Personal Information Protection Policy of Suzhou Abogen Biosciences Co., Ltd Official Website

Updated:November 29,2021
Effective:November 29,2021

Respected User,

Thank you for visiting the Official Website of Suzhou Abogen Biosciences Co., Ltd (, (hereinafter referred to as "Official Website"). The Official Website of Suzhou Abogen Biosciences Co., Ltd is operated by Suzhou Abogen Biosciences Co., Ltd and its Affiliates (hereinafter referred to as "Abogen Biosciences" or "We"). We are fully aware of the importance of personal information to you and will do our best to provide security for your personal information. We will protect your personal information in accordance with the requirements of national laws and regulations, abide the principles of unanimity of rights and responsibilities, clear purpose, consent of choice, minimum sufficiency, openness and transparency, ensuring safety, and subject participation. In order to help you understand what personal information We have collected through visiting the Official Website, and how We use, save, share and transfer this information when you visit our Official Website, We have made this "Suzhou Abogen Biosciences Co., Ltd Official Website Personal Information Protection Policy" (Hereinafter referred to as "This Policy"). Please read This Policy carefully, especially the content in bold. If you have any questions, comments or suggestions, you can contact us through the contact information in Section 11 of This Policy.

1.To complete the business functions you agree to use.

2.To ensure the safety and quality of the services We provide to you.

3.A longer retention period agreed by you.

4.Whether there is any other specific agreement on the retention period.

After the retention period expires, We will delete your personal information or de-identify it in accordance with the requirements of applicable laws.

If We stop operating the Official Website and related services, We will promptly stop collecting your personal information, and We will notify you of the suspension in the form of a public announcement. At the same time, the personal information We store will be deleted or de-identified.

VI. How We share, transfer, and publicly disclose your personal information

(1) Sharing

We will not share your personal information with any corporation, organization or individual, except in the following circumstances.

1. We will share your personal information with third parties under your express consent.

2. We may share your personal information with third parties to comply with laws and regulations, the need for litigation dispute resolution, or the requirements of administrative and judicial agencies.

3. To the extent permitted by laws and regulations, it is necessary to share your personal information in order to protect the benefit, property or safety interest of us, our affiliates or partners, you or other Abogen Biosciences users or the general public from damage.

4. Share with our affiliates. In order to provide services for you, We may share your personal information with our affiliates. However, We will only share necessary personal information, and the use of your personal information by affiliates is governed by This Policy or the Affiliates policy that is authorized by you and provides your personal information with substantially similar level of protection as This Policy. We and our affiliates will strictly abide by the personal information and data security protection policy of Abogen Biosciences.

(2) Transfer

We will not transfer your personal information to any other corporation, organization or individual, except in the following circumstances.

1. Obtained your express consent or authorization in advance.

2. Required by applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements.

3. Comply with the relevant agreement signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents provided.

4. With the growth of our business, We and our affiliates may conduct mergers, acquisitions, asset transfers or other similar transactions. If the relevant transaction involves the transfer of your personal information, We will require the transferee corporation, organization and individual that holds your personal information to continue to be bound by This Policy, otherwise We will require such transferee corporation, organization and individual to re-obtain your authorization and consent.

(3) Public disclosure

We will only disclose your personal information publicly under the following circumstances.

1. After obtaining your express consent.

2. We may publicly disclose your personal information when required by law, legal proceedings, litigation or compulsory requirements by governmental authorities.

VII. How We protect your personal information

We greatly value the security of your personal information, and We have taken industrial standard security measures to protect the personal information you provided to prevent unauthorized access, public disclosure, use, modification, damage or loss of data.

1.Abogen Biosciences has specifically appointed personal information security department,which is responsible for handling various affairs relevant to users' personal information that may be involved in Abogen Biosciences products and services, as well as drafting and establishing company policies, and reviewing user agreements for each product, supervising work principles and information processing mechanism for each product. The contact information of such department responsible for personal information security is as follows.

Person responsible for personal information security: Cybersecurity Department

contact details: 0512-69150735

We ensure the security of information by establishing special management systems, processes, organizations and other management measures. For example, We have established an overall principle and security strategy for information security work, established a security management system at various levels, and clarified the responsibilities, division of duties, and professional requirements of various different departments and positions within the security management organization.

2. We deploy an access control mechanism on the server end and adopt the principle of minimum sufficient authorization for staff who may have access to your personal information.

