Privacy Policy
2023-02-27
Introduction
Cornerstone Technology (Shenzhen) Limited (hereinafter referred to as “Cornerstone Robotics”, “we”, “our” or “us”) understands the importance of your personal information and thus takes the protection of your privacy and personal information very seriously. Also, we treat the contents of this Privacy Policy with utmost care and diligence. This Privacy Policy is closely related to our products and / or services you use. When you activate, browse, register, login, use or exit our products and / or services (hereinafter collectively referred to as “use our products and / or services” or “use products and / or services”), we will process and protect your personal information in accordance with the terms of this Privacy Policy, and thus we hope you carefully read and fully understand the full text of this Policy and, when necessary, make any choices that you deem appropriate under the guidance of this Policy. In this Privacy Policy, the relevant technical terms are explained to you in as plain and understandable language as possible to facilitate your understanding,
After carefully reading and fully understanding this Privacy Policy, you should choose whether to agree to the contents hereof and whether to agree to use our products and / or services. If you do not agree to the contents, our products and / or services may fail to work normally, the service outcomes may be below the expected level and the protection of personal information may fail to reach your expectation, and in such cases, you should immediately stop accessing / using our products and / or services. Your use or continued use of our products and / or services, or your failure to express objection to us in any express manner prior to your use or continued use of our products and / or services indicates that you fully understand and agree to all the contents of this Privacy Policy (including updated versions).
You should use our products and / or services only after thoroughly reading, clearly understanding the terms hereof and agreeing to the validity of all terms hereof, and you will not claim that the terms herein are illegal or invalid on the grounds that we have not fulfilled our reasonable notification obligations.
If you have any doubts or other concerns while reading this Policy, you may feed back via various channels we provide, and we will answer you as soon as possible. For details, please refer to the section “Contact Us”.
About Us
Cornerstone Technology (Shenzhen) Limited. is a medical technology research and development company focusing on the research and development of robotics in the fields of surgery, rehabilitation, clinical treatment, etc.
Our basic information is as follows: The company was founded on September 27, 2019, with the registered office located at 43A, China Energy Storage Building, No.3099 Keyuan South Road, Yuehai Subdistrict, Nanshan District, Shenzhen City, and the contact of 0755-86726432; if you would like to learn more about our company and platform, please contact us through the contact information provided herein.
This Privacy Policy will familiarize you with the following:
I.Scope of Application and Definitions of Relevant Terms
II.How We Collect and Use Your Personal Information
III.How We Use Cookie and Similar Technologies
IV.How We Share, Transfer and Publicly Disclose Your Personal Information
V.How to Manage Your Personal Information
VI.Retention Period of Personal Information and How We Protect Your Personal Information
VII.Cross-border Data Transmission
VIII.Protection of Minor's Information
IX.Update to This Privacy Policy
X.How to Contact Us
XI.Miscellaneous
I.Scope of Application and Definitions of Relevant Terms
(I)Scope of Application
This Privacy Policy applies uniformly to all products and / or services provided by Cornerstone Robotics. When you use any of our products and / or services, this Policy applies. However, if the product and / or service provides an independent privacy policy, such independent policy shall prevail, while anything uncovered in the independent privacy policy shall be subject to this policy. Please note that this Policy does not apply in the following cases:
1.Information is collected / processed by third parties that provide advertising services for our products and / or services.
2.Our products and / or services may contain or link to information provided by third parties and / or third-party services (including any third-party applications, websites, products, services, etc.) that are operated by third parties. Your use of such information (including any personal information you provide to such third parties) and / or services is subject to the user agreements and privacy policies (rather than this Policy) of such third parties. We would like to kindly remind you that when using third-party information and / or services, you should pay attention to and carefully read the relevant user agreements and privacy policies presented to you by the third parties, and handle your personal information properly and prudently. This Policy applies solely to our collection, storage, use, processing, transmission and disclosure of your personal information and does not apply to the collection of your personal information by any third party, as well as the services provided by any third party or the rules for the use of third-party information. We do not bear any responsibility for the collection, storage and use of your personal information by any third party to the extent permitted by law, and the third party shall be solely responsible for its behaviors of using your information.
3.Products and / or services are provided by others, not us.
(II)Definitions of Relevant Terms
Our products and / services: including but not limited to the software, websites, services (including off-site services, such as our advertising services and plug-ins “applied or shared via our services”) and related products or service feathers provided by us.
We would like to specially remind you that: This Policy is a general privacy policy uniformly applicable to Cornerstone Robotics, and the user rights stipulated herein and the relevant information security measures we provide apply to all our products and services; the types and corresponding usage and processing rules of “our products and / services” described herein as well as your personal information we collect may vary depending on the specific products / services you use (including client types, software versions, etc.), and more specifically, the actual situation of the products / services you actually use. For certain specific products / services, we may also develop specific privacy policies or agreements to provide more specific information about our privacy rules and security measures.
1.Personal information (from GB/T 35273-2020 “Information security technology - Personal information security specification”): refers to all kinds of information recorded electronically or by other means that can identify a specific natural person or reflect the activities of a specific natural person, either from that information alone or from that information combined with other information. The specific types of personal information we actually collect are defined in the following text.
