1. Introduction

1.1 This Privacy Policy explains how EziSurg Medical Co., Ltd. (hereinafter referred to as “we”, “us” or “EziSurg Medical”) collects, uses, discloses, transfers, stores and protects your personal information and what corresponding rights you have in relation to the processing of personal information. Personal information refers to any data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer.

1.2 This Privacy Policy concerns the following information that we collect about you:

A. Information we receive through our website at https://en.ezisurg.com/ and other related communication channels, including, but not limited to, our social media pages, channels, mobile apps and/or blogs where this Privacy Policy is linked to (together “EziSurg Medical Pages”);

B. Information we receive when you inquire about the products or services offered by us (including when you contact us for potential business, when you subscribe to newsletters, or when you contact customer support).

1.3 If this Privacy Policy does not cover certain scenarios where we use your personal information, we will explain these to you separately.

1.4 This Privacy Policy describes:

· What types of personal information do we process about you?

· For what purposes do we process your personal information?

· Disclosure of personal information to third parties

· What about links to third party sites?

· How are your personal information protected?

· Protection of minors’ personal information

· Retention of your personal information

· International data transfer

· Your rights

· Changes and notifications

· Contact Us

1.5 This Privacy Policy may be modified, e.g., as a result of new functionalities on the EziSurg Medical Pages that require the processing of personal information. We therefore advise you to check this Privacy Policy regularly. Any material changes will be notified via the EziSurg Medical Pages.

2. What types of personal information do we process about you?

2.1 We will collect and process the following personal information about you:

2.2 Personal information provided directly by you to us.

(1) When you contact us through EziSurg Medical Pages, we may require you to provide relevant personal information including: your name, email address, phone number or other contact details, your company name, your title, your request, your messages.

(2) When you call our customer services for assistance, we may require you to provide relevant personal information including: your name, email address, shipping address, phone number or other contact details, product information, delivery time, contact and communication records.

(3) When you participate in our online or offline events such as product or service introductions, market activities, seminars, we may require you to provide relevant personal information including: your name, email address, phone number or other contact details, your company name, your title.

The types of EziSurg Medical Pages you are visiting and the nature of the products or services you are requesting will determine the types of personal information we might ask.  

2.3 Information that we collect or generate about you. This includes:

(1) a file with your contact history or communication records;

2.4 We understand that the message you submit, and other information you provide to us may contain other people's personal information. In this case, you must obtain the legal authorization of others before providing it to avoid improper disclosure of others' personal information.

2.5 We do not process sensitive personal information about you.

3. For what purposes do we process your personal information?

3.1 Your personal information may be stored and processed by us in the following ways and for the following purposes:

(1) to understand feedback on our products or services, and to help provide more information on the use of those products or services quickly and easily;

(2) to communicate with potential business partners for business cooperation;

(3) to communicate with you to respond to your enquiries and to provide you with information about us and our products and services as well as any events or other news;

(4) to provide you with our services and products; and

(5) for the management and administration of our business.

3.2 When we use your personal information, we make sure that the usage complies with applicable law.  We are allowed to use your personal information in these ways because of one or more of the following apply:

(1) we have obtained your consent;

(2) we need to do so in order to perform our contractual obligations with you;

(3) we have legal and regulatory obligations that we have to discharge;

(4) we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

(5) the use of your personal information as described is necessary for our legitimate business interests, such as:

◦ allowing us to effectively and efficiently manage and administer the operation of our business;

◦ maintaining compliance with internal policies and procedures;

◦ monitoring the use of our copyrighted materials;

◦ direct marketing;

◦ managing our relationship with you;

◦ enabling quick and easy access to information on EziSurg Medical’s services;

◦ we need to do so in order to perform our contractual obligations with our other customers and third-party providers.

(6) Other situations provided by applicable laws and regulations.

4. Disclosure of personal information to third parties

4.1 We will not share your personal information with any third party except in the following circumstances.

4.2 We may disclose your personal information within EziSurg Medical group where necessary, and the group entities will only use your personal information as described in this Privacy Policy.

