Privacy Policy

This policy applies solely to the "Health Monitor" product or service. Last Updated: {September 1, 2023}

This policy is designed to help you understand the following:

1. How we collect and use your user information.

2. How we use Cookies and similar technologies.

3. How we share, transfer, and publicly disclose your user information.

4. How we safeguard your user information.

5. Your rights.

6. How we handle personal information of minors.

7. Storage and cross-border transfer of your user information.

8. How this policy is updated.

9. How to contact us.

We deeply recognize the significance of your user information and will do our utmost to ensure the security and reliability of your user information. We are committed to maintaining your trust by adhering to principles such as the Consistency of Rights and Responsibilities Principle, Clear Purpose Principle, Choice and Consent Principle, Minimal Necessity Principle, Security Assurance Principle, Subject Participation Principle, and Transparency Principle. Furthermore, we pledge to employ industry-standard security measures to protect your user information.

Prior to using our product(s) or service(s), please carefully read and comprehend this privacy policy.

1. How We Collect and Use Your User Information

(1) Information Collected and Used During Your Use of Our Products or Services

We will only collect and use your user information for the business purposes described in this policy. The purpose of collecting user information is to provide you with products or services. You have the right to choose whether to provide this information. However, in most cases, if you do not provide it, we may not be able to provide you with the corresponding services or address the issues you encounter:

When you use our services, we are allowed to collect information that you provide to us voluntarily or information that is necessary for providing you with the service. This information may include personal identification information, device information, log information, IP addresses, location information, and more. The user information we collect will be used for purposes such as identity verification, customer service, security measures, displaying activities, and health monitoring records.

The information you provide will continue to be authorized for our use during your use of our service. When you stop using push services, we will cease using and delete the aforementioned information.

We assure you that we will de-identify or anonymize the collected user information in accordance with the law. Information that cannot individually or in combination with other information identify the personal identity of a natural person does not constitute personal information under the legal meaning. If we identify your personal identity by combining non-personal information with other information or using it in combination with your personal information, we will treat and protect such information as your personal information in accordance with this privacy policy.

For the purpose of better operating and improving our technology and services, or due to changes in business strategies, when the collection, usage, or processing of user information required for our provided products or services goes beyond the scope mentioned above, or when we intend to use the collected user information for purposes not specified in this privacy policy, or when we intend to use information collected for specific purposes for other purposes, we will notify you within a reasonable period after obtaining user information or before processing user information, and obtain your authorization and consent.

(2) Exceptions to Obtaining Authorization and Consent

Please understand that according to laws, regulations, and relevant national standards, there are circumstances in which we do not need to obtain your authorization and consent for collecting and using your user information:

1. Directly related to national security and national defense;

2. Directly related to public safety, public health, and significant public interests;

3. Directly related to criminal investigations, prosecutions, trials, and execution of judgments;

4. Necessary for protecting the vital legal rights of you or other individuals' lives, property, etc., but it is difficult to obtain the individual's consent;

5. The collected user information has been voluntarily disclosed to the public;

6. Collected your user information from legally disclosed information sources, such as legal news reports, government information releases, and more;

7. Necessary for signing or performing a contract at your request;

8. Necessary to ensure the secure and stable operation of software and related services, such as discovering and addressing faults in software and related services;

9. When the information controller is a news entity and collecting the information is necessary for legitimate news reporting activities;

10. Necessary for academic research institutions to conduct statistical or academic research for public interests and provide the results of academic research or descriptions to the public after de-identifying the personal information contained in the results;

11. Other circumstances stipulated by laws and regulations.

**2. How We Use Cookies and Similar Technologies**

**(1) Cookies**

To ensure the proper functioning of our website, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, websites can store your browsing preference data.

We will not use cookies for purposes other than those described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies stored on your computer, and most web browsers have functions to block cookies. However, if you do so, you may need to manually adjust user settings each time you visit our website.

**(2) Web Beacons and Pixel Tags**

In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our website. For example, emails we send you may contain click-through URLs linking to content on our website.