2.Sensitive personal information (from GB/T 35273-2020 “Information security technology - Personal information security specification”): refers to personal information that, once leaked, provided illegally or abused, may endanger personal and property safety and lead to damage to personal reputation and physical and mental health, or discriminatory treatment, etc. The specific types of sensitive personal information we actually collect are defined in the following text. Sensitive personal information may have a greater impact on your personal rights and interests than other personal information. We would like to kindly remind you to think twice before providing us with your sensitive personal information.
3.Authorized consent: refers to your explicit authorization for specific processing of your personal information, including authorization through active action (i.e. express consent) or through passive inaction. (From GB/T 35273-2020 “Information security technology - Personal information security specification”) Please be aware that “Authorized consent” is sometimes referred to as “authorization” or “consent”.
4.User profiling: refers to the process of forming a model of your personal characteristics by collecting, aggregating and analyzing your personal information and then analyzing or predicting your personal characteristics, such as occupation, financial status, education, personal preference, credit records and behavior. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
5.Anonymization: refers to the process that through the technical processing of personal information, the subject of such personal information can not be identified or associated, and the processed information can not be restored. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
6.De-identification: refers to the process of technical processing of personal information so that such information cannot be identified or associated with its subject without the use of additional information. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
7.Deletion: refers to the action of removing personal information from systems performing daily business functions, making it irretrievable and inaccessible. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
II.How We Collect and Use Your Personal Information
When you use our products and / or services, we need / may need to collect and use some of your personal information based on the two types of service. For the first type, i.e. core business functions of our products and / or services, the information we need to collect is necessary for the normal operation of our products and / or services, and you must authorize us to collect it. If you refuse to provide such information, you will not be able to use our products and / or services properly; for the second type, i.e. additional business functions of our products and / or services, the information we may need to collect is required for non-core business functions, and you can choose whether to authorize us to collect it. If you refuse to provide such information, the additional business functions may be unimplementable or fail to realize the designed effects, however, your normal use of core business functions will not be affected.
We would like to remind you that: you understand and agree that since we aim to provide you with perfect products and services, we will keep improving our products, services and technologies, which means that as products and services are iterated, expanded, upgraded, etc., we may introduce new business functions or redivide existing ones, and thus may need to collect new personal information or change the purpose or manner of personal information usage. If a particular function or product / service requiring collection of your personal information is not covered herein, we will separately explain to you the purpose, content, use and scope of the information collection by any one or all of such means as update to this Policy, prompts on startup or browsing interface, pop-ups, website announcements, internal messages, emails and text messages, and offer you the option to provide your own consent, and collect your personal information with your consent. During this process, if you have any doubts or concerns regarding these matters, please contact us through the way provided at the end of the text, and we will give you an answer as soon as possible.
You are required to authorize us to collect and use your personal information for the following functions / scenarios:
(I)Search
When you use the search function, we will automatically collect some of your information, including search words (including voice messages), browsing history and time, search time. We collect such information to provide you with the content you need and services that may be of interest to you, as well as to improve our products and services.
(II)Account registration / login
When you use the account registration function, we will collect some information that you provide to us actively and can be used to identify your real identity alone or in combination with other information, including mobile phone number, verification code matching result, and password created. Your password will be automatically stored, transmitted and verified in encrypted form, and we will never store, transmit and verify your password in plaintext. When you keep, enter or use your password, please carefully assess the physical and electronic environment to prevent password leakage. We collect such information to complete the registration process, provide you with exclusive products and / services for registered users in a sustainable and stable manner and protect the security of your account. You should note that your mobile phone number and verification code matching result are sensitive personal information, the collection of which is to meet the requirements of relevant laws and regulations. If you refuse to provide such information, this function may be unavailable to you. Please consider it prudently before providing such information.
(III)Identity authentication
When you use the identity authentication function or service in our products and / or services, we may collect your real identity information (which may include name, identity document information, mobile phone number, email, (sensitive personal information)) to complete real-name authentication in relevant business scenarios such as purchasing products and / or services, registering products and other services, applying for product-related services and other scenarios where identity authentication is necessary, so as to meet the relevant legal and regulatory requirements, ensure the authenticity of user identity, implement anti-fraud and other risk control measures, protect system and service security, and provide services. To complete real-name authentication, you agree that we may independently or engage a third party to submit, inquire and verify your aforementioned identity information with relevant institutions (such as personal credit agencies and government agencies). After successful real name authentication, you cannot modify your real identity information without valid reasons. If such modification is necessary, please contact us for assistance.
(IV)Obtain or handle information for purchasing products and / or services
When you purchase products and / or services from Cornerstone Robotics, we will collect some or all of the following personal information, including consumer name, contact number, shipping / invoice address, country, nationality, postal code, consumption time, consumption amount, order generated, order number, order status, settlement mode, settlement status, settlement amount and other transaction-related information, to help you smoothly complete service transaction, ensure the security of your service transaction, and provide order inquiry, customer service, etc.
