Privacy Policy

Last updated: June 20, 2018

Vamos Biotech (Shanghai) CO., LTD (“VB”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe our practices regarding your privacy and the types of Personal Data and other information that we collect from users of our website (located at www.vamos-biotech.com) and users of our “Services” (meaning VB products and related services).

This Privacy Policy is incorporated into, and considered a part of, the VB Terms of Service. For this Privacy Policy, VB includes, collectively or individually, VB, and any subsidiary or affiliate company of VB (collectively or individually known as “VB”, “we”, “our” or “us”).

If an irreconcilable conflict exists between the terms of this Privacy Policy and the terms of any separate privacy agreement you have executed with VB related to the collection, use, and sharing of your data, then the provisions of that separate agreement will control to the extent practicable.

Our privacy practices cover all our technologies and business processes and are based on the following principles:

• Management Responsibility – VB assigns its executive management with primary responsibility for defining, documenting, promoting, and communicating the VB Privacy Policy and related procedures

• Notices – VB provides reasonable notice when Personal Data is collected and also discloses the purpose for which individual data is collected, stored, and processed

• Choice – Individuals are informed of their available choices in providing Personal Data.

VB collects Personal Data and Non-Personal Data from you when you visit our website, when you send us information or communications, and when you download and use our Services.

Personal Data

• We collect Personal Data from you. “Personal Data” is any information relating to an identified or identifiable natural person. An identifiable natural person is an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• We only collect Personal Data that is necessary, relevant, and limited in relation to the Services we are providing to you. We only collect and store Personal Data that is provided by you or that you have given us permission to read from your system. We do not generate or collect additional Personal Data outside of what you provide. For example, we read an email address as an identifier, e.g. person@company.com, but we do not allow the addition of a natural language name unless that explicitly exists in the customer system, e.g. John Doe, and our system has been configured by you to read that name.
• Like most internet services, we automatically gather data about you or your device browser including your IP address, cookies, and the pages you request. We store this information in log files each time you visit our website or access your account on our network. This data allows you a better experience using our Services.

Non-Personal Data

• Anonymous Data
  To make our website and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect “Anonymous Data” from you, such as browser type, operating system, domain name, and/or a date/time stamp for your visit. Anonymous Data has all Personal Data references removed such that the data cannot be reverse engineered or in any way attributed to the individual from which the information was collected. Anonymous Data collected by VB includes information about the date and time of the anonymous user’s visit and about how they have used our Services.

• Application Data
  VB collects Application Data when our products are deployed in your IT environment. “Application Data” means data about the performance of your application, system data (such as version data, names of plug-ins, etc.) about the environment in which your application is operating, data about the functions that are being performed by our Services, stack traces and source code snippets for certain classes of errors, and other similar data related to your application. Only data that is relevant to the Services you have purchased from VB will be collected.Some Services may collect messages being sent and received from your Contact Centre so that we can convey those messages to and from carrier networks. Similarly, to transmit voice calls to and from the telecommunications carrier networks, we collect the voice communications being sent and received to route them appropriately. You can also use our Services to record voice communications or have them transcribed, in which case, we will also collect those voice recordings or transcriptions.

• Information from Children
  We neither direct or target our Services to, nor do we intentionally collect Personal Data from, children who are under the age of 16. Further, we request that these individuals do not provide Personal Data through our Services. If we find that an individual under the age of 16 has created an account with us, we may disable that account or seek to have a parent or guardian provide consent for the child’s account.

• Personal Health Information and Sensitive Information
  VB’s Services are not intended for, and you shall not use them to receive, send or otherwise process Personal Health Information (PHI) as defined by the Health Insurance Portability and Accountability Act of 1996 as amended (HIPAA) or any sensitive Personal Data (e.g., information related to racial or ethnic origin, health or health records, political opinions, religion, or criminal background), unless otherwise provided in your written agreements with VB.

We may receive Personal Data about you from other sources such as telephone or fax, from companies that provide our products or services by way of a co-branded or private-labelled website, companies that offer their products and/or services on our website, or companies that provide services (such as payment processing services) in connection with our website (“Partner Companies”). Our Partner Companies may supply us with Personal Data, such as your name, e-mail, and mailing address information, in order to help us establish the account or fulfil orders.

Except as otherwise expressly provided, VB only collects Personal Data through our website and our Services, and this Privacy Policy applies only to the use of such Personal Data that we collect.