If you click on such a link, we will track this click to help us understand your product or service preferences and improve customer service. Web beacons are often transparent images embedded in websites or emails. Through pixel tags in emails, we can determine if an email has been opened. If you do not wish to be tracked in this way, you can unsubscribe from our mailing list at any time.

**(3) Do Not Track**

Many web browsers offer a Do Not Track feature, which sends Do Not Track requests to websites. Currently, major internet standard organizations have not established policies specifying how websites should respond to such requests. However, if your browser enables Do Not Track, all of our websites will respect your choice.

3. How We Share, Transfer, and Publicly Disclose Your User Information

(1) Sharing

We will not share your user information with any other companies, organizations, or individuals, except in the following circumstances:

1. Sharing with explicit consent: With your explicit consent, we will share your user information with other parties.

2. We may share your user information with external parties as required by laws and regulations, or by mandatory requests from government authorities.

3. Sharing with our affiliated companies: Your user information may be shared with our affiliated companies. We will only share the necessary user information and it will be subject to the purposes stated in this privacy policy. If our affiliated companies intend to change the purpose of processing user information, they will seek your authorization and consent again.

4. Sharing with authorized partners: For the purpose of achieving the objectives stated in this policy, some of our services may be provided by authorized partners. We may share certain user information with partners to provide better customer service and user experience. We will only share user information for legitimate, reasonable, necessary, specific, and clear purposes and only the information necessary to provide the service will be shared. To better operate and improve our technology and services, you agree that we and our authorized partners can use the collected information for other services and purposes in compliance with relevant laws and regulations.

For companies, organizations, and individuals with whom we share user information, we will sign strict confidentiality agreements with them, requiring them to process user information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.

(2) Transfer

We will not transfer your user information to any other companies, organizations, or individuals, except in the following circumstances:

1. Transfer with explicit consent: With your explicit consent, we will transfer your user information to other parties;

2. In cases of merger, acquisition, or bankruptcy liquidation, if user information transfer is involved, we will request the new company or organization holding your user information to continue to be bound by this privacy policy. Otherwise, we will ask the company or organization to obtain your authorization and consent again.

(3) Public Disclosure

We will only publicly disclose your user information under the following circumstances:

1. With your explicit consent;

2. Based on legal disclosure: In cases where there are legal requirements, legal proceedings, litigation, or mandatory requests from government authorities, we may publicly disclose your user information.

(4) Exceptions to Obtaining Prior Authorization and Consent for Sharing, Transferring, and Publicly Disclosing Information

Please understand that according to laws, regulations, and relevant national standards, there are circumstances in which we do not need to obtain your prior authorization and consent to share, transfer, or publicly disclose your user information:

1. Directly related to national security and national defense;

2. Directly related to public safety, public health, and significant public interests;

3. Directly related to criminal investigations, prosecutions, trials, and execution of judgments;

4. Necessary for protecting the vital legal rights of you or other individuals' lives, property, etc., but it is difficult to obtain the individual's consent;

5. Information that you have voluntarily disclosed to the public;

6. User information collected from legally disclosed information sources, such as legal news reports, government information releases, and more.

4. How We Protect Your User Information

(1) We have implemented security measures that comply with industry standards to protect the user information you provide from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonable and feasible measures to protect your user information. For instance, data exchange between your browser and the "service" is protected by SSL encryption; we also provide HTTPS secure browsing on our website; we use encryption technology to ensure data confidentiality; we deploy trusted protection mechanisms to prevent malicious attacks on data; we implement access control mechanisms to ensure that only authorized personnel can access user information; and we offer security and privacy protection training courses to enhance our employees' awareness of the importance of safeguarding user information.

(2) We will take all reasonable and feasible measures to ensure that irrelevant user information is not collected. We will only retain your user information for the period required to achieve the purposes described in this policy, unless an extension of the retention period is necessary or permitted by law.

(3) The internet is not an absolutely secure environment, and methods of communication such as email, instant messaging, and interactions with other users are not encrypted. We strongly advise against sending user information through such means.