(V)Customer service and other functions that require responses
When you interact with our customer service agent or use other functions that require responses (including submitting feedback online, communicating with online / human customer service agent, making after-sales service requests for our products and / or services, exercising your related personal information control rights, and other customer complaints and needs), we may require you to provide account information first and match it with your previous personal information to verify your user identity. When you use customer service or other functions that require responses, we may also collect the following sensitive personal information: contact information (phone number / email address you use to contact us or other contact information you voluntarily provide to us), your communications with us (including text / picture / audio and video / call record) and other necessary information related to your needs. To ensure a quality service experience and handle after-sales service issues, your communications with the customer service agent may be recorded, and we will access and use these recorded communications as a reference for resolving issues. We collect such information to investigate the facts and help you settle issues. If you refuse to provide such information, you may be unable to use our customer service and other response mechanisms.
(VI)Product security assurance
We need to collect some of your information to assure the security of your account and system when you use our products and / or services, and to help improve the security and reliability of our products and / or services so as to prevent any actions that may harm users, Cornerstone Robotics or the society. Such information includes your personal information like account login location, common device information (hardware model, device MAC address, IMEI, IMSI), login IP address, product version number, language mode, browsing history, network usage habits and service failure information, and sensitive personal information like transaction information. We will, based on the information mentioned above, comprehensively assess risks of your identity, account and transaction, verify your identity, perform customer service, detect and prevent security issues, monitor fraud, archive and backup data, as well as take necessary actions, including recording, audit, analysis and disposal, in accordance with the law. Once we detect or suspect that there is an account security risk, we will use the relevant information for security verification and risk mitigation to ensure the security of the products and services we provide to you, thereby protecting your rights and interests from infringement. At the same time, if there are account or system security issues, we will collect such information to optimize our products and services.
You may provide personal information of your own choice in the following situations:
(I)Your personal information is collected indirectly from external third parties
You understand and agree that we cannot obtain the personal information you provide to external third parties (excluding Cornerstone Robotics’ affiliates) or collected by external third parties, and will not use software programs to obtain your personal information in unconventional ways (such as malicious interference with other party's App data) without proper authorization. If it is necessary for business development to indirectly collect your personal information from a third party (by sharing, etc.), and we provide you with products or services directly or jointly, we (or the third party) will clearly inform you of the source, type, purpose and mode of use of your personal information as well as the business function for which your personal information will be used and the scope of authorization before such collection (where the mode and scope of use are beyond the scope of your original authorization with the third party, we will obtain your authorization again).
(II)You accept to receive marketing and promotional messages
If you opt to receive our marketing and promotional messages, we will collect and use the following personal information about you: email address, Cornerstone Robotics account, interactions with Cornerstone Robotics (such as subscription or unsubscription of marketing and promotional messages, or personal information you provide when participating in our activities). With your above personal information, we may send you relevant messages about Cornerstone Robotics’ products, services, activities and marketing campaigns that you may be interested in through email, SMS and other digital channels like mobile applications and social media. You may withdraw your consent to receive marketing messages at any time through the unsubscribe link at the bottom of the promotional email you may receive or by other means we provide to you. Also, you may contact us as specified in “Contact Us” to withdraw your consent.
(III)Other situations
If a particular function or product / service requiring collection of your personal information is not covered herein, or if we go beyond the stated purpose and the scope related directly or indirectly to the collection of your personal information, we will give you an explanation before collection and use of your personal information by such means as update to this Policy, prompts, pop-ups, messages and notifications, website announcements or in other ways that are convenient for you, offer you the option to provide your own consent, and collect and use your personal information with your express consent. Please be aware that if the information cannot identify or be associated with your identity when used alone or in combination with other information, it does not legally constitute your personal information; if your information can identify your identity when used alone or in combination with other information, and if we use your personal information in combination with any data that cannot be linked to any specific personal information, such data will be treated and protected as your personal information in accordance with this Policy during the period of combined use.
Exceptions
Furthermore, you fully understand and agree that we may collect and use your personal information without your authorization in the following circumstances:
□ Necessary for the performance of statutory duties or obligations;
□ Directly related to national security and national defense security;
□ Necessary to deal with public health emergencies, or to protect the life, health and property safety of natural persons in response to emergencies;
□ Directly related to criminal investigation, prosecution, trial and execution of judgment; or as required by laws and regulations, or by competent authorities such as administrative organs or public security bureaus, procuratorates, people’s courts;
□ Necessary to protect the life, property and other significant legitimate rights and interests of you or other individuals, but difficult to get your consent;
□ The information collected is voluntarily disclosed to the public by yourself or collected from legal public channels (such as legal news reports and government information disclosure);
□ Necessary for the conclusion and performance of relevant agreements or other written documents with you;
□ Necessary to maintain the safe and stable operation of our products and / or services, such as discovering and dealing with faults in our products and / or services;
□ Other circumstances as stipulated by laws and regulations.
