as mergers, acquisitions, asset transfers or similar transactions. You agree to authorize GemPharmatech to transfer your personal information as part of such transactions. If the transfer of personal information is involved, we will require the company or organization that accepts the transfer of your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require the company or organization to seek your authorization and consent again.
5.3 Public Disclosure
We may publicly disclose your personal information only under the following circumstances and on the premise of adopting security protection measures that meet industry standards:
5.3.1 Disclose the personal information you specify in the disclosure method you explicitly agree to according to your needs;
5.3.2 Under the circumstance that we are required to provide your personal information in accordance with the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information according to the required type of personal information and disclosure method. On the premise of complying with laws and regulations, when we receive the above-mentioned request for information disclosure, we will require the corresponding legal documents, such as summons or investigation letters, to be presented.
5.4 Exceptions to Prior Authorization and Consent for Sharing, Transfer and Public Disclosure of Personal Information Under the following circumstances, sharing, transfer and public disclosure of your personal information do not require your prior authorization and consent:
5.4.1 Related to GemPharmatech's performance of obligations stipulated by laws and regulations;
5.4.2 Related to national security and national defense security;
5.4.3 Related to public security, public health and major public interests;
5.4.4 Related to criminal investigation, prosecution, trial and execution of judgments, etc.;
5.4.5 For the purpose of protecting the major legitimate rights and interests such as the lives and property of you or other individuals, but it is difficult to obtain the consent of the person concerned;
5.4.6 Other circumstances for safeguarding public interests, for example, your credit evaluation information needs to be publicly disclosed/shared;
5.4.7 Personal information that you voluntarily disclose to the public;
5.4.8 Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
5.4.9 According to legal provisions, if personal information that has been de-identified is shared, transferred and publicly disclosed, and it is ensured that the data recipient cannot restore and re-identify the personal information subject, our processing of such data does not require additional notification to you and your consent.
Please note: The information you voluntarily publish or even publicly share when using our services may involve personal information or even sensitive personal information of you or others, such as your transaction information, and various forms of information including text, pictures or videos containing personal information that you choose to upload when making evaluations. Please consider more carefully whether to publish or even publicly share relevant information when using our services.
6. Your Rights
We respect and attach great importance to your rights in connection with your personal information, including the following:
- Right of Access. You are entitled to request us to confirm whether we process your personal information and, request a copy of your personal information.
- Right to Rectification. If any of your personal information collected by us is incomplete or inaccurate, you can ask us to correct or update such information.
- Right to Erasure. In certain circumstances, you can request us to delete all or some of your personal information:
■Our processing of your personal information violates applicable laws and regulations;
■We collected or used your personal information without your consent;
■Our processing of your personal information violates our agreement with you;
■The purpose of processing your personal information has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose; or
■You have withdrawn your consent for us to process your personal information.
- Withdrawal of Consent. You also have the right to withdraw your consent at any time where our processing of your personal information is based on your consent. However, certain features of the Website and our services may not be available if your consent has been withdrawn.
7 Update of This Policy
We reserve the right to change this Privacy Policy from time to time at our sole discretion. Without your explicit consent, we will not diminish the rights you are entitled to according to this policy. We will notify you of any material changes through a notification on the Website, and such change will only apply to information collected after the revised Privacy Policy takes effect. Any changes to this Privacy Policy will become effective immediately after being posted. We encourage you to periodically review this Privacy Policy to stay informed of changes and on how we are protecting your personal information.
8 How to Contact Us
If you have any questions, comments or suggestions about this Privacy Policy, matters related to your personal information, or complaints and reports, please contact us through the following methods.
Personal Information Protection Officer Email: services@gempharmatech.com
Contact number: [400-9660890]
Address: No. 12 Xuefu Road, Jiangbei New Area, Nanjing, China
Generally, we will reply within 15 days. If you are not satisfied with our reply, especially if our personal information processing activities have damaged your legitimate rights and interests, you can also complain or report to the cyberspace administration, telecommunications, public security, industry and commerce and other regulatory departments. Attachment: Examples of Personal Information and Sensitive Personal Information (for illustrative purposes only)
Personal information refers to various types of information related to an identified or identifiable natural person that is recorded electronically or by other means, excluding information that has been anonymized. Sensitive personal information is personal information that, once leaked or illegally used, could easily result in infringement of a natural person's dignity or harm to their personal or property safety. It includes information such as biometric identification, religious beliefs, specific identities, medical health, financial accounts, and whereabouts and tracks, as well as personal information of minors under the age of 14. (This definition is derived from the Personal Information Protection Law of the People's Republic of China).
9. Jurisdiction-Specific Terms
If you are located in any of the following jurisdictions, the jurisdiction-specific terms will apply to the processing of your information, in addition to the terms set out in other sections of this Privacy Policy.
In the event of any conflict between the application jurisdiction-specific terms and the rest of this Privacy Policy, the relevant jurisdiction-specific terms will supersede and control.
EUROPEAN ECONOMIC AREA AND UK
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), these additional jurisdiction specific terms will apply to the processing of your personal information.
We, GemPharmatech Co,. Ltd with registered office at 12 Xuefu Road, Jiangbei New Area, Nanjing 210000, P.R. China is the controller of your personal information for the purposes of the Website and applicable data protection laws.
How We Use Your Information
The table below summarizes how we use your personal information, as well as the lawful basis applicable to our processing of such personal information under applicable data protection laws.