(4) The internet environment is not entirely secure. We will make every effort to ensure the security of any information you send to us. Despite our considerable efforts and implementation of all reasonable and necessary measures, it is still possible that your user information could be subject to illegal access, theft, alteration, or destruction, which may lead to damage to your legitimate rights and interests. Please understand the above risks associated with the information network and voluntarily bear them.

**(5) In the unfortunate event of a security incident involving user information, we will promptly inform you in accordance with the requirements of laws and regulations. We will notify you of the basic details and potential impact of the security incident, the measures we have taken or will take, suggestions for self-prevention and risk reduction, and remedies available to you. We will inform you of the incident through means such as email, letters, phone calls, push notifications, etc. When it is difficult to inform each individual user, we will make reasonable and effective public announcements. Additionally, we will actively report the handling of the user information security incident to regulatory authorities, as required.

5. Your Rights

According to relevant laws, regulations, standards, and the prevailing practices of other countries and regions, we ensure that you have the following rights over your user information:

(1) Access to Your User Information

You have the right to access your user information, except as otherwise stipulated by laws and regulations. If you wish to exercise your right to access data, you can do so through the following methods: ① Go to the personal center to view personal information; ② Contact us to obtain your personal information.

If you are unable to access this user information through the above links, you can always contact us via our web form or send an email to {support@unionurture.com}. We will respond to your access request within 30 days.

For other user information generated during your use of our products or services, as long as it does not require excessive effort on our part, we will provide it to you. If you wish to exercise your right to access data, please send an email to {support@unionurture.com}.

(2) Correction of Your User Information

If you find that the user information we process about you is incorrect, you have the right to request correction. You can make a correction request using the methods listed in "Access to Your User Information." If you are unable to correct this user information through the above links, you can always contact us via our web form or send an email to {support@unionurture.com}. We will respond to your correction request within 30 days.

(3) Deletion of Your User Information

You can request the deletion of user information under the following circumstances:

1. If our processing of user information violates laws and regulations;

2. If we collect and use your user information without obtaining your consent;

3. If our processing of user information violates your agreement with us;

4. If you no longer use our products or services or if you have canceled your account;

5. If we no longer provide products or services to you.

We will assess your deletion request and take corresponding steps if the conditions are met. When you make a deletion request to us, we may ask you to verify your identity to ensure the security of your account. After you delete information from our service, due to applicable laws and security technologies, we may not immediately delete the corresponding information from the backup system. We will securely store your information until the backup can be cleared or anonymized.

(4) Change the Scope of Your Authorized Consent

Each business function requires some basic user information to be completed (see the "First Section" of this policy). You can give or withdraw your authorized consent for the collection and use of user information at any time. You can perform this operation through the following methods: ① Go to the personal center to modify personal information; ② Contact us to modify your personal information.

After you withdraw your consent, we will no longer process the corresponding user information. Also, please note that withdrawing consent may have certain consequences. For example, we may be unable to continue providing you with specific services or features. However, your decision to withdraw consent will not affect the user information processing carried out based on your consent before.

(5) User Account Cancellation

You can cancel a previously registered account at any time. You can do so through the following methods: ① Contact our support staff.

After canceling your account, we will cease to provide products or services to you and, upon your request, delete or anonymize your information, except as otherwise provided by laws and regulations. This may also result in you losing access to data in your account. Please proceed with caution.

(6) Obtaining a Copy of User Information

You have the right to obtain a copy of your user information. You can do so through the following methods: ① Contact our support staff.

Where technically feasible, for example, with data interface compatibility, we can directly transfer a copy of your user information to a third party designated by you, as per your request.

(7) Restrict Automated Decisions by Information Systems

In some business functions, decisions may be made solely based on non-human automatic decision-making mechanisms, algorithms, etc. If these decisions significantly affect your legitimate rights, you have the right to request an explanation from us. We will also provide appropriate remedies.

(8) Responding to Your Requests

For security reasons, you may need to provide a written request or other means of proving your identity. We may first ask you to verify your identity before processing your request.

We will provide a response within 30 days. If you are not satisfied, you can also file a complaint through the following channels: ① Contact our support staff.

(8) Responding to Your Requests

To ensure security, you may need to provide a written request or provide other forms of identity verification. We may require you to verify your identity before processing your request.

