Effective Date: 2021-06-30

1.   GENERAL REMARKS

EDAN (the Company) will respect and protect all Users who use the products and services provided by the Company. For the purpose of applicable data protection law, especially the General Data Protection Regulation (Regulation (EU) 2016/679), the Company is the data controller. You will see the Company referred to as EDAN Instruments, Inc., Edan Diagnostics, Inc., Edan Medical (UK) Limited, and other group members on our official website.

We recognize that your privacy is important to you, please take moment to read the information below. We are committed to protecting your privacy and ensure that any information you provide is collected in accordance with this Privacy Policy.

2.   WHAT DATA DO WE COLLECT?

We will collect, store, and use the following categories of personal information about you:

·       Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;

·       Your work related contact details (such as your telephone number(s), fax numbers and postal address, e-mail address);

·       Employer details and occupation;

·       Information necessary for legal compliance;

·       Your electronic identification data such as Internet Protocol (IP) address, website connection history and website journey.

3.    HOW DO WE COLLECT YOUR DATA?

You may provide us with personal information in a number of ways, such as when you:

·       Provide information to us via our websites, report a problem or request support by filling out forms in Contact Service.

·       Communicate with us by e-mail, phone, post, fax using the contact options on the site.

4.    THE LEGAL BASIS

Your personal data will only be processed if permitted by legal basis, This will include (as relevant):

·       Your consent may be a lawful reason for processing your personal data in certain cases, based on Art. 6 para. 1 lit. a GDPR.

·       In the processing of personal data required for the performance of our obligations under a contract with you. This also applies to processing operations that are necessary to carry out pre-contractual measures, Art. 6 para. 1 lit. b GDPR serves as the legal basis.

·       Processing which is necessary to comply with legal obligations under EU law (where relevant), Art. 6 para. 1 lit. c GDPR serves as the legal basis.

·       The processing is necessary to protect your vital interests, or those of another natural person, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

·       If processing is necessary to safeguard a legitimate interest of our company or a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data (first-mentioned interest), based on Art. 6 para. 1 lit. f GDPR.

5.    HOW WILL WE USE YOUR DATA?

The following contents explained the purposes for which we may use your personal information. Presenting the information in this way will make it more comprehensive for you to understand your rights related to your personal information, and this is explained further in the sections “WHAT ARE YOUR DATA PROTECTION RIGHTS?”:

Our Company collects your data so that we can:

·       respond to and/or process your request or inquiry;

·       improve our products and services, and ensure that content of the website are presented to you and your computer (or other electronic devices) in the most effective way;

·       perform any contract the Company has with you;

·       contact you (directly contact by the Company and the Group, or contact through a relevant distributor) by e-mail or phone for the above reasons.

·       manage our websites;

·       analyze the trend of using and visiting our website

·       monitor and record of telephone calls and email communications where necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business, for quality, training and security purposes.

·       compliant with our legal and regulatory obligations.

This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements change. Some personal information that we maintain will be archived in paper files, and other personal information will be archived in computer files and electronic databases.

6.    HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Your personal data will not be retained for longer than is necessary to fulfil the specific purposes listed in this notice and comply with legal requirements.

The criteria used to determine the data retention period include:

(i) Retention after query. Whatever the reason why you contacted us, we may retain your personal data for a reasonable period after you have enquired.

(ii) Retention in accordance with legal and regulatory requirements. Due to legal or regulatory requirements, we may further retain your personal data.

7.    WILL WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?

Your personal information may be shared within the EDAN Group Members, or with external partners and agencies involved in providing our services and products to you on our behalf (e.g. providers of services in respect of management, accounting, legal, logistics, auditing, compliance, IT systems and marketing).

We may also provide personal information to government authorities, law enforcement and regulatory authorities, but only where it is necessary, either to comply with the law or where permitted under the GDPR. For example where the disclosure is necessary for the purposes of the prevention and / or detection of crime or other purposes.

We reserve the right to transfer personal data about you in the event of any restructuring of the Company or sale of the Company's business. Should such a restructuring or sale occur, we will use reasonable efforts to direct the transferee to use data you have provided to us in a manner that is consistent with this Privacy Notice.

We will not sell your personal information to any third party other than as part of any restructuring of the Company or Group or sale of a relevant Group business.

8.    WILL WE TRANSFER YOUR PERSONAL INFORMATION ABORD?

Your personal information may be transferred to the country outside the European Economic Area (“EEA”), Individuals should be aware that recipients of their personal information, within the Group or third parties, may not be located within the EEA but located in the countries which not have the same levels of data protection. Steps will be taken to protect your personal information in that instance consistent with applicable law, and ensure that your personal data is kept secure as outlined in this policy.

9.    LINKS TO THE THIRD PARTIES

Our website contains links or references to other websites, e.g. to social media channels such as Facebook, or Youtube. Please note that you will be subject to other privacy policies if you click on links to other websites. Please also ensure that you read the Privacy Notice of every website you visit. We have no influence on their data processing.

10.    COOKIES AND WEB ANALYSIS

·       Analytics Information

- We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

·       Cookies and Similar Technologies

- When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Service and provide features to you.

- We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

·       Log File Information

- Log file information is automatically recorded and reported by your browser or the app you downloaded each time you make a request to access (i.e., visit, launch) our web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.

- When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring or exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, information on app and other software you used and other such information.

- We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

·       Device identifiers

- When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us.

- A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

·       Metadata

- Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.

- Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If you geotag your photo or tag your photo using other's APIs then, your latitude and longitude will be stored with the photo and searchable (e.g., through a location or map feature) if your photo is made public by you in accordance with your privacy config.

11.    WHAT ARE YOUR DATA PROTECTION RIGHTS?

You have the following rights to the data you have processed (as relevant):

·       The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed (Art. 16 GDPR);

·       The right to object to processing of your personal information (Art. 21 GDPR);

·       The right to restrict processing of your personal information (Art. 18 GDPR);

·       The right to have your personal information erased (Art. 17 GDPR);

·       The right to request access to your personal information and to obtain information about how we process it (Art. 15 GDPR);

·       The right to have the personal data concerning you transferred directly by one responsible person to another responsible person, insofar as this is technically feasible (“data portability”, Art. 20 GDPR);

·       Rights in relation to automated decision making including profiling (Art. 22 GDPR).

·       The right to withdraw your consent to any processing for which you have previously given that consent (Art. 7 GDPR).

Please contact us at support@edan.com if you would like to exercise any of your rights explained above in relation to your personal information.

12.    CHANGES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time, in order to reflect changes in the law and/or our privacy practices, so please review it periodically. We encourage you to check the date of this Policy for any updates or changes. The date at the top of this Policy will be updated accordingly.

13.    CONTACT/ADDRESS DETAILS

If you have any questions about this Notice, please contact us at

Edan Instruments, Inc.

#15 Jinhui Road, Jinsha Community,

Kengzi Sub-District, Pingshan District,

ShenZhen 518122, P.R.China

Or write at support@edan.com.