Privacy Policy of Arctic Vision Official Website

This Policy was last changed on September 1st, 2020.

Dear Users,

Thank you for visiting Arctic Vision Official Website (www.arcticvision.com, “Official Website”), which is operated by Arctic Vision (Shanghai) Biotechnology Co., Ltd. and its related parties (“Arctic Vision”, “we” or “us”). We respect your privacy and value the trust you place in us when you provide your personal data with us. This Privacy Policy of Arctic Vision Official Website (“Policy”) sets out how we, including how any member of Arctic Vision Group Company to which we legitimately transfer your personal data, collect and use personal data you provide to us through this Official Website. We also inform you why we use your personal data collected through the Official Website, with whom we share it, the rights to which you may be entitled and your choices about our use of such personal data. If you have any questions, comments or complaints, please contact us through the contact information provided in Section XI.

This Policy will help you understand the following information:

I. The scope of this Policy

II. How we collect and use your personal data

III. Exceptions which do not require authority and consent

IV. How we use Cookies

V. How we store your personal data

VI. How we share, transfer, and publicly disclose your personal data

VII. How we protect your personal data

VIII. Your rights to personal data

IX. How we protect personal data about minors

X. Revision to this policy

XI. Contact us

XII. Effectiveness of this Policy

I. THE SCOPE OF THIS POLICY

This Policy applies to the services we provide to you through the Official Website. In particular, this Policy does not apply to services provided to you by other third parties, such as the third-party services or websites you link to through the Official Website. You understand that these services are provided to you independently by third parties who will be solely responsible for the processing of your personal data in accordance with their policies.

We may formulate specific personal data protection policies, statements, notices, etc. (“Specific Policies”) with respect to specific online or offline services or products. If there are specific provisions in other Specific Policies, these Specific Policies shall prevail. For matters not provided in the Specific Policies, this Policy shall prevail.

II. HOW WE COLLECT AND USE YOUR PERSONAL DATA

Personal data means any information saved in electronic form or otherwise that can be used independently or together with other information to identify a natural person or reflect the activities of a natural person.

When you use the Official Website, we will collect and use the personal data necessary for the provision of relevant services as follows; if you do not use the services, we will not collect the corresponding information.

1. Browse the Official Website

When you browse the Official Website through a computer or mobile device, we will collect your following information:

a) Technical information, such as Internet Protocol (IP) addresses, browser types and versions, time zone settings and locations, browser plug-in types and versions, operating systems and platforms, visit identification code, IP region, source of link, the first page, network service provider, language environment, screen resolution, screen color (bits), Flash version, Cookie settings, JAVA settings, open time, stay time, address of stay page and other technologies you use on your device to access and browse Official Websites.

b) Use information, such as information about how you use our website, products and services, such as your search term, visit time, visit duration, number of pages visited, page last stayed, last visit time, visit type (whether it is your first visit), visit frequency.

2. Leave a message

When you leave a message to us on the Official Website, we will collect your name, e-mail address, telephone number, and the content you voluntarily fill in.

You understand and agree that after reading your message, we may contact you through e-mail, site message, phone, SMS, system message, etc., to promote our products or services to you. Each newsletter you receive from us will inform you how to unsubscribe from us. In addition, if you are not willing to receive message from us, or if you want to delete your name from our mailing list, you can also contact us through the contact information provided in Section XI.

3. Subscribe our newsletter

When you subscribe our newsletter through Official Website, we will collect your e-mail address you voluntarily provide. Each newsletter you receive from us will inform you how to unsubscribe from us. In addition, if you are not willing to receive message from us, or if you want to delete your name from our mailing list, you can also contact us through the contact information provided in Section XI.

4. Use of anonymized information

Please note that we also collect, use and share aggregated information, such as statistics or structural data. Aggregate data is not personal data but may be derived from your personal data, because it does not directly or indirectly show your identity, and we have the right to use it for any legitimate purpose (for example, we may aggregate your usage information to find out how many users visit specific website functions, study consumer and market preferences, improve existing products and services, and conduct financial forecasting and modeling). If we combine or associate the aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined information as personal data and will process it in accordance with the provisions of this Policy.

