BriteMED Technology Inc.
DATA PRIVACY NOTICE
(Version 1.0, Effective date: 2018/10/19)
Protecting the personal privacy of every customer, vendor, and employee is a crucial part of gaining and keeping your trust in BriteMED Technology Inc. (the “Company”, “we”, “us”). As a global organization, we strive to provide a high level of privacy protection across all of our businesses and services and to deploy consistent, rigorous policies and procedures.
This privacy Notice (the “Notice”) does not apply to third-party applications, products, services, websites or social media features that may be accessed through links that we provide on our websites and interfaces. Accessing those links may result in the collection of information about you by a third party. We do not control or endorse those third-party websites or their privacy practices. We encourage you to review the privacy policies of such third parties before interacting with them.
Your privacy is of utmost importance to us in servicing you. Our products and services are rendered to you on the basis of your understanding of your data privacy rights.
This Noticewill be made by multi-language and all language versions shall be valid. In case of any discrepancy between English version and other language version, the English version shall prevail.
Please read this Notice carefully. When visiting our website and using our services that link to or reference this Notice, you agree to be bound by the terms and conditions of this Notice.
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the data alone or in conjunction with any other data in the data controller’s possession or likely to come into such possession. The processing of your personal data is governed by applicable privacy laws.
What roles do we play in processing your data?
We are the data controller with respect to processing your data (contact details below). This means that we decide how your personal data is processed and for what purposes. We know that you care how data about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.
When are your personal data collected?
Some of your data can, in particular, be collected by us:
Our collection of personal data
The personal data we collect include any and all data you provide to us when you enter into contract with us, enter on our website, provide us information on a web formor give us in any other way. You can choose not to provide data to us, but we may then not be able to service you where such services require processing such data. We use the data that you provide for purposes administering your use of our services, such as communicating with you, responding to your requests, and improving our products and services. We may communicate with you by email . We will send you strictly service-related announcements or information on rare occasions when it is necessary to do so.
Personal data we collect
When you visit our websites, and use services, we may collect and store include: your e-mail address, name, address, phone number, and any information you provide during a transaction, or other transaction-based content that you generate as a result of your transaction, logistics and billing data (such as customs ID and tracking number), your service history with us, and any other information you may provide us such as your interests and preferences.
We also receive and store certain types of data whenever you interact with us. For example, we use "cookies" which are unique identifiers that we transfer to your device to enable our systems to provide features of our services such as provide remote access for you, allow you to visit our website without re-entering your username, verify that you have the authorization needed for the services to process your requests, personalize and improve your experience, record your preferences, and to improve the functionality and user-friendliness of our services. It also helps us to better understand how you interact with our services and to monitor aggregate usage and web traffic routing on our website. Most of the cookies used by us are so-called "session cookies". Cookies do not cause any damage on your computer and do not contain any viruses. Most browsers automatically accept cookies as the default setting. You can modify your browser setting by editing your browser options to reject our cookies or to prompt you before accepting a cookie. However, if a browser does not accept cookies or if you reject a cookie, some portions of our services may not function properly.
We obtain certain types of data when you access the contents and cloud services hosted by us, such as the Internet protocol (IP) address used to connect your computer to the internet, device ID or token, unique identifier, device type, referral URL, computer and connection data such as the type of operating system you use, your device information, your software information, browser type, browser language and version, ad data, access times, your browsing history, and your web log information. Our server automatically receives and records your IP address which your browser sent us on our server when you login to our website. We will store your IP address in our user registration databases. We will use your IP address for the following purposes:
Our website keeps your account information active in our user registration databases in order to provide immediate access to your personal data each time you visit our website, as noted above.
All the data we collect from you may be stored as log files in our server. These log files are used for analysis, research, auditing, and other purposes. Your data is stored in log files until the data is transferred to backup databases. We routinely back-up a copy your data to prevent loss of your data in case of a server breakdown or human error. However, all such copies of your data in our backup database will be retained only for as long as our data retention policy permits (see “How long do we keep your personal data?” below), and will in any case be deleted immediately upon your request.
Non-Personal data we collect
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect your activities on our website and cloud services. The information is anonymized before being stored to our servers, and it is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest.