We will provide a response within 30 days. If you are not satisfied, you can also file a complaint through the following channels: ① Contact our support staff.

For reasonable requests, we generally do not charge a fee. However, for repeated requests beyond a reasonable limit, we may charge a certain cost depending on the circumstances. We may also refuse requests that are unjustifiably repetitive, require excessive technical means (such as the need to develop new systems or fundamentally change existing practices), pose risks to others' legitimate rights and interests, or are impractical. Please also understand that, due to considerations of security, relevant legal requirements, or technical limitations, we may not be able to respond to some of your requests. For example, in the following cases:

1. Related to the fulfillment of obligations stipulated by laws and regulations by the user information controller;

2. Directly related to national security or national defense security;

3. Directly related to public security, public health, or major public interests;

4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

5. The user information controller has sufficient evidence to indicate that the user information subject has subjective malice or abuses their rights;

6. Related to the protection of the life, property, and other major legitimate rights and interests of the user information subject or other individuals, but it is difficult to obtain the consent of the individual;

7. Responding to the request of the user information subject would seriously damage the legitimate rights and interests of the user information subject or other individuals or organizations;

8. Involving trade secrets.

(6) How We Handle Children's Personal Information

We attach great importance to the protection of children's personal information. Our products, websites, and services are mainly directed towards adults. Without the consent of parents or guardians, children should not create their own user accounts. Although definitions of children may vary according to local laws and customs, we consider anyone under the age of 14 to be a child.

For cases where children's user information is collected with the consent of parents or guardians, we will only store, use, or disclose this information in compliance with the law, explicit consent from parents or guardians, or the necessity to protect children. Otherwise, we will try to delete the relevant data as soon as possible.

Given the limitations of existing technology and business models, it is difficult for us to actively identify children's personal information. If you discover that we have collected children's personal information without your knowledge or without obtaining verifiable consent from guardians, you can contact us promptly. We will try to delete the information upon discovery. Exemptions apply where the law requires us to retain the information.

(7) How Your User Information Is Stored and Transferred Globally

In principle, user information collected and generated within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. We will only retain your user information for the period required for the purposes and uses stated in this policy and for the shortest period as required by laws and regulations. After the above retention period expires, we will delete your user information or anonymize it in accordance with applicable laws and regulations. Except as otherwise provided by laws and regulations, or for public interests, scientific research purposes, etc., or your separate authorized consent, we may need to retain relevant data for a longer period.

Due to the fact that we provide products or services through resources and servers distributed globally, this means that, with your authorized consent, your user information may be transferred to overseas jurisdictions where you use the product or service, or accessed by these jurisdictions.

Such jurisdictions may have different data protection laws, or even no relevant laws. In such cases, we will ensure that your user information receives sufficient equivalent protection as in the People's Republic of China. For example, we may request your consent for the cross-border transfer of user information or implement security measures such as data de-identification before cross-border data transfers.

(8) How This Policy Is Updated

Our privacy policy may change. We will not reduce your rights granted under this privacy policy without your explicit consent. We will post any changes to this policy on this page.

For major changes, we will also provide more significant notice. Major changes referred to in this policy include but are not limited to:

1. Major changes in our service mode, such as the purpose of processing user information, types of user information processed, and ways of using user information;

2. Major changes in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy mergers, etc.;

3. Major changes in the main objects with whom we share, transfer, or disclose user information;

4. Major changes in your rights concerning the processing of user information and how to exercise them;

5. Major changes in the departments responsible for the security of user information, contact methods, and complaint channels;

6. When the security impact assessment report on user information indicates a high risk.

We will also archive previous versions of this policy for your reference.

(9) How to Contact Us

If you have any questions, opinions, or suggestions regarding this privacy policy, you can contact us through the following means:

Email: {support@unionurture.com}

We have established a dedicated department for user information protection. You can contact relevant personnel through the following means: Matthew@unionurture.com

In general, we will respond within 30 days.

If you are dissatisfied with our response, especially if our processing of user information has harmed your legitimate rights and interests, you can also seek a solution through external channels.