PRIVACY NOTICE

1. Introduction


Brilliant and its affiliated companies (hereinafter referred to as "Brilliant" or "We") respect your privacy and personal information protection. We thank you for visiting our website and other relevant interactive channels, including but not limited to our social media pages, social media channels, mobile applications and/or blogs (collectively referred to as "Brilliant Pages"), and for your interest in our company, products and services. This privacy policy applies to your personal information collected online and offline by Brilliant when you interact with Brilliant. For example, you visit the Brilliant page as a visitor, customer or potential customer, or the representative of our supplier or business partner, use the products or services provided by Brilliant, purchase Brilliant products, subscribe to Brilliant information and contact our customer service. We may also provide you with a separate privacy policy or statement to tell you how we collect and process your personal information under certain specific circumstances, such as specific products, services or projects provided by Brilliant. For example, when you participate in our clinical research projects or use our mobile applications, we may provide you with a separate privacy policy or statement. If there is any conflict or inconsistency between the above separate privacy policy or statement and this privacy policy, in principle, such separate privacy policy or statement shall take precedence over this privacy policy, unless otherwise mentioned or agreed.


2. For what purpose do we collect personal information?

The "personal information" in this privacy policy refers to the information related to you, or the information that can identify you individually or in combination with other information held by us. We encourage you to keep your personal settings and personal information complete and up-to-date.

User feedback data

You can choose to submit comments, questions, requests or complaints about our products and/or services through various channels provided on the page of Brilliance ("user feedback data"). When you do this, we may collect the following personal information from you: · Your Brilliance account data · Position· Department· Details of your comments/questions/requirements/complaints. We will use these personal information to reply to your questions, meet your requirements, solve your complaints, and improve our page, products and services.

Use data

We may collect the information generated when you use the products, services and/or pages of Brilliance, and use your personal information for analysis purposes. We do this in order to understand your interests and preferences, to improve our products, services and/or Brilliant pages, and to enhance your user experience.

Online behavior data

Brilliant may use cookies or similar technologies to collect information about your visit to Brilliant's website, so that you can gain more information and better online experience when interacting with our website. For more information about our use of cookies or similar technologies and your choice of cookies, see the section "Cookies or other similar technologies".


3. Share your personal information with others

Related parties and subsidiaries

For the purpose stated in this privacy policy, we may share your personal information with the affiliated companies of Brilliant.

Service providers and other third parties

We may share your personal information with third-party service providers in accordance with the provisions of this privacy policy and applicable laws to assist us in providing certain services, such as website hosting, information technology and related infrastructure provision, cloud services, order fulfillment, customer service, e-mail delivery, audit and other services. We will require these service providers to protect your personal information through contracts or other means· If you agree to receive marketing information from a third party, we may share your personal information with the third party so that they can send you marketing information· We may also share your personal information with our business partners when necessary to achieve the purposes listed in this privacy policy. For example, we may sell products or provide certain services to you together with our business partners.

Other uses and disclosures

We can also use and disclose your personal information when we deem it necessary or appropriate: (a) comply with the requirements of applicable laws (including laws outside your country or region), respond to the requirements of public and government departments (including government agencies and departments outside your country or region), cooperate with law enforcement or for other legal reasons; (b) Implement our terms and conditions; And (c) protect the rights, privacy, security or property of us and/or our affiliates or subsidiaries, you or others. In addition, when part or all of our business, assets or stock plans or actual reorganization, merger, sale, joint venture, transfer or other disposal (including bankruptcy or similar procedures), Brilliance may also provide your personal information to a third party (including the agent, auditor or other service provider of the third party).


4. Third-party service

In the process of browsing and using the page of Brilliance, you may encounter links from third-party service providers or directly use the services provided by third-party service providers, which may include social media platform providers, other mobile application developers or other website operators (such as WeChat, Microsoft, LinkedIn, etc.). We add these contents, links or plug-ins on the website to facilitate your login to our website or to facilitate your sharing of information with the accounts of these third-party service providers. These third-party service providers usually operate independently of Brilliant and may have their own privacy statements or policies. We strongly recommend that you review these policies or statements before using third-party services to understand how these third parties handle your personal information, because we are not responsible for the content of websites or applications not owned or managed by Brilliant, and the use and privacy protection measures. For example, you may directly jump to a third party's social media website through the link provided by our website. The personal information generated by your subsequent use of social media websites will be collected by the third party instead of us, and will be subject to the third party's privacy policy instead of this privacy policy.