Use of Google Analytics
Use of Opt-In/Subscribe Personal Data
You have a choice of whether and how you receive a variety of marketing measures and activities from us related to product solutions, services and helpful business content.
You can manage your preferences by:
• Opting-in to newsletter subscription on a web form;
• Opting-in to marketing measures and activities on a web form; or
• Unsubscribing newsletter or opting-out of marketing measures and activities, via a link at the bottom of newsletter or emails regarding marketing measures and activities.
If you no longer wish to receive these communications from us, please follow the opting-out “unsubscribe” instructions provided in the link at the bottom of our emails regarding marketing measures and activities, or update your account settings.
How do we process your personal data?
We comply with our obligations under applicable privacy laws by keeping personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary data that we need to service you; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
The processing operations we perform on your data cover automated and non-automated means of collecting, recording, organizing, structuring, storing, altering, retrieving, using, transmitting, disseminating or otherwise making available, aligning or combining, restricting, and/or erasing your data.
We use your personal data for the following purposes:
What is our lawful basis for processing your personal data?
In general, the lawful bases for us to process your personal data for the various types of processing performed on your data (please refer to “How do we process your personal data?” section of this Notice) is, as applicable, processing based on your consent, as necessary for us to enter into and to perform our contract with you, or as necessary to pursue the legitimate interest of our Company or of third parties.
We will collect, process and use the personal data supplied by you only for the purposes communicated to you and will not disclose your data to third parties except under the circumstances of data disclosure described in the “Sharing your personal data” section below.
Where we talk about our legitimate interest or that of third parties, such legitimate interest can include:
Necessity to provide us data
You are not under any obligation to provide us any personal data. As noted below, the choice is yours. However, please note that without certain data from you, we may not able to undertake some or all of our obligations to you under our service contract with you, or adequately provide you with our full range of services. If you would like to obtain more detail about this, please contact us following the instructions in the “Whom should I contact?” section below.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with the categories of data recipients listed below. We will only share your data with third parties outside of the Company with your consent, and you will have an opportunity to choose for us not to share your data.
We may disclose your personal data to:
We may provide you with opportunities to connect with third party applications or services. If you choose to use any such third party applications or services, we may facilitate sharing of your information with your consent. However, we do not control the applications or services of those third parties or how they use your information, and your use of such applications and services is not governed by this Notice. Please review the terms and the privacy policies of those third parties before using their applications or services.
We will display your personal data and account activity in your profile page and elsewhere on our service portals according to the preferences you set in your account. You can review and revise your profile information at any time. Please consider carefully what information you disclose in your profile page and your desired level of anonymity. In your profile page, we will also display your device information as well as provide the network connection information for the devices to the applications that connect to your devices.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for the given purpose for which your data is processed. If you will provide us, or have provided us, consent for us to process your data, we will process your data for no longer than your consent is effective. Notwithstanding the above, we may retain your personal data as required by applicable laws and regulations, as necessary to assist with any government and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal or administrative proceedings. If none of the above grounds for us to keep your data apply, we will delete and dispose of your data in a secure manner according to our data protection policy.
Privacy of data subjects under the age of 16
Our products and services are not targeted to persons under the age of 16. We do not knowingly collect or process personal data from persons under the age of 16. Please note that if you are under the age of 16, you should not buy or use our product or services and we will not be liable for any lost or damage incurred by the unauthorized disclosure or processing of personal data under the age of 16.
Your rights and your personal data
Unless subject to an exemption under applicable privacy laws, you have the following rights with respect to your personal data:
If you would like to exercise any of the above rights, please do so through this [ www.britemed.com.tw/sarf ].
After receiving your request, we will evaluate your request and inform you how we intend to proceed on your request. Under certain circumstances in accordance with applicable privacy laws and regulations, we may withhold access to your data, or decline to modify, erase, port, or restrict the processing of your data.
Please be advised that if you exercise the rights to erase data, restrict or object to our processing, or to withdraw your consent, we may not be able to continue our services to you if the necessary data is missing for processing.