III.How We Use Cookie and Similar Technologies
(I)Cookie and similar technologies
Cookie is a small file containing strings that are sent to and stored on your computer, mobile device or other devices (usually encrypted) when you log in and use a website or other online content. Similar technologies to Cookie are other technologies that can be used for purposes similar to Cookie, such as Web Beacon, Proxy, and embedded scripts.
Currently, we collect your personal information with Cookie mainly. You understand and agree that as technology evolves and our products and services further develop, we may also use technologies similar to Cookie.
(II)How We Use Cookie and Similar Technologies
When you use our products and / or services, we may use Cookie and similar technologies to collect some of your personal information, including your habits of visiting the website, browsing information, and login information, to facilitate your use of our products and / or services, simplify your operations (such as registration, login), and allow you to view your usage history (such as viewing task history), as well as provide you with services and content that better suit your needs and interests, protect your information and account security, improve our products and services, etc. We promise to use Cookie and similar technologies only for the purposes specified herein.
If supported by your browser, you may manage, (partially / fully) reject Cookie and similar technologies through your browser settings, or delete Cookie and / or similar technologies that are already stored on your computer, mobile device or other devices, thereby preventing us from tracking all or part of your personal information. For details on how to change your browser settings, please check the relevant setting page of the browser you use. You understand and acknowledge that some of our products and / services can be realized only with Cookie or similar technology, and that if you refuse to use or delete them, you may be unable to use our products and / or services normally or to get the best service experience through our products and / or services, and meanwhile, the protection of your information and your account security will be impacted to some degree.
IV.How We Share, Transfer and Publicly Disclose Your Personal Information
(I)Sharing
Sharing refers to the process in which Cornerstone Robotics provides personal information for other personal information controllers and both parties have independent control over personal information. Under normal circumstances, Cornerstone Robotics will not share your personal information with any companies, organizations or individuals. However, to provide you with better and quality products / services, we may share some of your personal information with third-party partners in accordance with the principles of “legality, minimum necessity and clear purpose”. The details are as below:
1.Sharing with explicit consent: With your explicit consent, Cornerstone Robotics will share information within the scope of your authorization with the third party specified by you;
2.Sharing required for the performance of legal obligations: Cornerstone Robotics may share your personal information with external parties as required by laws and regulations, for the resolution of lawsuits and disputes, or in response to lawful requests from administrative and judicial authorities, and for the performance of other legal obligations;
3.Sharing with Cornerstone Robotics’ affiliates: Your information may be shared with Cornerstone Robotics’ affiliates. We will only share your information with Cornerstone Robotics’s affiliates for specific, clear and legitimate purposes, and we will only share the information necessary to provide services;
4.Sharing with business partners: Cornerstone Robotics may share your order and account information with partners and other third parties to ensure the smooth completion of the services provided to you. However, we will only share your personal information for legitimate, lawful, necessary, specific and clear purposes, and will only share the personal information necessary to provide services. Our partners include:
5.Sharing with commodity suppliers and technical service providers: To ensure your successful payment when you pay for an order at Cornerstone Robotics, Cornerstone Robotics may share your personal information with third parties who support our functions, including those providing us with infrastructure technology service, payment service and data processing service. We need to collect your order information, reconciliation information and other necessary information required by law and share such information with above partners to verify your payment instructions and help you complete the payment.
Cornerstone Robotics will enter into a strict confidentiality agreement with the companies, organizations and individuals with whom personal information is shared, requiring them to process personal information in accordance with this Policy and to take relevant confidentiality and security measures.
(II)Transfer
Transfer refers to the process of transferring the control over personal information from Cornerstone Robotics to another personal information controller. Cornerstone Robotics will not transfer your personal information to any companies, organizations or individuals, except in the following cases:
1.You request the transfer yourself;
2.With your prior express consent, we will transfer your personal information to other parties;
3.Where it involves transfer of personal information for merger, division, dissolution or bankruptcy, we will inform you of the name and contact of the receiver, and require the new company or organization holding your personal information to be bound by this Policy; otherwise, we will ask the company or organization to obtain your authorization again.
4.Other circumstances as stipulated by laws and regulations.
(III)Public disclosure
In principle, Cornerstone Robotics will never disclose your information publicly. If public disclosure is indeed necessary, Cornerstone Robotics will inform you of the purpose of public disclosure, the type of information to be disclosed and the sensitive information that may be involved, and obtain your explicit consent. However, the following exceptions apply:
1.Public disclosure with your express consent;
2.Public disclosure based on law or reasonable grounds: Cornerstone Robotics may publicly disclose your information when required by laws, legal procedures, litigations, or by public and government authorities.
How Cornerstone Robotics protect your personal information
With a high priority on the security of personal information, Cornerstone Robotics adopts industry-standard practices to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss. Therefore, Cornerstone Robotics has taken the following measures:
1.We take all reasonable and feasible measures to minimize the collection of personal information and ensure that personal information unrelated to the accomplishment of the stated purposes is not collected. We retain your personal information only for the period necessary for the purposes described herein, unless retention period is extended or permitted by law;
2.We keep the data transmission and storage confidential with encryption technology. We adopt reliable protection mechanisms to protect data and server where data is stored from malicious attacks.
