Pharmato Privacy Policy

This "Pharmato Privacy Policy" (hereinafter referred to as "this Policy") applies to the related products and services provided to you by Pharmato Information Technology (Suzhou) Co., Ltd. and all its wholly-owned subsidiaries (hereinafter referred to as "Pharmato" or "we") (hereinafter referred to as "this Service"). Before using this Service, please carefully read and fully understand all the contents of this Policy, especially the content marked in bold font. Once you choose "I Accept" and use this Service or agree to use this Service in any other way, it is deemed that you agree to comply with all the terms of this Policy and agree that Pharmato will process your personal information in accordance with the requirements of laws and regulations. If you do not agree to any provision in this Policy, please do not register or use this Service.

1. Collection and Use of Personal Information

1.1 "Personal Information" refers to various information recorded in electronic or other ways that is related to identified or identifiable natural persons, but does not include anonymized information.

1.2. Collection and Use: To better provide services to you, Pharmato will follow the principles of "legality, legitimacy, and necessity", and collect your personal information in accordance with the provisions of laws and regulations and with your consent, mainly including: personal information provided when you register as a user or relevant personal information provided to Pharmato when using services provided by Pharmato. If you do not provide or do not agree to our collection and use of such personal information, it may cause our related products or services to fail to operate normally, or we will be unable to provide you with related products and services. The specific channels, scenarios, and functions through which we collect and use personal information include:

(1) Pharmato Official Website

• When you choose to apply for a trial on the Pharmato official website, we will collect your [name, email, phone, company, department, position, requirements] to assist you in completing the application.
• When you log in to the Pharmato official website through WeChat, we will collect your [WeChat Open ID, Union ID] to assist you in logging in to the website and using database products.
• When you browse the Pharmato official website, we will collect your [first login IP address information, user browsing record behavior on the website, browser information].
• When you contact us using the hotline phone reserved on the Pharmato official website, we may collect information you actively provide to us and personal information related to products to provide you with corresponding pre-sales and after-sales services.

(2) Pharmato WeChat Official Account

• When you use our WeChat official account (including "Pharmato" "Pharmato") to apply for a trial product, we will collect your name, company, department, position, mobile phone, email, and requirements to assist you in completing the application.
• When you follow our WeChat official account and browse the content we publish, we will collect your [WeChat nickname, WeChat avatar, Open ID, Union ID] for internal analysis of the reader group and their preferences to improve the service quality of the official account.

(4) Online Form Tools

We may assist other enterprises in collecting your relevant personal information through online form tools such as Questionnaire Star, Jinshuju, Maike, Xiaoe Tong, Zhiqi Baichuan, and Weiling, which may include [your name, mobile phone number, email address, company name, position, research field/direction, which cutting-edge technologies you are interested in, which companies you are most concerned about, which topics you expect to see reports on, etc.], for [product information promotion, online/offline event notification reminders via SMS/email/WeChat official account, improving media service quality].

(5) Email/SMS Marketing Products

For better service, we will send you product/service information and event notification emails or SMS through email marketing. We will collect your [email IP address, cookie information (including whether you open emails, unsubscribe from emails, mark emails as spam, etc.)] to analyze marketing effectiveness.

If you do not want to receive such emails or SMS, you can also unsubscribe through the unsubscribe option in emails and SMS. However, if you choose to unsubscribe, we may not be able to provide you with some convenient services. Therefore, in order for you to better receive real-time product/service and event information, we sincerely recommend that you keep your subscription.

2. The Purpose and Legal Basis for Our Collection and Use of Your Personal Information

2.1 Legal Basis for Our Processing of Your Personal Information

We ensure that our processing of your personal information complies with applicable laws and regulations, and we process your personal information based on the following legal bases:

• Based on your consent, and such consent is voluntarily and explicitly given by you with full knowledge (if any other legal basis below applies, we may process your personal information without obtaining your consent);
• We need to process your personal information to conclude and perform a contract to which you are a party;
• Necessary for the performance of statutory duties or legal obligations;
• Necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations;
• For the public interest, implementing news reporting, public opinion supervision, and other behaviors, processing your personal information within a reasonable scope;
• The personal information we process is information you have made public yourself or information that has been legally made public through other channels; or
• Other legal bases for processing personal information as provided by laws and administrative regulations.

2.2 Unless permitted by applicable laws and regulations, we will not use your personal information for any other purpose. When Pharmato wants to use information for other purposes not stated in this Policy, we will seek your consent in advance.

3. How We Process Your Sensitive Personal Information and Processing Purposes

3.1 "Sensitive Personal Information" refers to personal information that, once leaked or illegally used, is likely to cause infringement of the personal dignity of natural persons or harm to personal and property safety, including biometric identification, religious beliefs, specific identity, medical health, financial accounts, travel tracks, and other information, as well as personal information of minors under the age of fourteen.

3.2 Based on the purposes described in Section 2, we do not involve the collection of your sensitive personal information.

4. Entrusted Processing, Sharing, Transfer, and Public Disclosure of Personal Information

4.1 Entrusted Processing

Based on the purposes described in this Policy, we may entrust third parties ("trustees") to process your personal information on behalf of Pharmato. For example: [system operation and maintenance service providers, software development service providers, data analysis service providers, communication service providers]. These trustees have confidentiality obligations regarding your personal information and may only use your personal information for the purposes described in this Policy. We will require trustees to strictly comply with our measures and requirements regarding personal information and privacy protection, including but not limited to processing personal information according to relevant service agreements between trustees and us.