Transfer, Storage, and Processing of Data Abroad
As noted in the “Sharing your personal data” section of this Notice, as a globally operating company, we may share your information with our affiliate companies or third parties. Please refer to the “Sharing your personal data” section of this Notice for the recipients of your data and the reasons for our provision of your data to them. Where such entities are located in other countries and jurisdictions, we will therefore be transferring your personal data outside of the European Economic Area. In making such data transfers, we make sure to protect your personal data by applying the level of security required by applicable privacy laws. Where we transfer your data to a country or jurisdiction that cannot guarantee the required level of protection as required by applicable privacy laws, we have enhanced our IT security measures and have entered into Standard Contractual Clauses with the transferee to require security obligations on the transferee, both of which are intended to increase the protection of your personal data. Standard Contractual Clauses are one of a number of "appropriate safeguards" under the applicable privacy laws that enable the transfer of personal data concerning data subjects within the European Economic Area to jurisdictions that have not been designated by the European Commission as possessing an adequate level of data protection. You may request a copy of such Standard Contractual Clauses from us, or inquire about transfers of your information, by providing your request to the contact window set forth in the “Whom should I contact?” section.
If we wish to use your personal data for a new purpose not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing such further processing for a new purpose, setting out the relevant new purpose and processing conditions. In such case, we will find a lawful basis for further processing, and whenever necessary we will seek your prior written consent to such further processing.
We protect your data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, loss or theft, and loss of access. Some of the safeguards we use are data pseudonymization, data encryption, firewalls, and data access authorization controls. We take our data security very seriously. Therefore, the security mechanisms used to protect your data are checked and updated regularly to provide effective protection against abuse.
The server through which we collect your information are usually encoded using the encryption module of your browser, and are certified for international encryption technique. If necessary, we use SSL (Secure Socket Layers) encryption to protect your personal information. Moreover, we have put in place additional and comprehensive state-of-the-art security measures when your data are accessed via the internet. Firewalls prevent unauthorized access. Diverse encryption and identification layers protect your data from intrusion or disclosure to third parties during data transfer. Furthermore, we internally use sophisticated encoding methods in order to prevent de-coding by unauthorized persons. Moreover, an electronic identifier is generated during data transfer to safeguard your information.
For your confidentiality and security, we use ID to secure your personal information. It is important for you to protect your ID, or any personal information. Do not disclose your personal information to anyone. When you are finished using our services, please do not forget to log out from your account. If you share a computer, whether in a public or private setting, be sure to sign off and close your browsers when finished using a shared computer.
If you believe that the security of your data has been compromised, or if you like more information on the measures we use to protect your data, please contact us following the instructions in the “Whom should I contact?” section below.
What are your choices?
You have the choice to allow us to collect and process your data. The collection and processing of your personal data is neither a statutory nor a contractual requirement, although as noted above, we will be unable to provide you with certain services without the data necessary for such services purposes.
If you are dealing with us online, note that most browsers will inform you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies. Additionally, you can disable or delete data used by browser add-ons, such as Flash cookies, on your browser or on the website of its manufacturer.
You can always choose not to provide your data to us, although we may need such data to process your requests, in which case we will inform you of our constraints.
To the extent that you have consented to our processing of your data, you can choose to discontinue our processing at any time.
You can choose to request from us a copy of the personal data we store and process regarding you.
You can choose to add or update data that you have provided to us.
You can choose to erase your data, or you may choose to restrict our processing of your data instead.
You can choose to port your data to a third party under conditions stated above.
You can choose to object to our processing of your data.
Your choice or request on any aspects of data processing listed above can be communicated to us using the channels set forth in the “Whom should I contact?” section of this Notice.
In summary, what we are allowed to do with your data is, with limited exceptions under applicable privacy laws, up to you. However, in the event that you choose for us not to further process your data, such choice may affect the delivery of our obligations or services to you; in this situation, we will inform you of our constraints.
Whom should I contact?
If you have any question about this Notice, or if you would like to exercise any of your rights, or if you have any complaints that you would like to discuss with us, please in the first instance send us your signed and dated request. Please be as accurate as possible:
by post to
BriteMED Technology Inc.
Data Protection Officer
[3F., No. 306, Sec. 1, Datong Rd., Xizhi Dist., New Taipei City 221, Taiwan (R.O.C.)]
by log on to www.britemed.com.tw/sarf
In case of disagreements relating to our processing of your personal data, you can submit a request for mediation or other administrative action to the data protection supervisory authority with the competent authority where you reside or in which your data is processed. Please click here for a list of local data protection authorities in EEA countries: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.