The User Privacy Protection Policy

This Policy applies to the products and services that we provide for you through the website. If our affiliates use the products or services of our company without an independent privacy policy, this Policy also applies to the part of the products or services.

Before using our products or services, you are sure to carefully read and thoroughly understand this Policy, and use the relevant products or services after confirming the full understanding and consent to this Policy. If you have any questions about this Policy, you can contact us through our published contact information. Once you begin to use our products or services, you fully understand and agree to this Policy, and you agree that we are going to collect, process, store, use, share, and protect your personal information in accordance with this Policy.

1. Collection and processing of personal information

2. The use and disclosure of personal information

3. Protection and preservation of personal information

4. User's rights protection mechanism

5. Notice and revision

6. User appeal channels and feedback mechanism

We know the importance of personal information to you, and we will do our best to keep your personal information safe and reliable. We are committed to maintaining your trust in us, abiding by the following principles and protecting your personal information: principle of consistency of rights and responsibilities, principle of clear purpose, principle of choice and consent, principle of minimum necessity, principle of ensuring safety, principle of subject participation, principle of openness and transparency, etc. At the same time, we promise that we will take appropriate security protection measures to protect your personal information according to the mature safety standards in the industry.

We will collect and use your personal information for the following purposes as described in this Policy:

1. You authorize us to collect and use your personal information

We believe that you submit your Metagenomic next-generation sequencing data and using our service in order to better present the virulence factor genes as well as other relevant information content. Our products and services include core functions that include, but are not limited to, analysis of bacterial virulence genes in your metagenomic next-generation sequencing data for you and those necessary functions to improve our products and services. We may collect, save, and use the following information about you to achieve these functions.This information includes:

1.1 

Information necessary to enable gene detection and subsequent additional functions

1.1.1 Your account information

You first need to sign up for an account to become our user, which can be used within our website. When you register, you need to provide us with the account name, password that you are ready to use, your own email address, and the organization name. We will verify that your identity is valid by sending the email verification code. If you refuse to provide the email address for verification, it will result in unsuccessful registration. You will not be able to enjoy the products and services that we provide.

1.1.2 Query data information

To give you a quick overview of the analysis results for your data, we will collect the data information that you submit and the data information generated by analyzing the data that you submit (including, but not limited to, the sequence information, species information, detection sample types, analysis results, and other related information of your data). We will also use your above data information in order to continuously improve and optimize the functionality of our products and enhance your product experience.

1.2 

Necessary functions to improve our products and services

We may collect your data information, service usage and so on for data analysis to form user portraits to give you priority to the information that you are most relevant to you. We may obtain your other information to provide service and improve the quality of service, including the information you provide when you contact customer service and the information we obtain when you interact with our partners. For the information gathered from your various devices, we may associate them so that we can provide you with a consistent service on these devices. We may combine information from a certain service with information from other services to provide you with personalized content and advice.

2. 

You are fully aware that your authorization is not required to collect and use our personal information in the following circumstances:

2.1 

Related to national security and national defense security;

2.2 

Related to public safety, public health, or major public interests;

2.3 

Related to criminal investigation, prosecution, trial and execution of judgment;

2.4 

To safeguard the major legitimate rights and interests of the life and property of personal information subjects or other individuals, but it is difficult to obtain your consent;

2.5 

The personal information collected is disclosed by the personal information subject to the public itself;

2.6 

Your personal information is collected from the legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

2.7 

Necessary to sign a contract at your request;

2.8 

Necessary to maintain the safe and stable operation of the products and services provided, such as the discovery and disposal of faults of the products and services;

2.9 

Required for legitimate news coverage;

2.10 

Where it is necessary for an academic research institution to conduct statistics or academic research based on public interests, and the personal information contained in the academic research or description results is desensitized when the academic research or description results are provided externally;

2.11 

Other circumstances as stipulated by laws and regulations.

3. 

Rules for using your personal information

3.1 

We will use the collected personal information, in accordance with this Policy, and to realize our product and service functions.

3.2 

Your prior consent is requested when we want to use your personal information for other purposes not specified in this Policy or information collected for a specific purpose for another purpose.