Cookies

• “Cookies” are small pieces of information, which typically include an anonymous unique identifier, that are sent to your browser and stored on your hard drive or in device memory when you view a webpage, an advertisement, video or other types of content. We link the information we store in Cookies to the Personal Data you submit while on our site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. Your web browser may allow you to delete, block or otherwise disable the use of Cookies or tracking or monitoring technologies. If you choose to disable Cookies, some areas of our website that require you to be signed in to your account or otherwise identify yourself may not work properly. We may use Cookies for a number of purposes, including:
  • Identifying you as an account holder;
  • Requiring you to re-enter your password after a certain period of time has elapsed to protect you against unauthorized persons accessing your account;
  • Keeping track of preferences that you specify while you are using our Services;
  • Advertising.
• Our partners, affiliates and other service providers may use Cookies and other technologies to improve the quality of your experience when you interact with our website and Services and to deliver or target advertising to you. We may receive reports based on the use of certain technologies by these companies on an individual and aggregated basis.
• We may use Cookies, clear gifs and other technologies in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
• We use local shared objects, also known as Flash cookies, when we provide you with video content. Third parties, with whom we partner to provide these features on our website, use Flash cookies to collect and store information.

How We Respond to Do Not Track Signals
Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit to disable the tracking of an individual user. There is no industry consensus as to what “Do Not Track” means in this context. Similar to many websites and online service providers, VB does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser.

Personal Data Collected by or Shared with Third Parties

• Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our website and go to the website of a third party. During this process, a third party may collect Personal Data or Non-Personal Data from you. We have no control over, do not review, and cannot be responsible for these non-VB, third party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of data after you click on a link to a third-party website or location. We encourage you to carefully read the privacy statement and terms of use of any third-party website you visit.

• We may partner with a third-party ad network to either display advertising on our website or to manage our advertising on other websites. Our ad network partner may use Cookies and web beacons to automatically collect Non-Personal Data about your activities on this and other websites. This information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. We use the information we collect to provide you targeted advertising based upon your interests.

• If you do not wish to receive targeted advertising based on your information, you may submit this request to admin@vamos-biotech.com. Please note this request does not opt you out of generic advertising and you will continue to receive generic ads.

• Social Media Features and Widgets
  Our website includes social media features, such as the Facebook “Like” button and widgets, such as the “Share this” button or interactive mini programs that run on our website. These features may collect your IP address, which pages you are visiting on our website, and may set Cookies to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing the feature.

We use Personal Data to pursue our lawful business interests, which generally consist of responding to requests that you make to us, aiding us in serving you better, or providing Services to you. We collect only the information necessary for these purposes.

VB uses your Personal Data in the following specific ways:

• Facilitate the creation of and secure your account on our network;
• Identify you as a user in our system;
• Provide improved administration of our website and Services;
• Identifying you as an account holder;
• Provide improved administration of our website and Services;
• Research, analytics and reporting;
• Send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;
• Send you administrative e-mail notifications, such as security or support and maintenance advisories;
• Respond to your inquiries related to employment opportunities or other requests;
• Send promotional communications;
• Provide you with hardcopy or electronic newsletters, or surveys;
• Send upgrades and special offers related to our products and related services and for other marketing purposes;
• Make telephone calls to you, from time to time, as a part of secondary fraud protection or other abuse prevention or to solicit your feedback.

VB also uses your Personal Data for financial, regulatory and for legal purposes, including:

• Use your payment information so we can bill you and be paid for your use of our Services;
• Use your usage data so we can properly bill you for your use of our Services;
• Appropriately manage and route customer traffic, analyze and improve our Services, and identify and solve problems with our Services that arise;
• Use certain usage data to support regulatory requirements, such as calculation and reporting of tax or similar obligations;
• Respond to legal or regulatory inquiries as we believe to be required by applicable laws, regulations, or administrative authorities.

If you choose not to provide your information to us, then we may not be able to provide you with certain requested Services or information.

We may combine information you give us with publicly available information and information we receive from or cross-reference with select partners and others. By combining this information, we are better able to communicate with you about our Services, enabling us to serve you more effectively.