4.2. Sharing

Pharmato will not share your personal information with any third-party companies, organizations, or individuals, except in the following circumstances:

• It can be provided according to the terms of this Policy or other service agreements, online terms, and other provisions between you and Pharmato;
• You agree that Pharmato shares your personal information with other parties;
• According to the provisions of laws and regulations, or according to the mandatory requirements of government authorities, sharing your personal information externally.

4.3 Transfer

Pharmato will not transfer your personal information to any third-party companies, organizations, or individuals, except in the following circumstances:

• It can be provided according to the terms of this Policy or other service agreements, online terms, and other provisions between you and Pharmato;
• You agree that Pharmato transfers your personal information to other parties;
• In the event of merger, split, acquisition, or bankruptcy liquidation involving Pharmato and its affiliated company entities, if personal information transfer is involved, Pharmato will require the new company or organization holding your personal information to continue to be bound by the relevant terms of this Policy, and will require that company or organization to re-seek your authorization and consent.

4.4 Public Disclosure

Pharmato will only publicly disclose your personal information in the following circumstances:

• It can be provided according to the terms of this Policy or other service agreements, online terms, and other provisions between you and Pharmato;
• Obtain your explicit consent;
• According to laws, legal procedures, litigation, or mandatory requirements of government authorities.

5. Storage and Protection of Personal Information

5.1 Storage Location: Your personal information will be stored within China. If we need to transfer your personal information overseas, we will separately obtain your explicit authorization and fulfill legal obligations in accordance with the requirements of applicable Chinese laws and regulations, and ensure that your personal information is provided with adequate protection in accordance with this Policy.

5.2 Storage Period: Unless you agree to extend the retention period or it is permitted by law, Pharmato will only retain your personal information for the period necessary to achieve the purposes described in this Policy.

5.3 Security Protection Measures

• Pharmato will strictly comply with the requirements of the "Cybersecurity Law", "Personal Information Protection Law", and other relevant laws and regulations, and take technical measures and other necessary measures to protect the security of your personal information. We use various security technologies and procedures to establish a sound management system to protect your personal information from unauthorized access, use, or disclosure. However, due to technical limitations and various possible malicious means, Pharmato cannot guarantee the absolute security of your personal information.
• After the occurrence of a personal information security incident, Pharmato will inform you in a timely manner in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures Pharmato has taken or will take, suggestions for you to prevent and reduce risks independently, and remedial measures for you. Pharmato will inform you of the relevant situation of the incident in a timely manner through email, telephone, and other methods. When it is difficult to inform each personal information subject individually, Pharmato will take reasonable and effective methods to publish announcements. At the same time, Pharmato will also proactively report the handling of personal information security incidents to regulatory authorities as required.

6. What Legal Rights You Have Regarding Your Personal Information

Regarding your personal information processed by Pharmato, you have the following personal information rights:

(1) Right to Access: You have the right to access your personal information held by us.

(2) Right to Copy: To the extent permitted by applicable law, you have the right to request us to copy your personal information.

(3) Right to Correct and Supplement: You have the right to request us to correct and supplement your inaccurate or incomplete personal information.

(4) Right to Delete: In the following circumstances, you can request Pharmato to delete personal information: if Pharmato's processing of personal information violates laws and regulations; if Pharmato collects and uses your personal information without obtaining your consent; if Pharmato's processing of personal information violates agreements with you; if you no longer use Pharmato's products or services, or you cancel your account; if Pharmato no longer provides products or services to you. However, please note that when the storage period specified by applicable laws and regulations has not expired, even if you request us to delete your personal information, we still have the right to retain such information;

(5) Right to Withdraw Consent: For personal information we collect and process based on your consent, you have the right to request withdrawal of your consent. If you withdraw consent, it does not affect the validity of personal information processing activities we have conducted based on your consent before withdrawal. However, please note that even if you withdraw consent, we may still have the right to process your personal information based on other legal bases;

(6) Right to Refuse or Restrict Processing: Under specific circumstances, you have the right to require us to stop or restrict the processing of your personal information. In some cases, when you require us to restrict the processing of your personal information, we may have the right to refuse the request in accordance with the law;

(7) Right to Explanation: You have the right to require us to explain the rules for processing personal information;

(8) When we make decisions that have a significant impact on your rights and interests through automated decision-making methods, you have the right to require us to explain, and you have the right to refuse us to make decisions solely through automated decision-making methods; and

(9) Right to Complain and Report: You have the right to complain and report illegal personal information processing activities to personal information protection authorities.

You can contact us through the information in "How to Contact Us" below to exercise the above rights. Generally, we will respond to your above rights requests within 15 working days after verifying your identity.

7. Updates to This Policy

Pharmato has the right to unilaterally modify the content of this Policy at any time and publish it through website announcements and other methods. Once you choose "I Accept" and continue to use this Service or continue to use this Service in any other way, it is deemed that you have fully read, understood, and accepted the modified content of this Policy, and will use this Service in accordance with the modified Policy. If you do not agree to the modifications to this Policy, you should contact Pharmato in a timely manner.