To ensure that the site works properly, we sometimes store small data files called Cookie on a computer or mobile device. Cookie is a plain text file for a web server stored on a computer or a mobile device. The content of a Cookie can only be retrieved or read by the server that created it. Each Cookie is unique to your web browser or mobile app. The Cookie typically contains identifiers, site names, and some numbers and characters. With Cookie, websites can store data such as user preferences or items in the basket. We enable Cookie for the same purpose as most websites or Internet service providers, to improve the user experience. With Cookie, the site is able to remember the user's single visit (using session Cookie) or multiple visits (using permanent Cookie). With Cookie, the site is able to save settings, such as the language of a computer or mobile device, font size, and other browsing preferences. This means that users do not need to reconfigure their user preferences at each visit.If a web site does not use Cookie, the web site treats a web page as a new visitor every time the user opens it. For example, if you log into a site and go to another page, the site will not recognize you and you will be logged out again. We will not use Cookie for any purpose other than the purposes stated in this Policy. You can manage or delete Cookie according to your preferences. See About Cookies.org for details. You can clear all Cookies saved on your computer, and most web browsers have features to block Cookie. But if you do, you need to change user settings every time you visit our site.

1. Sharing

We will not share your personal information with companies, organizations, and individuals other than us and our affiliates, except where:

1.1 

Provide as necessary under applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements;

1.2 

Only by sharing your information can we realize the core functions of our products and services or provide the services you need;

1.3 

Handle your dispute or dispute with others at your needs;

1.4 

Compliance with the relevant agreements signed with you (including the electronic agreements signed online and the corresponding platform rules) or other legal documents agreed to provide;

1.5 

Use on your informed consent based on academic research;

1.6 

Use based on the social and public interest in accordance with laws and regulations.

1.7 

As otherwise agreed upon in this Policy.

We will sign strict data protection agreements with the companies, organizations, and individuals which we share personal information, to require them processing the personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.

2. Transfer

We will not transfer your personal information to any company, organization, or individual, except if:

2.1 

Get your prior express consent or authorization;

2.2 

Provide in accordance with the circumstances necessary for the applicable laws and regulations, the requirements of the legal procedures, and the mandatory administrative or judicial requirements;

2.3 

Compliance with the relevant agreements signed with you (including the electronic agreements signed online and the corresponding platform rules) or other legal documents agreed to provide;

2.4 

Where mergers, acquisitions, asset transfer or similar transactions, if personal information transfer is involved, we will require a new company or organization that holds your personal information to continue to be subject to this Policy, otherwise, we will require the company or organization to renew your authorization consent.

2.5 

As otherwise agreed upon in this Policy.

3. Public disclosure

We will publicly disclose your personal information only under the following circumstances and with safety measures meeting industry standards:

3.1 

Disclosure of personal information you specify under the disclosure method that you expressly agree with;

3.2 

If your personal information is required by laws, regulations, mandatory administrative law enforcement, or judicial requirements, we may publicly disclose your personal information according to the type of personal information and the mode of disclosure required. In compliance with laws and regulations, when we receive a request to disclose the above information, we will require the corresponding legal documents, such as a summons or a letter of inquiry. We firmly believe that information requested from us should be as transparent as the extent permitted by law. We have carefully reviewed all requests to ensure that they have a legal basis and limited to data that law enforcement is legally entitled to access for specific investigative purposes.

4. 

Exceptions to prior authorized consent for the sharing, transfer, or public disclosure of personal information

No prior authorized consent is required to share, transfer, or publicly make disclosure of your personal information under:

4.1 

Providing it under the provisions of laws and regulations or according to law at the requirements of administrative, judicial organs, state departments and other competent departments;

4.2 

To protect the major legal rights and interests of your life or other individuals, but it is difficult to get consent;

4.3 

The personal information that you disclosed to the public by yourself;

4.4 

Personal information is collected from the legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

According to the law, sharing and transfer of desensitized personal information, and ensuring that the data receiver cannot recover and identify the personal information subject, does not belong to the external sharing, transfer and public disclosure of personal information, the preservation and processing of such information will not need to inform you and obtain your consent.

