Winhealth Pharmaceutical Group Co., Ltd. and its affiliates (collectively, “Winhealth Pharma,” “we,” “us,” or “our”) are committed to protecting your privacy when you visit the Winhealth Pharma website  (the “Site”) or otherwise interact with us online. This Privacy Policy (this “Policy”) describes the types of information we may collect from you or that you may provide when you access the Site, and our practices for collecting, using, maintaining, protecting, and disclosing that information. We may update this Policy from time to time. We encourage you to review this Policy periodically for any changes. Your continued use of the Site after we make changes is deemed to be acceptance of those changes.

This Policy is formulated in strict compliance with applicable laws, regulations, national standards, and regulatory requirements, including but not limited to the Personal Information Protection Law of the People's Republic of China, the Data Security Law of the People's Republic of China, the Cybersecurity Law of the People's Republic of China, the Regulations on the Administration of Network Data Security, and the Information Security Technology — Personal Information Security Specification (GB/T 35273).

Please read this policy carefully to understand our policies and practices regarding your information and how we will handle it. If you do not agree with this policy and our practices, you may choose not to use the Site or register for any services or information provided by Winhealth Pharma. By accessing or using the Site, you acknowledge and agree to this policy.

The Site may contain links to or references of third-party websites. Please be aware that this policy does not apply to such third-party websites. We recommend that you review the privacy policy of each such website before providing any Personal Information.

1. Information We Collect and How We Collect It

We may collect the following categories of information from and about you:

• Personal Information – information that can identify you as an individual, such as your name, gender, age, postal address, email address, telephone number, job title, and organization name.

• Related Information– information that relates to you but does not, on its own, identify you, such as your user category (e.g., patient, healthcare professional, pharmaceutical industry practitioner, general visitor).

• Correspondence Records – records and copies of your correspondence with us.

• Internet-Generated Data – including your IP address, operating system, browser type, search queries on the Site, device information, and other website usage details (e.g., traffic data, location data, logs, and the resources you access and use).

• Survey Information – responses to survey questionnaires issued by us in connection with our business.

2. Sensitive Personal Information

We may collect Sensitive Personal Information from you, including medical and health data (such as disease conditions, medication records, and physical examination data), specific identity information, and Personal Information of minors under the age of 14. We will process such Sensitive Personal Information only where it is for a specific purpose and strictly necessary, and after implementing appropriate protective measures and obtaining your separate explicit consent. Prior to such processing, we will conduct a Personal Information protection impact assessment in accordance with applicable laws.

3. Information about Minors

The Site is not directed to individuals under the age of 18. Individuals under 18 shall not provide any Personal Information on the Site. We do not knowingly collect Personal Information from children under the age of 14. If we become aware that we have inadvertently collected such information, we will delete it promptly.

4. Methods of Collection

We collect information:

• Directly from you when you provide it to us through the Site;

• Automatically as you navigate the Site, through cookies and other tracking technologies as further described below; and

• From third parties, such as our business partners and agents.

5. Cookies and Other Tracking Technologies 

We use cookies and similar technologies for the following purposes: (i) to recognize your unique preferences, and (ii) to track user trends and patterns to better understand and improve the Site and enhance your experience. You may refuse cookies by adjusting your browser settings. Please note that if you disable cookies, some features of the Site may not function properly.

6. Third-Party Use of Cookies and Other Tracking Technologies

Certain content or applications on the Site, including advertisements served via social media and other websites, are provided by third parties (e.g., advertisers, ad networks, content providers). These third parties may use cookies, web beacons, or other tracking technologies to collect information about you when you use the Site. Such information may be combined with your Personal Information or may reflect your online activities over time and across different websites. They may use this information to deliver interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or their use. If you have any questions about targeted content, you should contact the responsible provider directly.

7. How We Use Your Information

We use the information we collect about you or that you provide to us, including Personal Information, for the following purposes:

• To respond to your inquiries and provide you with information about Winhealth Pharma and our products and services in accordance with your preferences;

• To present the Site and its content in a manner tailored to your preferences;

• To perform statistical analyses and to improve, develop, and enhance the Site and our offerings;

• To fulfill any other purpose for which you provide the information;

• To send you notices, including updates regarding the Site or our products and services;

• To carry out our obligations and enforce our rights arising from any contract entered into between you and us, including billing and collection;

• To enable your participation in interactive features of the Site;

• In any other manner described at the time of collection; and

• For any other purpose with your consent.

