【Special Note】
This policy applies only to products and services and their extended functions (hereinafter referred to as "Starna Therapeutics Services") provided by Starna Therapeutics and its affiliates (hereinafter referred to as "we" or "Starna Therapeutics"), including the Starna Therapeutics website, official WeChat account, video account, and other products and services offered to you in new forms as technology evolves. If a particular product or service we provide has a separate privacy policy or relevant legal statement with special provisions, that product's privacy policy will take precedence. Content not covered by the privacy policy and user service agreement for that product or service shall be subject to this policy. If our affiliates' products or services use products or services provided by Starna Therapeutics but do not have a separate privacy policy, this privacy policy also applies to those products or services.
Please carefully read the "Starna Therapeutics Privacy Policy" (especially the bolded content) and ensure you understand our rules for processing your personal information. If you have any questions during the reading process, please contact us using the contact information in the "Starna Therapeutics Privacy Policy".
Introduction
Welcome to the Starna Therapeutics website (“this website”)!
This website is provided and controlled by Starna Therapeutics (“we”), and our registered address is 2nd Floor, Building 2, No. 99 Jingu Road, Suzhou Industrial Park, Jiangsu Province, People’s Republic of China.
We take user privacy and personal information protection very seriously. When you use our products and/or services, we may collect and use your relevant information. We hope to explain to you through this Starna Therapeutics Privacy Policy (“this Privacy Policy”) how we collect, use, store, share, and transfer this information when you use our products and/or services, and how we provide you with access to, update, delete, and protect this information.
This Privacy Policy will help you understand the following:
1. What types of information we collect from you
2. How we use your information
3. How we share your information
4. Entrusted processing
5. How we protect your information
6. How long we retain your information
7. Protection of personal information for minors
8. Notices and revisions
9. Third-party links
10. Contact us
Table of Contents1. What Types of Information We Collect From You
2. How We Use Your Information
3. How We Share Your Information
4. Entrusted Processing
5. How We Protect Your Information
6. How Long We Retain Your Information
7. Protection of Minors' Personal Information
8. Notices and Revisions
9. Third-Party Links
10. Contact Us
1. What Types of Information We Collect From YouWhen you use this website, we may collect the following categories of information from you:
Information You Provide to Us.We may collect personal information that you provide to us. When you send us information through the "Contact Us" page on this website, you will need to provide your personally identifiable and contact information, such as your name, email address, phone number, country, and city; you may also provide us with your employment information, such as your employer and job title. We may also obtain information about you in your communications with us, such as in your comments, questions, feedback, and other content you provide while using the features of this website.
Information We Collect About You.During your use of this website, we may automatically collect some information about you. This information may include:
• Technical and device information. We may collect certain technical information about you and your device. This information may include, but is not limited to, your IP address, system time zone, system language, and other system or network identification information.
• Operational and behavioral information. We automatically collect information generated when you visit this website and record your activities on this website, including the time you spend on this website, which parts of the website you visit, and what information you access.
• Cookies and similar technologies. This website may use "cookies" and other tracking technologies to store information provided by users of this website. Cookies are fragments of information sent from a web server to a user's browser. Cookies may include information such as user preferences, time spent on the website, and pages visited. We use this information to identify you and to personalize and improve your experience on this website. You can manage your device's cookie settings using the features built into most browsers. For example, you can set your browser to notify you when it receives cookies, or you can choose to block cookies with your browser. However, please note that not accepting cookies may limit your use of certain features of this website. Additionally, please note that this website is currently unable to respond to your "Do Not Track" requests.
Information We Collect From Third PartiesWe may obtain personal information about your use and access to this website from third-party platforms and our service providers, such as your system's country/region, device brand and model, browsing history, including other services you accessed to access our website, search history, and click history.
2. How We Use Your InformationWe may use your information for the following purposes:
Based on our legitimate interests in providing this website, we may use your information for the following purposes:
• To review your comments or questions and provide you with appropriate services;
• To enforce our terms and policies;
• To process and respond to your requests, inquiries, applications, complaints, and feedback;
• To provide support and respond to your requests, feedback, and inquiries;
• To monitor, operate, maintain, and manage this website;
• To handle and resolve technical problems and malfunctions of this website;
• To ensure the effective and efficient operation of this website;
• To detect, prevent, or otherwise resolve security, fraud, or technical problems;
• To improve and enhance the functionality and performance of this website and related services;
• To properly manage and operate our relationship with you;
• To manage our business; and to protect, enforce, or maintain our rights and interests (including our rights and interests in cases of breach of our terms and conditions);
• For academic research purposes;
• For public interest purposes or public health emergencies that comply with laws and regulations.
We may use your information to fulfill our legal obligations and responsibilities. With your consent, or where permitted by law or regulation, we may also process your information for other purposes we disclose to you.
3. How We Share Your InformationWe may share your information with the following third parties:
Service Providers. We may share your information with third parties who provide services to us for the operation and maintenance of this website, such as website hosting service providers, development service providers, and cloud service providers.
Our Affiliates. We may share your information with any member, subsidiary, or affiliate of our company for purposes including preventing unauthorized use and supporting users in order to provide this website.
Law Enforcement Agencies and Competent Authorities. We may share your information with competent authorities, courts, third parties, and other agencies as required by court judgments, subpoenas, legal proceedings, regulatory requirements, or where information is permitted or required by law, including situations where we reasonably believe it is necessary or appropriate to investigate, prevent, or take action against illegal activities, suspected fraud, or potential threats to the personal safety of any person.