3.We implement access control mechanisms to ensure that only authorized personnel have access to personal information; to control the number of authorized personnel and manage their permission level based on business needs and personnel levels; and to log the access to personal data, which will be regularly audited by the administrator;
4.We strictly select business partners and service providers,. and implement the requirements on personal information protection into the business contract or audit, assessment and other activities of the two parties;
5.We conduct security and privacy protection trainings, tests and education campaigns to enhance employees’ awareness of the importance of protecting personal information.
In all, Cornerstone Robotics will do its best to protect your personal information. Nevertheless, no measures can be completely foolproof, and this is also no product, service, website, data transmission, computer system or network connection that is absolutely secure.
To control the potential risks such as leakage and loss of and damage to personal information, Cornerstone Robotics has established multiple systems and control measures, defined the classification criteria and corresponding response flow of security incidents and vulnerabilities, and established special web pages for security notification and warning. Besides, Cornerstone Robotics has set up a special emergency response team for security incidents, which activates security plans, carries out stop-loss, analysis and localization, develops remedial measures and works with relevant departments for backtracking and enforcement in response to different security incidents in accordance with the requirements of security incident response standards.
In the event of an unfortunate personal information security incident, Cornerstone Robotics will, according to laws and regulations, inform you of the basic details and possible impacts of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and mitigate risks, remedies for you and so on. We will report to you the incident by such means as email, SMS and push notification; where it is impossible to notify each subject of personal information, we will make an announcement in a reasonable and effective manner. Additionally, we will report the response to personal information security incident to regulatory authorities as required.
(IV)Delegated processing
In order to improve the efficiency of information processing, reduce information processing cost or enhance the accuracy of information processing, we may delegate our competent affiliates or other professional organizations to process user information on our behalf; however, we will require such delegate to comply with strict confidentiality obligations and take effective confidentiality measures, and prohibit such delegate from using the information for unauthorized purposes by written agreements, on-site audits and other means. Upon termination of such delegation, the delegate will no longer retain your personal information.
Exceptions
Please be aware that, according to laws and regulations, we may share, transfer and publicly disclose your personal information without your prior authorization in the following circumstances:
Necessary for the performance of statutory duties or obligations;
Directly related to national security and national defense security;
Necessary to deal with public health emergencies, or to protect the life, health and property safety of natural persons in response to emergencies;
Directly related to criminal investigation, prosecution, trial and execution of judgment; or as required by laws and regulations, or by competent authorities such as administrative organs or public security bureaus, procuratorates, people’s courts;
Necessary to protect the life, property and other significant legitimate rights and interests of you or other individuals, but difficult to get your consent;
The information collected is voluntarily disclosed to the public by yourself or collected by us from legal public channels (such as legal news reports, government information disclosure);
Necessary for the conclusion and performance of relevant agreements or other written documents with you;
Other circumstances as stipulated by laws and regulations.
(V)Responsibilities or liabilities related to sharing, transfer and public disclosure
We will, in strict accordance with provisions herein as well as relevant laws and regulations, carry out sharing, transfer and public disclosure of your personal information; for damages to your legitimate rights and interests due to our fault, we are willing to bear the corresponding liability for damages to you within the scope prescribed by law. If we share, transfer or publicly disclose your personal information with a third party in breach of laws and regulations or our agreement with you, you are entitled to request us to delete it, and we will immediately stop such sharing, transfer or public disclosure upon receipt of your request, and notify the third party to delete it in a timely manner.
V.How to Manage Your Personal Information
We understand your concern about your personal information, and we make every effort to ensure your rights to access, correct and delete your personal information and to withdraw your consent, so that you have the full capacity to protect your privacy and security. Your rights include:
(I)Access, correction, deletion and copy acquisition
You are encouraged to update and modify your information to make it more accurate and effective. You may contact us to access or inquire about your information through the customer service on our website, and upon receipt of your application and completion of account verification (we need you to provide your account, password, registered mobile phone number, text verification code and other information to verify your identity as the account owner), we will assist you in modifying, supplementing and deleting information. We will take proper technical measures to, as possible as we can, ensure that you can access, update and correct your own information or other information provided when using our services. You may contact us by the contact person and email provided herein to obtain a copy of your personal information. If you have troubles during your access or need to obtain other personal information that is not available above, please contact us through the means provided in this Policy.
(II)Change of the scope of your authorized consent
As mentioned above, some features of our products and services require your authorization. You may withdraw (or stop) the continued authorization for permissions at any time. Some information is necessary for using our services, and we are unable to unilaterally withdraw the authorization to disclose necessary information, but the provision of most of other information is at your discretion. You may contact us to change the scope of your authorization for our continued collection of information, or withdraw your continued authorization.
You should understand that upon your withdrawal of authorization, we will no longer provide you with the service corresponding to the withdrawn authorization, and no longer process the corresponding information. However, your withdrawal of authorization will not affect the previous information processing that was conducted based on you authorization.
