Virtue Diagnostics (which includes Suzhou Virtue Diagnostics Co., Ltd. and its affiliates, hereinafter referred to as “Virtue,” “we,” “our,” or “us”) respects and is committed to protecting your privacy. This Privacy Policy (hereinafter referred to as the “Policy”) describes how we collect, use, disclose, share, transfer, and store the information you provide to us when you use our digital online services and related support services (hereinafter referred to as the “Services”), and outlines your rights concerning such information.

We recognize the importance of your personal information and are dedicated to safeguarding its security. We are committed to maintaining your trust and pledge to adhere to the following principles in protecting your personal information: lawfulness, fairness, necessity and good faith, alignment of rights and responsibilities, purpose limitation, informed consent, data minimization, security assurance, data-subject participation, and transparency. Furthermore, we commit to adopting appropriate security protection measures in accordance with industry-standard security standards to protect your personal information.

Please read this Policy carefully to understand our practices regarding your information. If you have any questions, please contact us using any of the methods provided in Section VI “Contact Us” of this Policy.

This Policy will help you understand the following:

I. How We Collect and Use Your Personal Information

Personal information refers to any information recorded electronically or by other means that relates to an identified or identifiable natural person, excluding anonymized information. Sensitive personal information refers to personal information that, if leaked or illegally used, may easily infringe upon human dignity or endanger personal or property safety, including but not limited to identification numbers, personal biometric information, bank account numbers, property information, location tracks, transaction information, and personal information of children under the age of 14 (inclusive).

Please note that we use bold font to draw your specific attention to the collection of sensitive personal information. We will only collect your sensitive personal information where there is a specific purpose and sufficient necessity, and we undertake to implement strict protective measures. Prior to collecting any of your sensitive personal information, we will obtain your separate consent via a pop-up window or other means. Where laws or administrative regulations require written consent, we will obtain your written consent. Before providing your consent, please ensure you have carefully considered and confirmed that such provision is appropriate.
 

(A) Collection and Use for Basic Functions

The purpose of collecting personal information is to provide you with our Services and to ensure our compliance with applicable laws, regulations, and other regulatory requirements. Specifically, for the following scenarios, you need to agree to provide the following information for us to securely and effectively implement these basic functions; otherwise, you may be unable to enjoy the corresponding services.

1. Live Event or Offline Exhibition Registration:
   To enable your successful registration for our live events or offline exhibitions, we may collect your name, areas of interest, company, job title, email address, mailing address, postal code, mobile number, and other personal information. The purpose of collecting this information is to accurately and conveniently notify you of event or exhibition details (e.g., webinar links) in a timely manner upon successful registration.

2. Direct Marketing:
   To enable you to successfully receive marketing and promotional information that you have subscribed to from us, we may collect your email address, mobile number, name, and other personal information. The purpose is to accurately and conveniently deliver the subscribed marketing content to you in a timely manner. We will clearly identify ourselves and provide our contact details within the sent materials, and provide you with a means to opt-out of future communications.

3. Digital Recruitment:
   To enable you to apply for positions you are interested in through our online recruitment platforms or official recruitment accounts, we may collect your name, email address, phone number, residential address, mailing address, date of birth, gender, marital status, educational background, professional qualifications, work experience, and other information. We collect this information to assess your suitability for the applied position, use it as a basis for screening potential candidates, and contact you to arrange subsequent recruitment interviews and onboarding processes.

(B) How We Obtain Your Information from Third Parties

In circumstances permitted by law, we may obtain your personal information from third parties.

If the processing of your personal information in the course of our business operations exceeds the scope of the consent you originally provided to the third-party service provider, we will obtain your explicit consent before processing such information. Additionally, we will strictly comply with relevant laws and regulations and require the third-party service provider to ensure the legality of the information it provides.

(C) Non-Personal Information We Collect

We may also collect other information that cannot directly or indirectly identify a specific individual and does not constitute personal information under applicable local laws. Such information is referred to as non-personal information. The purpose of collecting such information is to improve the Services we provide to you. The categories and quantity of information collected depend on how you use our Services.

II. How We Entrust Processing, Share, Transfer, and Publicly Disclose Your Personal Information

(A) Entrusted Processing

Virtue may engage other companies to process your personal information on our behalf. We undertake to comply with the following requirements when entrusting third parties to process personal information:

1. Ensure the scope of the commissioned analysis does not exceed the scope for which we have obtained your authorization and consent, unless such consent is not required.
2. Conduct a prior assessment of the of the processor’s data security capabilities to ensure compliance with applicable legal requirements..
3. Stipulate the responsibilities and obligations of the entrusted processor through contracts, requiring them to comply with applicable laws and to adhere to standards no less protective than those we owe to you.
4. Accurately record and retain details of the entrusted processing of personal information to ensure the security of your information and maintain effective access and control over your personal information processed under the entrustment.
5. Require the entrusted processor to delete your personal information and destroy all data copies upon termination of the entrustment relationship, or when we delete or anonymize your personal information according to this Policy.

(B) Sharing

Generally, we do not share your personal information externally, except in the following circumstances:

1. After obtaining your explicit consent, Virtue will share information within the scope of your authorization with the third parties you designate.
2. Certain components of our Services are provided by third-party service providers. To this end, we need to provide them with portions of your personal information, for example, for IT services, customer support services, email delivery services, and other similar services, to ensure they can provide services to us. Some data sharing with third parties may be conducted through Application Programming Interfaces (APIs) or Software Development Kits (SDKs).

   If we share your personal information with these third parties, we will employ measures such as encryption to safeguard your information’s security. We will conduct reasonable reviews of the data security environment of the companies and organizations with whom we share personal information and enter into strict data processing agreements with them, requiring them to implement adequate protective measures for your information and strictly comply with relevant laws, regulations, and regulatory requirements.

3. In connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may disclose your personal information to affiliates or other third parties. In such cases, you will be notified via email and/or a notice on our website regarding the change in ownership, potential incompatible new uses of your personal information, and choices you may have regarding your information.
4. When we believe it is necessary or appropriate to: (a) comply with applicable laws and regulations; (b) comply with legal process; (c) respond to requests from public authorities and government agencies, including those outside your country of residence; (d) enforce our terms and conditions; (e) protect our operations, business, and systems; (f) protect the rights, privacy, safety, or property of Virtue, you, or others; and (g) seek available remedies or limit damages we may sustain.
5. Disclose your personal information to our subsidiaries or affiliates for the purpose of conducting regular business activities.