Regardless of any choices you make regarding your Personal Data (as described below), VB may disclose Personal Data and Non-Personal Data if it believes in good faith that such disclosure is necessary to:

• Investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of VB’s Terms of Service, or as otherwise required to comply with relevant laws, regulations, legal process or a government request (including to meet national security or law enforcement requirements) or to respond to subpoenas or warrants served on VB;

• Respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury;

• Protect or defend the rights, security, integrity or property of VB or users of the products or related services or to enforce our agreements and policies.

If VB is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email or a prominent notice on our website of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data. If another company acquires our company or our assets, that company will possess the Personal Data and the Non-Personal Data collected by it and us and will assume the rights and obligations regarding your Personal Data and the Non-Personal Data as described in this Privacy Policy.

We do not sell, trade, or share the Personal Data collected from our Services to third parties other than as outlined in this policy.

• The information that VB collects may be stored and processed in the United States, Europe, Australia, or any other country in which VB or its subsidiaries, affiliates or service providers maintain facilities.

• EU Data Transfers
  The transfer of Personal Data from an EU country or organization to a non-EU country or organization falls under and requires compliance with certain safeguards in the EU General Data Protection Regulation. To support compliance, VB requires execution of Standard Contractual Clauses with the other party before any such transfer may take place.
• Data Access and Retention
  VB retains Personal Data we process on behalf of our customers for as long as is needed, to provide our Services. VB may also retain Personal Data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
• Information Related to Data Processed for Our Customers
  VB processes information under the direction of its customers and has no direct relationship with the individuals whose Personal Data it processes. If you submit to us (or to third parties acting on our behalf) any Personal Data relating to other individuals in connection with your use of the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. It is our customers’ responsibility to ensure that the information they provide us can be legally collected in the country of origin, transmitted to us, and maintained or used by us.

• VB is committed to protecting the security of Personal Data and the Non-Personal Data of any format or media. We use appropriate security measures to protect the security of your data both online and offline. All Personal Data is encrypted in transit and at rest, all Non-Personal Data is encrypted in transit. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people.

• Since no data transmitted over the internet can be 100% secure, we cannot guarantee the security of any information you transmit to us. However, we make every effort to secure your data by working closely with trusted third-party vendors and hosting partners needed to run the VB Services. Such hosting partners utilize security measures including physical premises, network, and identify access management security practices. Where possible, we seek to obtain confidentiality agreements with these providers that are consistent with this Privacy Policy and that limit their use or disclosure of your data. If you have any questions about security on our website or Services, you can contact us at legal@vamos-biotech.com.

• In the event that Personal Data is compromised as a breach of security, VB will promptly notify you in compliance with applicable laws.

• We offer you choices regarding the collection, use, and sharing of your Personal Data. When you share your Personal Data with us, you may be subscribed to receive optional email messages. We will then periodically send you free newsletters and emails that directly promote the use of our website or the purchase of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” at any time by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly at info@vamos-biotech.com. Despite your indicated email preferences, we may send you notices of any updates to our Terms of Service or Privacy Policy. We may also contact you via email with transactional or relationship messages such as account status messages, security updates or notifications of changes in the terms of your account. These types of transactional or relationship email messages are not optional.

• You can contact us to exercise your rights of access, modification, and deletion or to object to the processing of your personal data by sending an email to leval@vamos-biotech.com. At any time, you may withdraw previously given consent to the collection or use of your Personal Data. This will not affect the lawfulness of processing based on your consent before withdrawal.

• Although you may request deletion of your Personal Data, please note that we may be required (by law or otherwise) to retain certain information or to keep information for a specified time, in which case we will comply with your deletion request only after we have fulfilled such requirements. Certain data associated with your account may also remain on VB’s servers in an aggregated or anonymized form that does not specifically identify you. When we delete account information, it will be deleted from the active database, but may remain in our archives. We will otherwise retain your information for as long as your account is active or as needed to provide you Services as well as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you are an end user of an application that uses VB’s Services, you should direct requests for access and/or deletion of your data associated with that application to the relevant application provider in accordance with that application provider’s own privacy policy.

We post customer testimonials on our website which may contain Personal Data. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. If you want your testimonial removed, please contact us at admin@vamos-biotech.com.

If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact our Legal Team by email at legal@vamos-biotech.com, or by mail at 2F, Building #5, Lin Gang Fengxian Industrial Park, 1800 Xin Yang Road, Feng Xian District, Shanghai 201413, P.R. China.

VB will take any privacy compliant seriously and we will aim to resolve any issue in a timely manner. You may have the right to submit a complaint to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.