(III)Deregistration of your account
You may apply to deregister your account through our customer service or by other manners publicly disclosed by us. After deregistration of your account, you will no longer be able to log in and use our products and services with this account; the content, information, data and records under the account will be deleted or anonymized (except as otherwise provided by laws and regulations or otherwise required by the regulatory authorities; for example, your network operation log will be retained for at least six months according to the provisions of the Cybersecurity Law of the People's Republic of China); the account cannot be restored once deregistered.
(IV)Notice regarding sensitive information
Certain information may be considered sensitive due to its unique nature, such as your race, religious belief, personal health and medical information, as well as identification documents, personal biometric information, property information, and transaction information.
Please note that the content and information you provide when enjoying our services (such as photos or information about your identity) may disclose your sensitive information. Please carefully consider whether to disclose your sensitive information when using our services.
You agree that your sensitive information will be processed for the purposes and in the manner described herein.
Exceptions
Please understand and acknowledge that, according to laws and regulations, we may not respond to your requests for rights of inquiry, correction / modification, deletion, withdrawal of consent, deregistration, copy acquisition, etc. in the following circumstances:
□ Directly related to national security and national defense security;
□ Directly related to public safety, public health and major public interests;
□ Directly related to criminal investigation, prosecution, trial and enforcement of judgment, etc.;
□ With sufficient evidence to indicate your subjective malicious or abuse of rights;
□ Resulting to serious damages to the legitimate rights and interests of other individuals or organizations due to response to your request;
□ Involving trade secrets;
□ Other circumstances as stipulated by laws and regulations.
VI.Retention Period of Personal Information and How We Protect Your Personal Information
(I)Retention period of personal information
We will retain your personal information only for the period necessary for the purposes described herein, unless as required by legitimate business or as otherwise permitted or required by laws and regulations; for example, according to the E-commerce Law of the People’s Republic of China, the information about goods, services and transactions should be retained for at least three years from the date of completion of transaction. After the retention period has expired, we will delete or anonymize your personal information as required by applicable law.
We determine the retention period of personal information based primarily on the following criteria:
1.The completion of transaction purposes related to you, maintenance of relevant transaction and business records, and response to your possible inquiries or complaints;
2.The assurance of security and quality of services we provide to you;
3.Your consent to a longer retention period;
4.The existence of other special agreements or laws and regulations regarding retention period.
(II)We will take security measures in line with industry standards to protect the personal information you provide from unauthorized access, disclosure, use, modification, data damage or loss. We will take all reasonably feasible measures to protect your personal information. For example, we adopt SSL to encrypt and protect data (such as credit card information) exchanged between your browser and the “Service”; we use encryption technology to ensure data confidentiality; we employ reliable protection mechanisms to prevent data from malicious attacks; and we implement access control mechanisms to ensure that only authorized personnel can access personal information.
(III)We will take all reasonably feasible measures to ensure that no irrelevant personal information is collected. We will retain your personal information only for the period necessary for the purposes described herein, unless retention period is extended or permitted by law.
(IV)The Internet is never an absolutely secure environment, and user's communications via email, instant message and other means are not encrypted. Thus we strongly recommend you do not send personal information through such means. Please use a complex password to further protect your account.
(V)The Internet environment is not completely safe, and we will do our best to ensure or guarantee the security of any information you send to us. For the damages to your legitimate rights and interests caused by unauthorized access, public disclosure, alternation or damage to information due to our destroyed physical, technical or administrative protection facilities, we will bear corresponding legal responsibilities.
(VI)Response to security incident
In the event of an unfortunate personal information security incident, we will, according to laws and regulations, timely inform you of the basic details and possible impacts of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and mitigate risks, remedies for you and so on. We will report to you the incident without delay by such means as email, telephone and push notification; where it is impossible to notify each subject of personal information, we will make an announcement in a reasonable and effective manner.
Please understand that due to restrictions on technologies and risk control, though we have tried our best to enhance security measures, we cannot guarantee the absolute security of information at all times. You should understand that the system and communication network you use to access our services may fail due to situations beyond our control.
VII.Cross-border Data Transmission
Cornerstone Robotics is a company headquartered in China, with affiliates, business partners or suppliers located in different countries and regions around the world. Your personal information may be transmitted to our affiliates, business partners or service providers located outside your country so that they can assist us in processing your personal information for purposes stated herein. The rules for personal information protection in these countries and regions may differ from those in your country. In this case, we will transmit personal information only for the purposes stated herein. To the extent required by applicable law, we will take proper measures to protect your personal information when transmitting such information to these receiving parties in other countries.
VIII.Protection of Minor's Information
1.We highly value the protection of minor’s information. Minors should obtain consent from their guardians before using our products / services. If you are a minor, you should read this Policy under the guardianship and guidance of your guardian, and use our products / services and submit your personal information with the guardian's express consent and guidance. In cases where personal information of a minor is collected with the consent of a parent or legal guardian, we will only use or publicly disclose this information as permitted by law, with the express consent of the parent or guardian or as necessary to protect the minor.
2.If we discover that we have collected the personal information of a minor without the prior consent of the verifiable parent or legal guardian, we will make efforts to delete the relevant data as soon as possible.
