Privacy Policy

Holwray Pharmaceutical (China) Co., Ltd. has always valued privacy and expected you can understand how we collect, use and disclose information. It is stated in this Privacy Policy that our practice regarding information collected by us or our service provider through websites or network assets (such as mobile websites or applications, hereinafter referred to as "websites") that we are liable for operating and managing, and you can refer to this Privacy Policy therefrom. Providing us with your personal information or using the website means that you have agreed to the terms of this Privacy Policy. Please read this Privacy Policy carefully. Using our products and/or services means you agree that you have reached the age of 18 and fully understood and accepted the all terms and contents of this Privacy Policy. You may not use our products and/or services if you do not agree with this Privacy Policy.

Scope of personal information

The term "personal information" mentioned herein refers to the information we collect from individuals that can be used to identify specific personal identities, which may fall into personal information that may be used alone (such as name and identity card information) and personal information that cannot be used alone but shall be used in combination with other information (such as location information and vehicle status). The personal information we collect may include both types mentioned above. For the former type, we will only collect it with your prior notification and consent; while for the latter type, we can collect, use, transfer and disclose it for any purpose without combined use.

The "personal information", which we may collect from you, includes but is not limited to your name, mailing address, telephone number, e-mail address, other contact information, age, date of birth, gender, educational background, occupation, language, zip code, area code, personal image, interests, identity card information, employment company information, behavior information, etc.

Collection of personal information

We will collect and save your personal information in a variety of ways:

• You voluntarily provide the information to us when visiting or participating in our official website or other online services (e.g. When you contact us through the website or email to ask questions, comment or participate in online surveys);
• When you follow our social media (such as Weibo and WeChat);
• When you post personal information through publicly accessible means, such as BBS, Weibo and WeChat;
• Through your browser: Most browsers will collect certain information, such as Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and the type and version of Internet browse. We may collect similar information, such as device type and identification if you visit a website with a mobile device.
• Use Flash cookies: Use Adobe Flash technology (including Flash Local Storage Objects, referred to as "Flash LSOs") enable us to provide information more in line with your needs, facilitate further access to and use of website, collect and save more information about the website usage. If you do not want to save the Flash LSO on the computer, you can adjust the settings of the Flash Player and use the tools in the Website Storage Settings Panel to prevent. You can also access the Global Storage Settings Panel and manage Flash LSO following the instructions, which include: How to delete an existing Flash LSO (referred to as "information" in the Macromedia website), how to prevent the Flash LSO from being saved in your computer without permission and (for Flash Player 8 and later) how to prevent Flash LSO from being sent by people other than the operator of this page when you browse the page, etc. It should be noted that restricting Flash Player's acceptance of Flash LSO may affect the functionality of some Flash applications, which may involve Flash applications used by websites or online content.
• Use pixel tags, web beacons or clear GIFs, or other similar technologies: These technologies may be used in some web pages and e-mail messages in HTML format to track actions of website users and e-mail recipients, measure the effectiveness of marketing activities, and make comprehensive statistics on website usage and response speed.

Collect information through Cookies

We will learn about customers' use of our website through Cookies and other tracking technologies. Cookies is a specific identifier that identify your device. Through this, we can recommend personalized products and advertisements to you (including union websites that provide advertising content from this website). We will classify and summarize the information collected through Cookies to provide more targeted and valuable product information and services to different groups of customers. The information collected through Cookies is personal information that cannot be used alone. You understand and agree that we will use this it in combination with your other information. Most web browsers will automatically turn on Cookies, but you can turn off it by adjusting the browser settings at any time. However, Cookies enables you to enjoy better and more personalized services. Turning off it may prevent you from fully enjoying services on the website, so we recommend you to open it.