5. Cookies or other similar technologies


When you use the Brilliance page, we may use cookies or other similar technologies to collect your information. For example, when you visit our website, receive our email, use our mobile applications and/or networking devices. In most cases, we cannot directly identify you from the information we collect using these technologies. We collect your information through cookies or other similar technologies, which are mainly used to: · ensure the normal operation of the Borrycom page. These cookies are necessary for you to browse and use the functions of the Borrycom page. Without these cookies, you may not be able to use and access the Borrycom page normally. For example, these cookies can record the information you have entered. When you visit next time, you do not need to enter it again· Analyze the usage of the page of Brilliance to measure and improve the performance of the page. This kind of cookies will collect information about your behavior of visiting the website, such as the pages you often visit and whether you receive error notifications. Through this information, we can improve the structure, navigation and content of the website to provide you with a better access experience. You can change the cookies settings in your browser at any time to manage your cookies preferences. If you disable our cookies in your browser settings, you may find that some parts of our website do not work properly. If you have any questions about our use of cookies or other similar technologies, you can also contact us through the contact information in the "How to contact us" section.


6. Your rights and choices

According to applicable laws and regulations, you may have the following rights to your personal information held by us: access, correction, deletion, restriction of processing, objection to processing and/or withdrawal of consent. More specifically, you can submit a request to us for access to some of your personal information held by us; We are required to update, correct, modify, delete or restrict the processing of your personal information. If there are relevant provisions in applicable laws and regulations, you can also withdraw your consent or objection to the processing of your personal information previously provided to us at any time based on the legal reasons applicable to you, and we will handle it appropriately according to your needs. In addition to the options provided on the Brilliance page, such as the unsubscribe option contained in the promotion email, accessing and managing your Brilliance account data after logging in, you can also contact us directly through the contact information shown in the "How to contact us" section of this privacy policy to request the exercise of these rights. We will respond to your request in accordance with applicable laws and may require you to provide more information to verify your identity. At the same time, please understand that in some cases, we may not be able to respond to your request for some legal reasons stipulated by applicable laws. For example, responding to your request may cause us to violate our legal obligations. In your request, please specify the personal information you want to access or change, and whether you want to restrict the processing of your personal information from our database, or tell us in other ways what restrictions you want to set on our use of your personal information.


7. How do we protect your personal information

Bricon follows the ISO/IEC 27001 Information Security Management System (ISMS) and uses various technical and organizational measures and operating procedures to protect your personal information. For example, we will adopt access control mechanisms, use firewalls, secure servers, and de-identify, anonymize, or encrypt certain types of data (such as property information and other sensitive data). In addition, Brilliant will regularly test and evaluate the effectiveness of technical and organizational measures to ensure the security of your personal information. You are responsible for keeping your account name and password safe. Please note that no security measures are perfect or 100% secure. Therefore, we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, changed or destroyed in violation of any of our physical, technical or organizational safeguards.


8. Retention period of personal information

Unless otherwise stated when collecting your personal information (for example, in the form you fill in), we will keep your personal information for the longer of the following periods: (i) the period necessary to achieve the purpose of collecting or otherwise processing personal information specified in this privacy policy, or (ii) the period necessary to fulfill legal obligations (such as data retention obligations under tax or other commercial laws).


9. Cross-border transmission of data

Brilliant is a global company headquartered in China. Our affiliates, business partners or suppliers are distributed in different countries and regions around the world. Your personal information may be transferred to our affiliates, business partners or service providers outside your country so that they can assist us in processing your personal information for the purposes described in this privacy policy. Personal information protection rules in these countries may be different from those in your country. In this case, we will only transfer personal information for the purpose stated in this privacy policy. To the extent required by applicable laws, when we transfer your personal information to recipients in other countries, we will take appropriate measures to protect the information.


10. Information about minors

Although the page of Brilliant generally does not serve minors under the age of 18, the policy of Brilliant requires us to obtain the permission of parents or guardians before collecting, using or disclosing the personal information of minors according to the legal requirements. If we know that we have collected the personal information of minors, we will immediately delete these data from the records. Brilliant strongly recommends that parents or guardians actively monitor children's online activities. If parents or guardians find that their children have provided us with personal information without consent, please contact us in accordance with the "How to contact us" section of this privacy policy. After verification, we will delete or otherwise process the personal information of minors according to the requirements of parents or guardians.


11. Change of privacy policy

The services provided by Brilliant are in constant development, and the form and nature of our services may change from time to time without prior notice to you. Brilliant reserves the right to modify or update this privacy policy from time to time to reflect changes in our services and updates of applicable laws, and will publish major amendments on our website. We will publish a notice in a prominent place on the privacy policy page to inform you of any major changes to this privacy policy, and will indicate the latest update time at the top of the notice.


12. How to contact us

If you have any questions, opinions, questions or complaints about your personal information held by us, or if you want to exercise any rights related to personal information, please go to xlj@neuracle.cn Contact us. Please note that this email address is only used for personal information-related issues. In addition, you can also submit your request or complaint to the competent data protection authority at any time.

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Neuracle Medical Technology(Shanghai) Co.,Ltd

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