4.3 We may provide your personal information to third party agents, contractors or service providers (such as accountants, service provider for payment services, professional advisors, IT and communications providers) who process your personal information on behalf of us and under our instructions. These third parties will be subject to appropriate data protection obligations, and they will only use your personal information as described in this Privacy Policy.

4.4 To the extent required by law, for example if we are under a duty to disclose your personal information in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights, we may provide your personal information to competent authorities.

4.5 If we sell our business or assets, in which case we may need to disclose your personal information to the prospective buyer for due diligence purposes, and if we are acquired by a third party, in which case the personal information held by us about you will be disclosed to the third-party buyer.

5. What about links to third party sites?

The EziSurg Medical Pages may contain references (e.g., via hyperlinks) to other websites or apps, which are offered by third parties. EziSurg Medical is not responsible for the processing of your personal information via these websites or apps. EziSurg Medical advises you to check the privacy policies, the terms and conditions of these websites and apps before downloading the apps or using their service. This Privacy Policy applies only to the EziSurg Medical Pages, and your use of third-party websites and apps is at your own risk.

6. How are your personal information protected?

EziSurg Medical strives to protect your personal information by means of technical and organizational measures that are in line with the industry standards, such as firewalls and secure servers so that access to your personal information is limited to authorised personnel.

7. Protection of minors’ personal information

The EziSurg Medical Pages are designed for adults. We will not knowingly collect any personal information about children under the age of 14. If you are under the age of 14, you may only use the EziSurg Medical Pages with the approval and involvement or a parent or legal guardian.

8. Retention of your personal information

8.1 For how long EziSurg Medical will hold your personal information will vary and will be determined by the following criteria:

· The purpose for which EziSurg Medical is using it: EziSurg Medical is required to retain the personal information for as long as necessary to satisfy or meet the purpose for which it was obtained or any other legal purpose.

· Legal Obligations: Laws or regulations may set a minimum period for which EziSurg Medical must retain your personal information.

9. International data transfer

9.1 EziSurg Medical is a global business and our operations are spread around the world. As a result, we collect and transfer personal information on a global basis. That means that we may transfer your personal information to locations outside of your country. We will ensure that your personal information is protected and transferred in a manner consistent with legal requirements.

9.2 You can obtain more details of the protection given to your personal information when it is transferred outside your country by contacting us using the details set out under the “Contact Us” section below.

10. Your rights

10.1 Applicable data protection laws may give you a number of legal rights in relation to the personal information that we hold about you. Not all data protection laws are the same so not all of these rights apply in all places. Also, some of these rights are subject to qualifications and limitations and exercising these rights may impact on the products and services that we can provide to you. However, we will take appropriate technical measures to enable you to control how we use your personal information where we can do that.

10.2 You may have the following rights (subject to the places where you resident):

· the right to obtain information regarding the processing of your personal information and access to the personal information which we hold about you;

· the right to withdraw your consent to the processing of your personal information at any time. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation;

· in some circumstances, the right to receive some personal information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to EziSurg Medical;

· the right to request that we rectify your personal information if it is inaccurate or incomplete;

· the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;

· the right to object to, or request that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request; and

· the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

10.3 You can exercise your rights by contacting us using the details set out under the “Contact Us” section below.

11. Changes and notifications

11.1 We may update this Privacy Policy from time to time. If there is any material change to this Privacy Policy, we will notify you either by posting a notice the EziSurg Medical Pages or by sending you an email notice or by other means permitted under applicable law. You will be able to see our current Privacy Policy along with its most recent revision date. The revised Privacy Policy will take effect from the date of publication.

11.2 You should review this Privacy Policy periodically. By continuing to use our relevant products or services or visit the EziSurg Medical Pages, you will be deemed to have accepted to the changes or updates to this Privacy Policy. If you do not agree to such changes or updates, you should not use our products or services or visit EziSurg Medical Pages.

12. Contact Us

If you have any further questions about the processing of your personal information or about this Privacy Policy, you can always contact us:

by e-mail: publicaffairs@ezisurg.com

by phone: +86-21-5045 6176

by mailing to: No.399 Miao-Qiao Road, Pudong New District, Shanghai, P.R. China