returnTJ Biopharma Privacy Policy
I. Introduction
This Privacy Protection Policy (hereinafter referred to as "Policy") aims to inform you about how TJ Biopharma (Hangzhou) Co., Ltd. and its subsidiaries and/or branches (hereinafter referred to as "TJ Bio" or "we") process (including collecting, using, storing, sharing, transferring, disclosing) and protect your personal information when you use our products, services, participate in our activities, or interact with us through other means or visit our websites or other online resources (e.g., WeChat official accounts) (hereinafter collectively referred to as “Service” or "Services").
We fully understand the importance of personal information to you and will take corresponding security protection measures in accordance with relevant laws and regulations to protect the security and privacy rights of your personal information. Please read and understand the entire content of this Policy carefully before using our Services. Your continued use of our Services or provision of personal information indicates that you have fully understood and agreed to the entire content of this Policy (including updated versions). If you do not agree with this Policy, please stop using our Services immediately.
II. Personal Information Collection
(I) Collection Principles
We adhere to the principles of legitimacy, legality, and necessity, collecting and using your personal information only for the purposes of the Services described in this Policy. If we intend to use your information for purposes not specified in this Policy, or use information collected for a specific purpose for other purposes, we will inform you in a reasonable manner and obtain your consent as required by laws and regulations before such use.
(II) Collection Methods and Content
1. Information You Actively Provide
• When you register for our Services, such as visiting TJ Bio's website or WeChat official account, you need to provide us with information such as mobile phone number, name, ID type, ID number, your organization name, position, email address, WeChat ID, etc.
• When you make medical inquiries, product complaints, etc., to us, you may need to provide additional information, such as name, contact phone number, country, province and city, postal code, email address, age, gender, type of inquirer/complainant (e.g., patient, distributor employee, healthcare professional), content of the inquiry/complaint, details on the usage of the pharmaceutical product being inquired about or complained of, and other medical and health information.
• TJ Bio establishes a pharmacovigilance system in accordance with the law, conducts monitoring of adverse drug reactions, collects, tracks and analyze suspected adverse drug reaction information, and takes timely risk control measures for identified or potential safety risks. To collect and record safety information, when you report adverse events and other safety-related information, you may need to provide information such as the name, age, date of birth, gender, address, phone number, postal code, country, contact information, information related to the personal health status, and medication information (dosage, indication, route of administration, etc.) of the patient/consumer/subject/clinical trial participant, description of the adverse event, medical history, etc.; you may also need to provide the reporter's name, profession, address, postal code, country, phone number, email, relationship to the patient, practice institution (if a healthcare professional), etc..
• When you visit our offices, contact us, participate in activities we organize, or provide feedback to us, you may need to provide interaction information such as name, contact information, organization name, position, related questions, or opinions. We may also take audio or video recordings, or photograph for related meetings and activities, which may involve collecting your portrait, voice, etc.
• According to clinical trial-related laws and regulations, when you participate in our clinical trials as an investigator, we need to collect your name, contact information, working organization, educational background, training records, work experience, professional qualifications, etc. When you apply to participate in our clinical trials as a subject/clinical trial participant, we need to collect your year of birth, gender, nationality, height, weight, ethnicity, efficacy and safety-related information, diagnosis and treatment records, medical records, medication information, test reports, treatment follow-up information. We will de-identify the personal information of subjects/clinical trial participants.
• When you apply for job opportunities with us, you need to provide us with information such as your name, educational background, work experience, qualification certificates, etc.
2. Information We Collect Automatically
• When you visit our website or use our Services, our system automatically collects technical information such as your IP address, browser type, operating system, access time, pages visited, website browsing information, etc. This information helps us optimize the Service experience and ensure Service security.
• We may use technologies such as Cookies and pixel tags to collect information about your browsing habits, preferences, etc., to provide you with more personalized Services. You can refuse or manage Cookies through your browser settings, but this may affect your use of some of our functions.
III. Collection of Sensitive Personal Information
If the information you provide to us may contain your sensitive personal information (as defined in the "Personal Information Protection Law of the People's Republic of China"), such as biometric information, religious beliefs, specific identity, medical health, financial accounts, location tracking, etc., as well as personal information of minors under the age of fourteen. Before you provide any sensitive personal information, please carefully consider whether it is appropriate to provide such information and agree that your sensitive personal information may be processed for the purposes and in the manner described in this Policy. If you refuse to provide such information, it may affect your use of the corresponding Services or prevent the achievement of the corresponding purposes, but it will not affect our provision of other Services to you. We promise you that TJ Bio will process your sensitive personal information with the utmost care and take corresponding technical and management measures to fully protect the security of your personal information. We anticipate that processing your sensitive personal information according to this Policy will not have an adverse impact on your rights and interests.
IV. Collection of Minors' Personal Information
We place great importance on the protection of minors' personal information.