3. We will conduct account auditing and monitoring of server operations. If We discover in an external announcement that a server operating system has security breach, We will update the server security as soon as possible to ensure the security of all server systems and applications.

4. We have established an emergency response protocol for cyber security incidents, and We have allocated sufficient resources to ensure the implementation of the emergency response protocol. If our physical, technical or management protection measures are unfortunately damaged, We will promptly activate emergency protocol to prevent the expansion of security incidents, report to the national governmental agencies in accordance with the requirements of laws and regulations, and promptly adopt reasonable and effective methods such as pushes and announcements to inform you of the basic situation of the security incident, possible impact, measures that have been taken or measures to be taken, etc.

VIII. Your rights

During your use of the Official Website, you can access and manage your personal information in the following ways.

(1) Inquire and correct your personal information

You can contact us to inquire and correct your personal information through the contact information in Section 11.

(2) Delete your personal information

You have the right to request us to delete your personal information under following circumstances.

1. We collected your personal information illegally without your consent.

2. Our processing of your personal information violates the requirements of laws and regulations.

3. Our usage and processing of your personal information violated our agreement with you.

4. You no longer use our products or services.

5. We have stopped providing services to you.

You can contact us to request the deletion of your personal information through the methods provided in article 11 of This Policy, and We will reply within 15 business days. After We delete your personal information from the server, We may not delete the corresponding data from the backup system immediately, but We will delete such information when the backup is updated.

Please note that if the retention period stipulated by laws and administrative regulations has not expired or the deletion of personal information is technically difficult to achieve, We may not be able to delete your personal information, but We will stop processing your personal information in a timely manner.

(3) Withdraw your authorization and consent

Each business function requires some basic personal information to be completed. For the collection and use of additional personal information, you can give or withdraw your authorization and consent at any time. Your withdrawal of authority does not affect our previous processing activities of your personal information, but We will not continue to process your personal information. You can contact us through the contact information in article 11 to change the scope of your authorization.

IX. Protection of personal information of minors

Our products, websites and services are mainly for adults. Without the consent of their parents or guardians, minors under the age of 14 are not allowed to use our products or services.

For the collection of minors’ personal information with parental consent, We will only use or publicly disclose this information when permitted by law, the parent or guardian's express consent or necessary to protect the minor.

If We discover that We have collected minors’ personal information without obtaining verifiable parental consent, We will try to delete the relevant data as soon as possible.

X. Changes and revisions to This Policy

Our personal information protection policy may change. Without your express consent, We will not restrict your rights in accordance with This Policy.

For material changes to This Policy, We will provide significant notice. You can also browse the Official Website to check the latest policy at any time.

The material changes referred to in This Policy include but are not limited to the following:

1.Our service model has undergone material changes. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.

2.Significant changes have taken place in our control and other aspects. Such as ownership changes caused by mergers and acquisitions, etc.

3.Changes in the main objects of personal information sharing, transfer or public disclosure.

4.Material changes of your right to participate in the processing of personal information and how to exercise it.

5.Changes in our administering department, contact information and complaint channels for handling personal information security.

6. When the personal information security impact assessment report shows that there is a high risk.

If you continue to use our website after such changes and revisions, it will be deemed that you agree to the changes and revisions of This Policy.

XI. How to contact us

Suzhou Abogen Biosciences Co., Ltd is the operator of the Official Website of Abogen Biosciences, which is also the controller of your personal information. Our registered address is Biobay, B1-501, 218 Xinghu Ave., Suzhou, China. If you have any questions, comments, suggestions or complaints about our policies and the handling of your personal information, please call 0512-69150735 to contact us.

Under normal circumstances, We will respond to your request within 15 business days. You understand that due to review of material, business verification, operational procedures, etc., the processing time of your request may be longer than the 15 business day time limit. If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legitimate rights and interests, you may also file a complaint or report to the supervisory departments of Jiangsu Internet, Telecommunications, Public Security, Industry and Commerce where We are located. You may call our local government hotline (for example, 12345) for complaints or reports or file a lawsuit with a court with jurisdiction in our location (Suzhou, Jiangsu). You may call the Jiangsu Municipal Court's consultation telephone number 12368 to inquire about the lawsuit. We sincerely hope that you can conduct friendly consultations with us before you file a complaint with the government or the court. We welcome and thank you for your supervision and suggestion.

XII. Effectiveness of This Policy

This Policy is established on November 29, 2021, and is officially effective on November 29, 2021.