How Do We Use Your Personal Information

We will use the collected personal information for the following purposes (hereinafter referred to as "Purpose of Personal Information Collection"):

• Manage and provide you with our products and services, and communicate with you on their use in a timely manner;
• answer your inquiries and meet your requirements, such as sending the documents you requested or reminding you of e-mails; send you sorts of important information, including that on the relationship and website, terms, conditions and policy changes, and other regulatory information; and engage in various activities for commercial purposes, such as data analysis, auditing, development of new products, improvement of websites, products and services, determination of website usage trends, customization of website experience by providing tailor-made products and services, and weighing the effect of promotional activities. The information collected will also be disclosed to the following parties:
• To our affiliates for the purposes described in this Privacy Policy. HOLWRAY PHARMACEUTICAL (CHINA) COMPANY LIMITED is the liable party for managing the sharing of personal information; -Third-party partners who carry out brand joint or market joint promotion with us; -Third-party service providers who provide services including website hosting and management, mobile application hosting, data analysis, payment processing, order fulfillment, architecture provision, IT services, customer services, delivery services of e-mails and direct mails, audit services and other services so that they can make available various services customers need; -A third party that is involved in the reorganization, M&A, sale, joint venture, entrustment, transfer or other disposal of all or part of an enterprise, assets or shares (including those related to bankruptcy or similar judicial proceedings). Furthermore, we will use and disclose this information in such ways that are necessary or appropriate as we deem, including: (a) Where applicable law allows, including the law of a country other than your country of residence; (b) in accordance with legal proceedings; (c) to respond to requests from public sector and government authorities, including those in countries other than your country of residence; (d) to exercise the rights and obligations as specified in provisions of the policy; (e) to protect the business operations of us or our affiliates; (f) to protect the rights, privacy, security or property of you, others and us or our affiliates; (g) to enable us to remedy or limit possible losses. With your consent, we may also use and disclose the information collected through the website in other ways.
• We will also use and disclose passively collected information as described herein "Collection and Use of Passive Information" for other purposes, unless required by current laws (e.g. in case where we are required to regard it as personal information). In addition, we may use and disclose information without personal identification marks for any purpose. In case of combination with information without or with personal identification (e.g. Merging your name with your geographical location), we will regard the merged information as personal information.

Disclose and Share Your Personal Information to Third Parties

We respect your personal privacy and abide by relevant laws and regulations. We promise to strictly keep your personal information collected confidential and will not sell it to others. Your personal information will be shared with the following third parties who abide by this Privacy Policy or provide at least the same protective practices as this Privacy Policy only for the purpose of personal information collection. Unless otherwise stated, such third parties shall not represent Holwray Pharmaceutical to collect, use or transfer personal information, etc. Therefore, Holwray Pharmaceutical is not liable for the collection, use or transfer of personal information by them.

• Affiliates and subsidiaries: we may share your personal information with them in order to make sure that the Company Group members provide you with roughly the same quality of service.
• Authorized distributors: they are our sales channels in charge of introducing and selling products and services to you. We will share your personal information with them for the purpose of personal information collection in order to provide better pre-sales and after-sales services.
• Business partners: We have established business cooperation with a number of third parties and may share your personal information with such third-party partners in order to promote cooperation and launch quality and updated products and services.
• Third-party service providers: we employ third-party companies (such as suppliers and service outsourcers) to provide our customers with relevant services, including but not limited to car purchase loans, vehicle insurance, vehicle-mounted information, roadside rescue, telephone follow-up, sending letters, e-mails or short messages, cleaning up customer information, analyzing data, providing marketing assistance, customer satisfaction investigation, accepting customer consultation and handling customer requests, etc. Such third parties can access, use, process or retain your personal information only for performing their duties or assisting us in achieving the purpose of personal information collection. Besides, they cannot use your personal information for any other purpose.

Processing and storage of personal information

We will not process, tamper with or destroy your personal information in violation of the purpose personal information collection or beyond the scope of this Privacy Policy.

We take reasonable and sufficient security measures, including but not limited to those in electronic and physical forms to store and prevent your personal information data from unauthorized access, disclosure and loss.