Unless otherwise stated, our Services are mainly aimed at adult users, and we do not collect minors' personal information. If required by specific business needs, we will collect minors' personal information after obtaining authorization from their guardians (e.g., clinical trial data of minors or adverse reaction reports of minors' medication, some online/offline activities open to minors, etc.).
If you are a minor under the age of eighteen, you should obtain the consent of your guardian in advance before using our Services. We only collect, use, or disclose minors' personal information when permitted by laws and regulations, with the explicit consent of the guardian, or when necessary to protect the interests of the minor. The personal information of children under the age of fourteen is sensitive personal information, and we will take stricter protective measures. If you are the guardian of a minor, please read and understand the content of this Policy carefully before providing us with the minor's personal information. If you find that we have collected a minor's personal information without your consent, or if you have any questions or concerns about our processing of a minor's personal information, please contact us promptly through the contact methods specified in this Policy, and we will take measures as soon as possible, such as deleting the relevant information.
V. Information Use
(I) Purposes of Use
We collect your personal information mainly for the following purposes:
1. To provide, maintain, and improve our Services for you, including but not limited to account registration, identity verification, providing customer support, processing your requests, etc.
2. To send you Service-related notifications, including but not limited to important announcements, Service updates, security warnings, etc.
3. To provide you with personalized Service content and recommendations, for example, recommending products, Services, or information that may be of interest to you based on your browsing history, preferences, etc. You will not be subject to decisions based solely on automated decision-making that have significant effects on you, unless we have a reason to do so and we have notified you.
4. To conduct data analysis and research to understand user needs and behavior and optimize our Services and operational strategies.
5. To protect the legitimate rights and interests of us, you, or other users, such as preventing fraud, handling disputes, protecting intellectual property rights, etc.
6. To comply with applicable laws and regulations or respond to lawful requests from government departments.
(II) Methods of Use
We will use technical means to de-identify, encrypt, or anonymize your information to ensure its security. Without your consent, we will not provide any of your personal information to any third party, except in the following circumstances:
1. Directly related to national security and national defense security;
2. Directly related to public security, public health, and significant public interests;
3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
4. Necessary for protecting the life, property, and other significant legitimate rights and interests of you or other individuals, but where it is difficult to obtain your consent;
5. The personal information collected is disclosed by you to the public on your own initiative;
6. Collecting personal information from legally publicly disclosed information, such as through lawful news reports, government information disclosure, etc.;
7. Related to obligations stipulated by laws and regulations, regulatory requirements, and relevant provisions of industry authorities;
8. For safeguarding the ownership and related rights of this website.
VI. Entrusted Processing, Sharing, Transfer, and Public Disclosure of Information
(I) Entrusted Processing
TJ Bio may engage contract research organizations (CROs) and other third-party service providers (e.g., software and information technology service suppliers, etc.) to provide related Service support for TJ Bio. These entities process your personal information on behalf of TJ Bio and are subject to TJ Bio's supervision. TJ Bio will require them to take appropriate confidentiality and security measures to protect the security of your personal information.
(II) Sharing
TJ Bio will not share your personal information with companies, organizations, or individuals outside of TJ Bio, except in the following circumstances:
1. With your explicit consent obtained in advance.
2. Sharing as required by law: We may share your personal information as required by laws and regulations, regulatory requirements, litigation dispute resolution needs, or according to requests made by administrative or judicial authorities in accordance with the law.
3. Sharing with our partners: To provide you with more comprehensive Services, we may share part of your personal information with partners, but we will require partners to strictly protect your personal information in accordance with this Policy and relevant laws and regulations, and only for the purpose of providing Services.
4. TJ Bio may provide your personal information to other processors according to relevant laws, regulations, and regulatory requirements, such as drug regulatory authorities like China's National Medical Products Administration, the U.S. Food and Drug Administration, etc.
(III) Transfer
TJ Bio will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
1. With your explicit consent obtained in advance.
2. In the event of mergers, acquisitions, asset transfers, or similar transactions, if personal information transfer is involved, we will require the new holder of your personal information to continue to be bound by this Policy; otherwise, we will require that company or organization to seek your authorization and consent again.
(IV) Public Disclosure
TJ Bio will only publicly disclose your personal information under the following circumstances:
1. With your explicit consent obtained in advance.
2. We may publicly disclose your personal information as required by laws and regulations or mandatory orders from administrative or judicial authorities.
VII. Information Storage
(I) Storage Location
In principle, TJ Bio stores your personal information within the territory of the People's Republic of China. We will only provide it to overseas affiliates, partners, service providers, or regulatory authorities when necessary for asset transfer/acquisition, business cooperation, or required by regulations.
To meet the requirements of pharmacovigilance regulations applicable globally, TJ Bio needs to submit drug safety data to relevant partners, marketing authorization holders of other medicinal products, and drug regulatory authorities to comply with applicable pharmacovigilance quality management standards. TJ Bio needs to provide your personal information overseas for this purpose.