IX.Update to This Privacy Policy
You are encouraged to review our Privacy Policy every time you use our products or services. In order to provide you with better service, we will update the provisions of this Privacy Policy based on product updates and relevant laws and regulations, which constitute an integral part hereof. If these updates result in substantial reduction or significant changes of your rights hereunder, we will notify you by prominent notifications, push messages or other means before they take effect; your continued use of our services indicates that you have thoroughly read, understood and agreed to be bound by the revised Privacy Policy. To safeguard your legitimate rights and interests, we encourage you to regularly check this Policy on the settings page of our platform.
The “significant changes” above include, but are not limited to:
1.Significant changes in our service model, such as the purposes of personal information processing, types of personal information processed, and the way in which the personal information is used;
2.Significant changes in our ownership structure, organizational structure and so on, including change of owner caused by business adjustment, bankruptcy, and merger and acquisition, etc.
3.Changes in main objects of personal information sharing, transfer or public disclosure;
4.Significant changes in your rights to participate in personal information processing and in how you exercise these rights;
5.Changes in the department responsible for personal information security, contact information and complaint channels;
6.A high risk as indicated by the personal information security impact assessment report;
7.Occurrence of other circumstances that are important or may affect your personal rights and interests seriously.
X.How to Contact Us
(I)For any doubts or concerns (including inquiries and complaints) regarding the implementation hereof or the privacy-related matters that you encounter when using our services, we have developed various feedback channels to provide you with a satisfactory solution:
1.Online feedback channel: you may submit feedback through the online feedback channel provided in “Contact Us”;
2.Human customer service channel: you may call any of our customer service hotlines to contact us;
3.Special email channel: to better protect your rights and interests, we have set up a special email address info@csrbtx.com, through which you can contact us.
(II)Upon receipt of your comments or suggestions, we will respond to you as soon as possible, generally within 15 working days after verification of your user identity or within the period specified by applicable laws and regulations, and we will not charge you for such service in general. However, you understand and acknowledge that we will not respond to your requests in the following situations:
1.Directly related to national security and national defense security;
2.Directly related to public safety, public health and major public interests;
3.Related to criminal investigation, prosecution, trial, etc.;
4.With sufficient evidence to indicate your subjective malicious or abuse of rights;
5.Necessary to protect the life, property and other significant rights and interests of you or other individuals, but difficult to get consent from you or such individual;
6.Resulting to serious damages to the legitimate rights and interests of you or other individuals or organizations due to response to your request;
7.Involving trade secrets;
8.Other circumstances as stipulated by laws and regulations.
(III)If you are unsatisfied with our response, or if we refuse to make improvements after your feedback that our processing of your personal information has infringed your legitimate rights and interests, you are entitled to file a complaint or report to regulatory authorities such as administration for industry and commerce, public security bureau.
XI.Miscellaneous
(I)The interpretation and dispute resolution of this Policy shall be governed by the laws of the mainland of the People's Republic of China. In the event of any dispute arising out of the execution and performance hereof, the two parties shall try to solve it through amicable negotiation; if such negotiation fails, either party may bring a suit to the people's court with jurisdiction in the place where Cornerstone Robotics is located.
(II)The headings used herein are provided for convenience and reading only, and do not affect the meaning or interpretation of any provisions in the text.
Cornerstone Technology (Shenzhen) Limited (hereinafter referred to as “Cornerstone Robotics”, “we”, “our” or “us”) understands the importance of your personal information and thus takes the protection of your privacy and personal information very seriously. Also, we treat the contents of this Privacy Policy with utmost care and diligence. This Privacy Policy is closely related to our products and / or services you use. When you activate, browse, register, login, use or exit our products and / or services (hereinafter collectively referred to as “use our products and / or services” or “use products and / or services”), we will process and protect your personal information in accordance with the terms of this Privacy Policy, and thus we hope you carefully read and fully understand the full text of this Policy and, when necessary, make any choices that you deem appropriate under the guidance of this Policy. In this Privacy Policy, the relevant technical terms are explained to you in as plain and understandable language as possible to facilitate your understanding,
After carefully reading and fully understanding this Privacy Policy, you should choose whether to agree to the contents hereof and whether to agree to use our products and / or services. If you do not agree to the contents, our products and / or services may fail to work normally, the service outcomes may be below the expected level and the protection of personal information may fail to reach your expectation, and in such cases, you should immediately stop accessing / using our products and / or services. Your use or continued use of our products and / or services, or your failure to express objection to us in any express manner prior to your use or continued use of our products and / or services indicates that you fully understand and agree to all the contents of this Privacy Policy (including updated versions).
You should use our products and / or services only after thoroughly reading, clearly understanding the terms hereof and agreeing to the validity of all terms hereof, and you will not claim that the terms herein are illegal or invalid on the grounds that we have not fulfilled our reasonable notification obligations.
If you have any doubts or other concerns while reading this Policy, you may feed back via various channels we provide, and we will answer you as soon as possible. For details, please refer to the section “Contact Us”.