Sale or Merger. We may disclose your information to any third party that:
• Acquires or intends to acquire all or part of our assets or shares;
• Is acquired by us in whole or in part.
• Third parties that merge with us; or
• Third parties that succeed us in all or part of our business.
In each of the above circumstances, the third party is legally obligated not to disclose or use your information without our authorization.
Please note that information you voluntarily share, or even publicly share, when using our services may involve your or others' personal information, including sensitive personal information. Please consider carefully before sharing.
4. Entrusted ProcessingWe may entrust authorized partners to process your personal information to provide you with corresponding products or services. However, we will only share your personal information for legitimate, proper, necessary, specific, and explicit purposes, and will only share the personal information necessary to provide the products or services. If our partners use your personal information for purposes not entrusted by us, they will obtain your separate consent.
Our partners include the following types:
Technology service providers. We may provide your personal information to third parties that support our functions, including providers of infrastructure technology services, data analysis services, and data processing services.
Advertising and analytics service partners. We will comply with laws and regulations and industry-standard security technologies, and entrust these partners to process information related to advertising placement, reach, and effectiveness.
For partners who process our personal information, we will sign data protection agreements with them, requiring them to process personal information in accordance with the agreement, this Privacy Policy, and relevant laws and regulations.
5. How We Protect Your InformationWe implement security measures in accordance with this Privacy Policy and have physical, electronic, and administrative processes in place to protect and safeguard the information we process about you. However, there is no absolute security in transmitting data over the internet, and we cannot guarantee the absolute security of your information. You assume all risks associated with transmitting your information to us.
6. How Long Will We Retain Your Information?During your use of this website's services, your personal information will be retained for the period required to achieve the purposes described in this policy, and will also be determined in accordance with legally mandated retention periods. For example, the E-commerce Law of the People's Republic of China requires that information on goods and services and transaction information be retained for no less than three years from the date of transaction completion. After the retention period expires, we will delete your personal information or anonymize it in accordance with applicable laws.
We may also retain your information for other legitimate purposes; for example, when we are bound by laws and regulations, mandatory requirements of administrative and judicial authorities, contracts, or similar obligations and are required to retain personal information. We respect and highly value your rights related to your personal information, including:
Right to access data. You have the right to request confirmation from us regarding whether we are processing your personal information and to request a copy of your personal information.
Right to correction. If any personal information we collect about you is incomplete or inaccurate, you can request us to correct or update that information.
Right to erasure. In certain circumstances, you can request us to erase all or part of your personal information.
Withdrawal of consent. If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. However, if your consent is withdrawn, you may not be able to use some features of this website and our services.
You can contact us in accordance with Section 10 (Contact Us) of this Privacy Policy to exercise any of your rights. To protect your privacy, we may request additional information from you to verify your identity before we process your request.
7. Protection of Personal Information of MinorsStarna Therapeutics attaches great importance to the protection of the personal information of minors. If you are a minor under the age of 18, you should obtain your guardian's consent before using our products and/or services. Starna Therapeutics protects the personal information of minors in accordance with relevant national laws and regulations.
We will not proactively collect personal information from minors directly. For cases where we collect personal information from minors with the consent of their guardians, we will only use, share, transfer, or disclose this information as permitted by law, with the consent of their guardians, or as necessary to protect the minor.
8. Notifications and RevisionsWe reserve the right to revise this Privacy Policy from time to time at our sole discretion. We will notify you of any material changes to this Privacy Policy through notices posted on this website. Such changes apply only to information collected after the revised Privacy Policy takes effect. Any revisions to this Privacy Policy will take effect immediately upon posting. We encourage you to review this Privacy Policy periodically to understand any changes to this Privacy Policy and how we protect your personal information.
9. Third-Party LinksThis Privacy Policy does not apply to any other website or platform unless the context otherwise requires. Please note that this website may include links to other websites, platforms, or products whose privacy policies and practices differ from ours. These links are provided for your convenience and to provide more information. They do not imply any affiliation or sponsorship between us and third-party websites, nor do they represent our endorsement of the information on those websites. We are not responsible for the collection and processing of your information if you provide it to any of these third parties or interact with their websites.
10. Contact UsIf you have any questions about this Privacy Policy, please contact us through our official website.
Generally, we will respond within 15 days. If you are dissatisfied with our response, especially if our processing of your personal information infringes upon your legitimate rights, you may also file a complaint or report with the Cyberspace Administration, telecommunications authorities, public security bureaus, and industry and commerce regulatory departments.
Appendix: Examples of Personal Information and Sensitive Personal Information (Personal information not collected by Starna Therapeutics' website, official WeChat account, or video account is for illustrative purposes only)
Personal Information: Information recorded electronically or otherwise relating to an identified or identifiable natural person, excluding anonymized information.
Sensitive Personal Information: This refers to personal information that, if leaked or illegally used, could easily infringe upon the personal dignity of an individual or endanger their personal or property safety. This includes biometric information, religious beliefs, specific identity, medical and health information, financial accounts, location tracking, and the personal information of minors under the age of fourteen.
Device Information: This includes device identification codes (IMEI, IDFA, AndroidID, MAC, OAID, IMSI, and other device-related information), application information (application crash information, notification on/off status, application installation list, and other application-related information), device parameters and system information (device type, device model, operating system, and hardware-related information), and device network environment information (IP address, WiFi information, base station information, and other network-related information).