(II) Storage Period
TJ Bio will store your personal information for the period required by laws and regulations and necessary to achieve the purposes of the Services. After the storage period expires, we will delete or anonymize your personal information.
VIII. Your Rights
(I) Right to Know
You have the right to know how your personal information is collected and used.
(II) Right of Access
You have the right to access (including consult and copy) your personal information, including your registration information, usage records, etc. You can contact us through our service interface or the contact information below to request access (including consultation and copying) to your personal information.
(III) Right to Correct and Supplement
If you find that the personal information we collect and store about you is inaccurate or incomplete, you have the right to request us to correct or supplement it. You can contact us through our service interface or the contact information below to request correction or supplementation of your personal information.
(IV) Right to Deletion
Under the following circumstances, you have the right to request us to delete your personal information:
1. Our collection or use of your personal information violates applicable laws and regulations, or breaches the agreement between us;
2. Our collection or use of your personal information exceeds the necessary scope or purpose;
3. You no longer use our Services, or you have cancelled your account, or you have withdrawn your consent;
4. The purpose of our processing has been achieved, become impossible to achieve, or the personal information is no longer necessary for achieving the processing purpose;
5. We have ceased providing products or Services, or the storage period has expired;
6. Other circumstances stipulated by laws and regulations.
If the retention period stipulated by laws and administrative regulations has not expired, or if deletion of personal information is technically difficult, we will cease processing except for storage and taking necessary security protection measures.
Please understand that due to our legal obligations under pharmacovigilance regulations, TJ Bio may not be able to delete or restrict the processing of your information if it is processed for pharmacovigilance purposes.
(V) Right to Withdraw Consent
You have the right to withdraw your consent to our collection and use of your personal information. You can contact us through our service interface or the contact information below to withdraw your consent. However, please note that withdrawing consent may affect your use of some of our Services. The withdrawal of consent does not affect the validity of personal information processing activities we have carried out based on your consent before your withdrawal.
(VI) Right to Restrict Processing
You have the right to request restriction of the use of your personal information, even to "lock" your personal information, to enable you to exercise other rights. During this period, your personal information will no longer be used by us, but you understand that we still need to store your personal information.
(VII) Right to Data Portability
You have the right to request the transfer of your personal information to another personal information processor. TJ Bio will provide a means for the data processor you designate to access and obtain the relevant personal information if the following conditions for the personal information transfer request are met:
1. The identity of the requester can be verified;
2. The personal information requested for transfer is provided with your consent or collected based on a contract;
3. Transferring the personal information is technically feasible;
4. Transferring the personal information does not harm the legitimate rights and interests of others.
If the number of requests to transfer personal information, etc., obviously exceeds a reasonable range, TJ Bio may charge necessary fees based on the cost of transferring the personal information.
(VIII) Right to Account Cancellation
You may cancel the account you previously registered through channels such as official accounts at any time. Upon cancellation of the account, we will stop providing you with the corresponding Services and delete your personal information as requested by you, unless otherwise stipulated by laws and regulations.
(IX) Right to Complain and Report
If you believe that TJ Bio's personal information processing activities violate applicable laws and regulations or the terms of this Policy, you have the right to complain or report to us, or to the relevant regulatory authorities.
IX. Information Security
TJ Bio has taken reasonable technical and management measures to ensure the security of your personal information and prevent its leakage, alteration, damage, or loss. For example, we use encryption technology to store your personal information encrypted; we implement strict access permission management for personnel accessing your personal information; we regularly evaluate and improve our information security management system.
Although we have taken the above security measures, please note that no security measures are absolutely secure. You need to properly keep your account, password, and other authentication information to avoid personal information leakage due to your negligence.
X. Policy Changes
We may update this Policy from time to time in response to changes in applicable laws and regulations, business development, technological advancements, or other relevant factors. We will publish the updated Policy on our website or service interface and notify you through appropriate means. Please check for updates to this Policy regularly.
XI. Third-Party Websites and Hyperlinks
This website may provide links to other websites as a Service to visitors of our website. We believe these websites may provide useful information. However, TJ Bio does not endorse and is not responsible for the content or privacy policies of third-party websites. Similarly, TJ Bio cannot control the information you choose to provide to these websites.
XII. Contact Information
If you have any questions, comments, or suggestions regarding this Policy, or need to exercise your personal information-related rights, you can contact us through the following methods:
Email: compliance@tjbio.com
Contact Address: 6th Floor, Building 3, Hexiang Technology Center, Qiantang New District, Hangzhou City, Zhejiang Province, China
Postal Code: 310018
We will respond to your request within 15 working days after receiving it. For reasonable requests, we generally do not charge fees, but for multiple repeated requests or requests exceeding reasonable limits, we may charge a certain fee to cover the relevant costs depending on the situation. For groundless repeated requests, requests requiring excessive technical means (e.g., requiring the development of new systems or fundamental changes to current practices), requests posing risks to the legitimate rights and interests of others, or very impractical requests, we may refuse but will explain the reasons to you.