1. Our technology and measures to protect your personal information

We attach great importance to personal information security and take all reasonably feasible measures to protect your personal information:

1.1 

Data security technical measures

We will adopt safety protection measures that meet industry standards, including establishing reasonable institutional specifications and safety technologies to prevent your personal information from unauthorized access, modification and avoid damage or loss of data. We will take everything reasonably feasible to protect your personal information.

1.2 

Other security measures that we have taken to protect our personal information

We manage the storage and use of personal information by establishing a data classification and classification system, data security management norms, and data security development norms. We conduct comprehensive security control of the data by confidentiality agreements with information contact, monitoring, and audit mechanisms.

1.3 

We only allow access to employees and partners of the company necessary to access personal information. We also require all personnel who may have access to your personal information to perform the corresponding confidentiality obligations.

1.4 

We will take all reasonably feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period required to meet the purposes stated in this Policy, unless the retention period is extended or permitted by law.

1.5 

The Internet is not an absolutely secure environment, and e-mail, instant messaging, social software and other communication mode with other users cannot be fully encrypted. We suggest that you use complex passwords when using such tools and pay attention to protect your personal information.We will try our best to ensure the security of any information that you send to us. If our physical, technical, or management protection facilities are damaged by a third party, resulting in unauthorized access, public disclosure, tampering, or destruction of information, and damage to your legitimate rights and interests, you have the right to pursue a third party, and we will actively cooperate.

1.6 

After the unfortunate personal information security incident, we will timely inform you in accordance with the requirements of laws and regulations: Basic information and possible impact of security events, disposal measures that we have taken or will take, suggestions that you can independently prevent and reduce risks, remedies, etc. We will immediately inform you of the relevant situation of the event by mail, letter, telephone number, push notice and other ways. When it is difficult to inform the subject of personal information one by one, we will make an announcement in a reasonable and effective way.

1.7 

If you have any questions about our personal information protection, contact us through the contact information agreed at the bottom of this Policy. If you find that your personal information is leaked, especially your account and password have leaked, you can contact us through the agreed contact information of "How to Contact Us" at the bottom of this Policy, so that we can take appropriate measures.

2. Storage of your personal information

2.1 

Your personal information will be stored within the PRC.

2.2 

Unless otherwise specified by laws and regulations, we will save your personal information until your account number is cancelled. We promise that this is to guarantee your interest in the use of our products and services.

2.3 

If we terminate the services or operations, we will notify you at least 60 days prior, and delete or anonymize your personal information after the termination of the services or operations.

Our products, websites, and services are mainly intended for adults. Children (minors under the age of 14) shall not create their own user accounts without the consent of their parents or guardians. Collecting a child's personal information with parental consent, we will only use or disclose this data if necessary as permitted by law, the express consent of the parent or guardian, or the protection of the child. If we find ourselves collecting the child's personal information without obtaining prior verifiable parental consent, we manage to remove the relevant data as soon as possible.

We attach great importance to your attention to your personal information, and do our best to protect your right to query, correct, and delete your personal information, so as to make you have the full ability to protect your privacy and security. Your rights will include:

1. 

Query and correct your personal information

You have the right to inquire and correct your personal information at any time except provided by laws and regulations, including:

1.1 

Your account information, email address, etc;

1.2 

When you need query or correct for other personal information that you generate in using our products and services, you can contact us at any time following the "How to Contact us" contained in this Policy. We will promptly respond to your request .

1.3 

You cannot query and correct your personal information: in addition to the information listed above, some of your personal information we can not provide you with the inquiry and correction services. This information is mainly designed to enhance the information about your device collected by your user experience and the personal information generated when you use the additional features. The above information will be used within the scope of your authorization, you cannot query and correct, but you can contact us to delete or do anonymization processing.

You can contact us and correct your personal information through rvfscan@hugobiotech.com.

2. 