III. EXCEPTIONS WHICH DO NOT REQUIRE AUTHORITY AND CONSENT

Subject to the applicable laws and regulations, we may collect and use your personal data without the need to obtain your consent under any of the following circumstances:

1.where the collection and use are in direct relation to performance of our obligations under laws and regulations;

2.where the collection and use are in direct relation to national security or national defense;

3.where the collection and use are in direct relation to public security, public sanitation, or major public benefits;

4. where the collection and use are in direct relation to criminal investigations, prosecutions, court trials, enforcement of rulings, etc.;

5.where the collection and use are for the sake of safeguarding vital legal rights and interests, such as the life and property of personal data subjects or other individuals, but it is difficult to obtain your consent;

6.where academic research institutions use the information for statistics and academic research purposes for the sake of public interest, or publish the research results or provide them to other parties to the extent that such results are de-identified and cannot re-identify the data subjects; and

7.other circumstances specified by laws and regulations.

IV. HOW WE USE COOKIES

A cookie is a small text file that a website stores on your computer or mobile device when you visit the site. The text in a cookie often consists of identifiers, site names, and some numbers and characters. We can collect and store data about your preference with Cookies. We will not use Cookies for any other purpose not described in this policy. You can manage or delete Cookies according to your preferences. For details, please visit AboutCookies.org. You can clear all the cookies stored on your computer, and most web browsers have the function of blocking Cookies. But if you do so, you need to change the user settings by yourself every time you visit our Official Website. You can learn more about changing browser settings by visit the following links: <Internet Explorer>、<Google Chrome>、<Mozilla Firefox>、<Safari> and <Opera>.

V. HOW WE STORE YOUR PERSONAL DATA

1.Where we store your personal data

The personal data we collect will be stored in the region of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”). Although the data protection laws in Hong Kong may differ from those in the country where you reside, we will ensure that appropriate safeguards are implemented to ensure an adequate level of protection of your personal data as laws or regulations in your own country.

2.How long we store your personal data

We will retain your personal data only for a limited period of time needed to fulfil the purposes of processing mentioned above, unless a longer storage period is required by law. The storage period will depend on following standards and the longest period of time shall prevail.

a) provide the products or services you agree to use;

b) ensure the safety and quality of our products and services;

c) a longer period you agree to; and

d) other special agreements on the storage period.

Your personal data will be deleted or anonymized after the storage period.

If we stop operating our Official Website, we will give a notice to you. At the same time, we will delete or anonymize your personal data and will no longer collect your personal data.

VI. HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR PERSONAL DATA

1. Share

We will not share your personal data except in the following circumstances:

a) with your explicit consent, we will share your personal data with other parties.

b) we may share your personal data with others in accordance with laws and regulations, the needs of litigation dispute settlement, or the requirements of administrative and judicial authorities.

c) to the extent permitted by laws and regulations, it is necessary to share your personal data in order to protect us, our affiliates or partners, you or other users of Arctic Vision or the public interest, property or security from damage.

d) in order to provide services to you, we may share your personal data with our affiliates. However, we will only share necessary personal data, and the use of your personal data by our affiliates is subject to this Policy, or the affiliate’s policy which you authorized and consented and provides your personal data with substantially the same level of protection as this Policy. Our affiliates and we will strictly comply with this Policy and other security policies of Arctic Vision.

2. Transfer

We will not transfer your personal data to any other company, organization or individual except:

a) obtain your explicit consent or authorization in advance;

b) provide such data in accordance with the applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements;

c) provide such data in accordance with the relevant agreements entered between you and us (including the electronic agreements signed online and the corresponding platform rules);

d) with the development of our business, it is possible for us and our affiliates to carry out merger, acquisition, asset transfer or other similar transactions. If the relevant transaction involves the transfer of your personal data, we will require the company, organization and individual acquiring your personal data to continue to be bound by this Policy, otherwise we will require the company, organization and individual to obtain your consent again.

3. Publicly disclose

We may only publicly disclose your personal data under the following circumstances:

a) after obtaining your explicit consent; and

b) disclosure under the law: we may publicly disclose your personal data as required by laws, under legal procedures, in lawsuits or upon compulsory requirements of competent authorities under the government.

VII. HOW WE PROTECT YOUR PERSONAL DATA

We have taken security protection measures in line with industry standards to protect the personal data you provide, so as to prevent unauthorized access, public disclosure, use, modification, damage or loss of data.

1. Arctic Vision has appointed special persons in charge of personal data protection, who is responsible for dealing with all matters related to products and services of Arctic Vision that may involve users’ personal data, as well as planning and formulating the company’s policies, reviewing the data protection policies for each product, supervising the working principle and information processing mechanism of each product, etc.