How we use your personal information | Our lawful basis |
To review your comments or questions, and provide you with appropriate services. | It is necessary for our legitimate interests to review and respond to you and provide you with an appropriate service. |
To enforce our terms and policies. | It is necessary for our legitimate interests to enforce our terms and policies to protect our Website and effectively manage and protect our business. |
To process and respond to your requests, queries, applications, complaints and feedback. | It is necessary for our legitimate interests to review and respond to your requests, queries, applications, complaints and feedback when you contact us. |
To provide support and respond to your requests, feedback and queries. | It is necessary for our legitimate interests to provide you with support and to respond to you when you contact us. |
To monitor, operate, maintain and manage the Website. | It is necessary for our legitimate interests to effectively operate our Website. |
To address and resolve technical issues and bugs. | It is necessary for our legitimate interests to effectively operate our Website and resolve any technical issues. |
To ensure the Website operates effectively and efficiently. | It is necessary for our legitimate interests to effectively and efficiently operate our Website. |
To detect, prevent or otherwise address security, fraud or technical issues. | It is necessary for our legitimate interests to protect the security of our Website and our business. |
To improve and enhance the features and performance of the Website and relevant services. | It is necessary for our legitimate interests to improve and develop the Website and relevant services. |
To properly manage and administer our relationship with you. | It is necessary for our legitimate interests to manage our relationship with you. |
To manage our business. | It is necessary for our legitimate interests to effectively manage our business. |
To protect, enforce or defend our rights and interests (including, in relation to a violation of our terms and conditions). | It is necessary for our legitimate interests to protect and defend our rights and interests. |
To meet our legal obligations and responsibilities. | It is necessary to comply with legal obligations that we are subject to. |
For other purposes as disclosed to you, where we have your consent to do so. | Consent. |
As required to do so by law. | It is necessary to comply with legal obligations that we are subject to. |
Your Rights. In addition to the rights set out in Section 7 (Your Rights ), you also have the following rights in connection with your personal information:
o Withdrawal of Consent. You also have the right to withdraw your consent at any time where our processing of your personal information is based on your consent. However, certain features of the Website and our services may not be available if your consent has been withdrawn.
o Right of Restriction. In certain circumstances, you may have the right to request that we restrict the processing of your personal information.
o Right of Portability. You may have the right to receive personal information about you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that personal information to another entity.
o Right of Objection. Where we process your personal information on the basis of our legitimate interests, you have the right to object to this. However, we may continue to process your personal information if you have objected where we have compelling legitimate grounds to continue such processing or for the establishment, exercise or defense of legal claims.
o Direct Marketing. You have the right to ask us to stop processing your personal information for direct marketing purposes.
o Automated Decision Making. In certain circumstances you have the right to request that you are not subject to automated processing of personal information, which produces a legal effect or similarly significantly affects you.
You also have the right to lodge a complaint with your local data protection/supervisory authority in your jurisdiction regarding the processing of your personal information.
You can contact us using the contact details in the Privacy Policy to exercise any of your rights.
International Transfer. The following section shall be added to the end of Section 5 in the main body of this Privacy Policy:
Transfers of personal information outside of the EEA/UK
If you are located in the EEA or the UK, your personal information may be transferred to us, stored at, processed in or otherwise accessed outside of the EEA or the UK, for example in China. We will ensure appropriate measures and safeguards are in place regarding the international transfer, storage and processing of your personal information. We will also obtain your separate consent for the international transfer of your personal information outside of the EEA or the UK to the extent required under applicable data protection laws.
UNITED STATES (CALIFORNIA)
If you are a California resident, these additional jurisdiction specific terms will apply to the processing of your personal information. The following terms used in this section and not otherwise defined have the meanings given to such terms under the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”).: “personal information,” and “sell / sale.”
California Privacy Rights. Under CCPA and CRPA, California residents have the right to request access or deletion of the personal information we have collected in the preceding twelve (12) months. You can also request the disclosure of the categories of personal information we collect, the purposes for which we collect, sell or disclose that information, and the categories of third parties with whom we share the information.
No Sale. You have a right to opt out of sale of your personal information. We do not sell, and in the preceding twelve (12) months did not sell, any personal information about you.
Right to Non-Discrimination for the Exercise of CCPA Rights. You may not be discriminated against because you properly exercise any of your rights under the CCPA and CRPA.
Exercise of Rights. To exercise your privacy rights under CCPA and CRPA, please contact us and submit a request via the email address as provided in Section 8 (How to Contact Us). In order to protect your privacy, we may require you to provide additional information to demonstrate your identity before we are able to process your request. You may designate an authorized agent to make such request on your behalf in writing or through a power of attorney. We may require the agent to provide proof of your authorization and may need your confirmation directly with us before accepting such a request from an agent.
PEOPLE'S REPUBLIC OF CHINA
If you are located in the mainland China, these additional jurisdiction specific terms will apply to the processing of your personal information.
We, GemPharmatech Co,. Ltd with registered office at 12 Xuefu Road, Jiangbei New Area, Nanjing 210000, P.R. China is the personal information processor of your personal information for the purposes of the Website and applicable data protection laws.
Law Enforcement Agencies and Authorities. The following statement shall be added to the end of Section 5 (How We Share Your Information - Law Enforcement Agencies and Authorities) in the main body of this Privacy Policy:
“The disclosure of your information under this section will also be subject to applicable data protection laws.”
Your Rights. In addition to the rights set out in Section 6 (Your Rights), to the extent permitted by applicable laws, you also have the following rights in connection with your personal information:
o Right to Restriction and Rejection of Processing. In certain circumstances, you may have the right to restrict or reject the processing of your personal information.
o Portability of Personal Information. You may request us to transfer your personal information that we possessed to another personal information processor that is designated by you. We will review your request, and if such request meets the statutory requirements under relevant provisions formulated by the competent authorities, we will duly provide you with the channel for such transfer.
o Right to Request for Explanation. You have the right to request us to explain about our rules as to the processing of your personal information.
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