Our Privacy Policy was updated on: June 6, 2024

About us

Bluesail Surgical Co., Ltd.and its affiliated companies Changzhou Tongchuang Medical Instrument Technology Co., Ltd., Ningbo Hitcm Medical Devices Co.,Ltd. , Bluesail Surgical HK Limited (hereinafter refer to as “Bluesail Surgical”, “we”, “our” or “us”) take your privacy very seriously. This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to Bluesail Surgical.

About this privacy policy

This Privacy Policy explains how Bluesail Surgical collects, uses, discloses, processes and protects any personal information that you give us or that we collect from you. Should we ask you to provide certain information by which you can be identified when you use the services on our platform, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users. Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information Bluesail Surgical has access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy.

How we can help you

Ultimately, what we want is the best for all our users. Should you have any questions with our data handling practices as summarized in this Privacy Policy, please contact us：[sim@bluesail.cn]

1 What information is collected by us and how do we use it?

1.1 What information is collected by us

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. We will only collect the information that is necessary for its specified, concrete, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our services or respond to your queries. Depending on the service you choose, we may collect the following types of information:

1.1.1 Information you provide to us

We may collect any personal information you provide to us, which is necessary for the service you choose. For example, your name, contact information, title, etc.

1.1.2 Information that we collect in your use of services

We may collect log information related to your use, such as cookies, IP addresses. Log information is information related to your use of certain features of the websites. For example, cookies and IP addresses, network request information, standard system logs, crash information, log information generated by using the services (such as access time, activity time, etc.). 

1.2 How we use the personal information that we collect

The purpose of collecting personal information is to provide you with services, and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:

· Providing, processing, maintaining, improving and developing our services to you.

· Handling your questions or requests about our services

· Conducting relevant promotional activities. 

· Internal purposes such as data analysis, research, and development of statistical information related to the use of our services for improvement.

· Storing and maintaining information related to you for our business operations (such as business statistics) or for fulfilling our legal obligations.

· Other purposes with your consent.

2 Cookies and other technologies

Technologies such as cookies, tags, and scripts are used by Bluesail Surgical and our third party service providers and business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below). These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. These technologies help us better understand users’ behavior, tell us which parts of our websites people have visited, as well as facilitate and measure the effectiveness of web searches. We treat information collected by cookies and other technologies as non personal information, except where Internet Protocol (IP) addresses or similar identifiers are considered personal information by local laws.

· Log files: As true of most websites, we gather certain information and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we gather about you.

· Local storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our sites also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.

3 How we share, transfer, and publicly disclose your personal information

3.1 Sharing

We do not sell any personal information to third parties.

We may sometimes share your personal information with third parties (as described below) in order to provide or improve our services, including offering services based on your requirements. If you no longer wish to allow us sharing this information, please contact us.

3.1.2 Sharing with third party service providers and business partners

To help us provide you with services described in this Privacy Policy, we may, where necessary, share your personal information with our third party service providers and business partners.  We guarantee that the sharing of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. 

3.1.5 Other

In accordance with legal requirements, legal procedures, litigation and/or requests from public agencies and government agencies, Bluesail Surgical may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.

In order to enforce our terms or protect our business, rights, assets or services, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the service, violations of our terms or policies, or other harmful or illegal activities), we may also disclose information about you. (There may be occasions when Bluesail Surgical may collect, use or disclose your personal information without your consent if it is and only to the extent it is permitted under applicable data protection laws). This may include providing your personal information to public or government agencies; communicating with third-party partners about the reliability of your account to prevent fraud, violations, and other harmful behaviors.

In addition, we may share your personal information with:

· our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice; and

· investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to an entity in the Bluesail Surgical Group; and

· any other third parties, if authorized by you to do so in relation to a specific disclosure.

3.2 Transfer

Bluesail Surgical will not transfer your information to any subject except in the following cases:

· Where we have obtained your explicit consent;

· If Bluesail Surgical is involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any changes in the ownership, use, and any choice of your personal information you possibly possess by email and/or by posting a prominent notice on our websites.

3.3 Public disclosure

Bluesail Surgical will only publicly disclose your personal information under the following circumstances:

· Where we have obtained your explicit consent;

· Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation, or at the request of the competent government departments.

4 How we store and protect your personal information

4.1 Bluesail Surgical’s security safeguards

We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place all legally required physical, electronic and managerial procedures to safeguard and secure the information we collect from you. 

All your personal information is stored on secure servers, and protected in controlled facilities. We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal information. We conduct security and privacy protection training courses and tests to enhance our employees' awareness of the importance of protecting personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information when transferred from you or to you via the Internet.

4.2 Retention policy

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy, or as required by applicable laws. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding service. An exception to this is personal information that we are processing for public interest, scientific, historical research, or statistical purposes. Bluesail Surgical will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

5 Your rights

CONTROLLING YOUR PERSONAL INFORMATION

5.1 Your rights to your personal information

Depending on applicable laws and regulations, you have the right to access, rectification, and erasure of any other personal information that we hold about you (hereinafter referred to as the request).

5.2 Withdrawal of consent

You may withdraw your consent previously provided to us for a particular purpose by submitting a request, including collecting, using, and/or disclosing your personal information in our possession or control.

6 How your personal information is transferred globally

Bluesail Surgical processes and backs up personal information through a global operating and control infrastructure. Currently, Bluesail Surgical has data centers in the United States, Germany and Singapore. For the purposes described in the Privacy Policy, your information may be transferred to these data centers in accordance with applicable law.

We may also transfer your personal information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. The jurisdiction in which these global facilities are located may or may not protect personal information to the same standards as in your jurisdiction. There are different risks under different data protection laws. However, this does not change our commitment to comply with this Privacy Policy and to protect your personal information.

If we need to transfer personal information outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with related applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing uniform safeguards. 

7 Protection of minors

We consider it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing.

8 How we update this privacy policy

We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. Such changes to Privacy Policy will apply from the effective date specified in the notice or website. We encourage you to check this page regularly for the latest information on our privacy practices. Your continued use of the services on the website will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal information from you or when we use or disclose your personal information for new purposes.

9 Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to Bluesail Surgical’s collection, use, or disclosure of your personal information, please contact us.