Name: Yi (York) Chen

Contact information: yorkchen@arcticvision.com / Communications@arcticvision.com

2. We have formulated special management policies, procedures, systems to ensure the security of data. For example, we have formulated the general policies and security strategy for information security, established the security management system with respect to all aspects and delineated the security protection responsibility for each department and position.

3. We deploy the access control mechanism on the server side, and adopt the principle of minimum authorization for the staff who may contact your personal data.

4. We will audit and monitor the account of the server operation. If we find the server operating system has any security loopholes, we will upgrade the server security in time to ensure the security of all server systems and applications.

5. We have formulated the emergency plan for network security incidents and allocated sufficient resources to ensure the implementation of the emergency plan. If our physical, technical or management protection measures are unfortunately damaged, we will launch the emergency plan in time to prevent the expansion of the safety incident, report to the national competent authority in accordance with the requirements of laws and regulations, and inform you of the basic situation, possible impact, measures taken or measures to be taken in a reasonable and effective way such as push or announcement, etc.

VIII. YOUR RIGHTS TO PERSONAL DATA

When you use the Official Website, you may at any time exercise certain rights with regard to your personal data you may have under applicable law and regulation, including the following rights:

1. Access and rectify your personal data

You can contact us to access and rectify your personal data through the contact information provided in Section XI below.

2. Delete your personal data

Under any of the following circumstances, you may raise a request for deletion of your personal data:

a)  When our collection of personal data does not obtain your consent and violates laws and regulations

b) When our processing of personal data violates laws or regulations.

c) When our use and processing of personal data violates our agreement with you.

d) When you no longer use our products or services.

e) When we no longer provide you with any products or services.

You can contact us to delete your personal data through the contact information provided in Section XI, and we will reply to you within fifteen (15) working days. When we delete your personal data from the server, we may not delete the corresponding data from the backup system immediately, but we will delete this information when the backup is updated.

3. Withdraw your consent

Our services can only be provided with certain basic personal data. In terms of the collection and use of additionally collected personal data, you may grant or withdraw your authority and consent at any time. After you have withdrawn your consent, we will cease processing the corresponding personal data. However, your decision to withdraw your consent does not affect the previous processing of personal data based on your authority. You can contact us to withdraw your consent through the contact information provided in Section XI.

IX.  HOW WE PROCESS INFORMATION ABOUT MINORS

The Official Website mainly target adult users. Without the consent of the parents or guardians, minors under the age of 14 may not use our products or services.

For our collection of minors’ personal data with parents’ consent, we will only use or publicly disclose this information subject to laws and regulations with the explicit consent of the parents or guardians, or as necessary to protect the minors.

If we find that we have collected minors’ personal data without prior verifiable parents’ consent, we will try to delete the relevant data as soon as possible.

X.   REVISION TO THIS POLICY

We may revise this Policy from time to time. We will not reduce your rights due under this Policy, without your explicit consent.

In the case of material changes, we will provide your prompt and conspicuous notification. You can also browse the Official Website at any time to view the latest Policy.

For the purpose of this Policy, major changes include but are not limited to:

1. Significant changes to our service mode, such as the purposes of processing personal data, categories of personal data to be processed, the ways to use personal data, etc.;

2. Significant changes to the ownership structure, organizational structure, etc., such as changes to the owners as a result of business adjustments, bankruptcy, mergers and acquisitions;

3. Changes to recipient with whom we may share or transfer personal data, or public disclosure of personal data;

4. Significant changes to your rights to personal data and the ways in which you can exercise such rights;

5. Changes to the security policy with respect to personal data, contact information of such department, or complaint channels; and

6. Changes made due to high risks identified in the security impact assessment report for personal data.

After such changes and modifications, if you continue to use our Official Website, it means that you agree to be bound by this revised Policy.

XI.  CONTACT US

Arctic Vision (Shanghai) Biotechnology Co., Ltd. is operator of the Official Website and the controller of your personal data. Our registered address is Floor 3, Building 1, 400 Fangchun Road, China (Shanghai) Pilot Free Trade Zone. If you have any questions, comments, suggestions or complaints about our Policy and our processing of your personal data, please send email to communications@arcticvision.com to contact us.

Under normal circumstances, we will respond to your request within fifteen (15) working days. You understand that the processing time for your request may be longer than the above time limit due to document review, information verification, operational procedures, etc.

XII. EFFECTIVENESS OF THIS POLICY

This Policy was last changed on [September 1], 2020 and will take effect on [September 1], 2020.

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Room 1732, Century Century Tower 1, Century Avenue, Pudong New District, Shanghai, China
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