8. Disclosure of Information

We do not share Personal Information with unaffiliated third parties for their own direct marketing purposes. However, we may disclose aggregated information about our users and other non-identifying information without restriction.

We may disclose Personal Information collected as described in this Policy to the following categories of recipients:

• Our subsidiaries and affiliates, provided they comply with this Policy;

• Contractors, service providers, and other third parties who support our business and are contractually obligated to maintain the confidentiality of Personal Information and use it only for the purposes for which it was disclosed;

• A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Winhealth Pharma’s assets, in which Personal Information held by us about our Site users is among the assets transferred;

• Parties to whom we need to disclose information in order to accomplish the purpose for which you provided it;

• Other parties with whom we share information after obtaining your separate consent; and

• As otherwise required or permitted by law.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including in response to any government or regulatory request;

• To enforce or apply our Terms of Use and other agreements; and

• When we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Winhealth Pharma, our users, or others.

9. Cross-Border Transfer of Personal Information

Winhealth Pharma is headquartered in Hong Kong, and certain business operations may involve the transfer of your Personal Information outside the People's Republic of China (including to the Hong Kong Special Administrative Region). Where such cross-border transfer occurs, we will inform you of the name and contact information of the overseas recipient, the purposes and methods of processing, the categories of information transferred, and the associated risks, and we will obtain your separate consent. We will take necessary measures, such as conducting security assessments, adopting standard contractual clauses, or obtaining certifications in accordance with applicable requirements of the national cyberspace administration, to ensure that the overseas recipient provides a level of protection consistent with Chinese legal standards.

10. Your Choices Regarding Use and Disclosure

We strive to provide you with meaningful choices regarding the use and disclosure of your information. You may:

(1) Choose not to provide Personal Information on the Site;

(2) Set your browser preferences to block cookies related to your use of the Site;

(3) Follow the unsubscribe instructions included in communications sent to you; and/or

(4) Unsubscribe from our services by emailing us at contactus@winhealth.hk.

11. Accessing, Correcting, Deleting, and Exercising Other Rights

You may send an email to contactus@winhealth.hk to request access to, correction, deletion, or copying of any Personal Information you have provided to us, or to request the cancellation of your account or withdrawal of your consent. We may decline such requests where we believe the change would violate any law or legal requirement, or would render the information inaccurate. We will respond to all legitimate requests within fifteen (15) business days.

Proper access and use of information provided on the Site are subject to our Terms of Use.

12. Data Security

We have implemented appropriate technical and organizational measures to protect your Personal Information against unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls and is protected by encryption and other safeguards.

However, the transmission of information via the internet is not completely secure. Although we strive to protect your Personal Information, we cannot guarantee the security of your data transmitted to the Site. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

13. Retention Period

We retain your Personal Information for as long as necessary or permitted in light of the purposes for which it was collected and as set forth in this Policy. The criteria used to determine our retention periods include: (i) the duration of our ongoing relationship with you and provision of the Site services; and (ii) whether we are subject to a legal obligation (e.g., statutory retention periods for financial or medical records).

14. Updates to This Privacy Policy

We may update this Policy from time to time. We will post any changes on this page and, where appropriate, notify you via email or through the Site. The date of the most recent revision will be indicated at the top of the Policy. We encourage you to review this Policy regularly to stay informed about how we are protecting your information.

15. Governing Law and Dispute Resolution
This Policy and all matters relating to your use of the Site shall be governed by and construed in accordance with the laws of the People’s Republic of China, without regard to its conflict of laws principles. Any dispute arising out of or in connection with this Policy shall be submitted to the competent courts of the place where Winhealth Pharma is domiciled, unless otherwise required by applicable law.

16. Contact Us

If you have any questions, concerns, or suggestions regarding this Privacy Policy or our privacy practices, please contact us at:

Winhealth Pharmaceutical Group Co., Ltd.  

Address: 7th Floor, Building A, Fengqigu Huazhang, No. 520 Shaoxing Road, Gongshu District, Hangzhou, Zhejiang Province, China  

Email: contactus@winhealth.hk