Delete your personal information

2.1 

If our handling of personal information is in violation of laws and regulations;

2.2 

If we collect and use your personal information without your consent;

2.3 

If our act of handling personal information violates our agreement with you;

2.4 

If you no longer use our products or services, or if you cancel your personal account;

2.5 

If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also simultaneously notify the entities that obtain your personal information from us to timely delete it, unless otherwise provided by laws and regulations, or that these entities receive your independent authorization.

You can contact us to delete your personal information through rvfscan@hugobiotech.com.

3. 

Change the scope of your authorization or withdraw your authorization

You can change the scope of our continue to collect personal information or withdraw your authorization by canceling account, closure device functions and other ways.

Please understand that each business function needs some basic personal information to complete, and when you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to withdrawal consent or authorization and no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous personal information processing based on your authorization.

4. Cancel account

After you cancel your account, we will stop providing products and services for you , and according to your requirements, we will delete your personal information unless otherwise provided for by laws and regulations.

You can contact us to cancel your account on the website at rvfscan@hugobiotech.com.

5. 

Responding to your request

If you are unable to query, correct or delete your personal information as described above, or if you need to inquire, correct or delete other personal information that you generate when you use our products or services, or that you believe that we have any violation of laws and regulations or agreements with you regarding the collection or use of personal information, you may contact us by way under this Policy.

We will not be able to respond to your request if:

5.1 

Related to national security and national defense security;

5.2 

Related to public safety, public health, or major public interests;

5.3 

Related to criminal investigation, prosecution and trial;

5.4 

There is sufficient evidence that you have subjective malice or abuse of rights;

5.5 

Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.

Your personal information collected by Hugobiotech may be processed in the country /region where you use the product or services, or in Hugobiotech or its affiliates or its subsidiaries ,or other countries /regions where service providers, business partners have institutions,or to receive access from these countries /regions. Data protection laws may differ in these countries/regions. In such cases, Hugobiotech will take steps to ensure that the data we have collected is processed in accordance with the requirements of this Policy and the applicable law. Including when the personal information of data subject located in the EU is transferred to not recognized equivalent data protection level countries or regions, Hugobiotech will use various legal mechanisms, such as signing the standard contract terms that European Commission approved or request your consent to cross-border transfer of personal information, or implementing security measures such as data anonymity before cross-border data transfer. Personal information collected and processed during our operations in the PRC will be stored within the PRC.

1. 

This Policy will be updated to provide you with better services and as we develop. However, we will not reduce your rights under this Policy without your express consent. We will issue an updated version on our platform and by announcements or in other appropriate ways before taking effect, and please keep an update on the latest privacy policies.

2. 

We also provide more distinct notifications of major changes (we describe the specific changes to the Policy by including, but not limited to, email, text messages, or special tips on the browsing page etc. ).

Major changes referred to in this Policy include, but are not limited to:

2.1 

Our service model has changed significantly. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information;

2.2 

We have undergone significant changes in the ownership structure, organizational structure, etc. Such as business adjustment, bankruptcy,mergers etc causing owner changes;

2.3 

The main objects of personal information sharing, transfer or public disclosure shall change;

2.4 

Your rights to participate in personal information processing and their exercise methods have changed significantly;

2.5 

When the department responsible for handling personal information security, contact information and complaint channels change;

2.6 

When the personal information security impact assessment reports indicate the presence of high risk.

1. 

What needs to be announced to you is that the service operator is Hugobiotech Beijing Co., Ltd. If you have any questions, comments, or suggestions on matters related to this Policy or your personal information, please email rvfscan@hugobiotech.com to contact us.

2. 

We have set up a Personal Information Protection Commissioner that you can contact by sending an email to rvfscan@hugobiotech.com.

3. 

For safety, we may require you to provide a written request, or show off your identity in other ways. Generally, we will respond within 60 business days after receiving your feedback and verifying your identity. If you are not satisfied with our response, especially if our personal information processing behavior damages your legitimate rights and interests, you can also complain to the Consumer Rights Protection Department or file a lawsuit in the court where the defendant lives.

4. 

We promise to protect your privacy because we respect each of our users. We do our best to do it well, and we hope to win your trust!

Last updated date: [20220101 ]