About Us
Cornerstone Technology (Shenzhen) Limited. is a medical technology research and development company focusing on the research and development of robotics in the fields of surgery, rehabilitation, clinical treatment, etc.
Our basic information is as follows: The company was founded on September 27, 2019, with the registered office located at 43A, China Energy Storage Building, No.3099 Keyuan South Road, Yuehai Subdistrict, Nanshan District, Shenzhen City, and the contact of 0755-86726432; if you would like to learn more about our company and platform, please contact us through the contact information provided herein.
This Privacy Policy will familiarize you with the following:
I.Scope of Application and Definitions of Relevant Terms
II.How We Collect and Use Your Personal Information
III.How We Use Cookie and Similar Technologies
IV.How We Share, Transfer and Publicly Disclose Your Personal Information
V.How to Manage Your Personal Information
VI.Retention Period of Personal Information and How We Protect Your Personal Information
VII.Cross-border Data Transmission
VIII.Protection of Minor's Information
IX.Update to This Privacy Policy
X.How to Contact Us
XI.Miscellaneous
I.Scope of Application and Definitions of Relevant Terms
(I)Scope of Application
This Privacy Policy applies uniformly to all products and / or services provided by Cornerstone Robotics. When you use any of our products and / or services, this Policy applies. However, if the product and / or service provides an independent privacy policy, such independent policy shall prevail, while anything uncovered in the independent privacy policy shall be subject to this policy. Please note that this Policy does not apply in the following cases:
1.Information is collected / processed by third parties that provide advertising services for our products and / or services.
2.Our products and / or services may contain or link to information provided by third parties and / or third-party services (including any third-party applications, websites, products, services, etc.) that are operated by third parties. Your use of such information (including any personal information you provide to such third parties) and / or services is subject to the user agreements and privacy policies (rather than this Policy) of such third parties. We would like to kindly remind you that when using third-party information and / or services, you should pay attention to and carefully read the relevant user agreements and privacy policies presented to you by the third parties, and handle your personal information properly and prudently. This Policy applies solely to our collection, storage, use, processing, transmission and disclosure of your personal information and does not apply to the collection of your personal information by any third party, as well as the services provided by any third party or the rules for the use of third-party information. We do not bear any responsibility for the collection, storage and use of your personal information by any third party to the extent permitted by law, and the third party shall be solely responsible for its behaviors of using your information.
3.Products and / or services are provided by others, not us.
(II)Definitions of Relevant Terms
Our products and / services: including but not limited to the software, websites, services (including off-site services, such as our advertising services and plug-ins “applied or shared via our services”) and related products or service feathers provided by us.
We would like to specially remind you that: This Policy is a general privacy policy uniformly applicable to Cornerstone Robotics, and the user rights stipulated herein and the relevant information security measures we provide apply to all our products and services; the types and corresponding usage and processing rules of “our products and / services” described herein as well as your personal information we collect may vary depending on the specific products / services you use (including client types, software versions, etc.), and more specifically, the actual situation of the products / services you actually use. For certain specific products / services, we may also develop specific privacy policies or agreements to provide more specific information about our privacy rules and security measures.
1.Personal information (from GB/T 35273-2020 “Information security technology - Personal information security specification”): refers to all kinds of information recorded electronically or by other means that can identify a specific natural person or reflect the activities of a specific natural person, either from that information alone or from that information combined with other information. The specific types of personal information we actually collect are defined in the following text.
2.Sensitive personal information (from GB/T 35273-2020 “Information security technology - Personal information security specification”): refers to personal information that, once leaked, provided illegally or abused, may endanger personal and property safety and lead to damage to personal reputation and physical and mental health, or discriminatory treatment, etc. The specific types of sensitive personal information we actually collect are defined in the following text. Sensitive personal information may have a greater impact on your personal rights and interests than other personal information. We would like to kindly remind you to think twice before providing us with your sensitive personal information.
3.Authorized consent: refers to your explicit authorization for specific processing of your personal information, including authorization through active action (i.e. express consent) or through passive inaction. (From GB/T 35273-2020 “Information security technology - Personal information security specification”) Please be aware that “Authorized consent” is sometimes referred to as “authorization” or “consent”.
4.User profiling: refers to the process of forming a model of your personal characteristics by collecting, aggregating and analyzing your personal information and then analyzing or predicting your personal characteristics, such as occupation, financial status, education, personal preference, credit records and behavior. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
5.Anonymization: refers to the process that through the technical processing of personal information, the subject of such personal information can not be identified or associated, and the processed information can not be restored. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
6.De-identification: refers to the process of technical processing of personal information so that such information cannot be identified or associated with its subject without the use of additional information. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
7.Deletion: refers to the action of removing personal information from systems performing daily business functions, making it irretrievable and inaccessible. (From GB/T 35273-2020 “Information security technology - Personal information security specification”)
II.How We Collect and Use Your Personal Information
When you use our products and / or services, we need / may need to collect and use some of your personal information based on the two types of service. For the first type, i.e. core business functions of our products and / or services, the information we need to collect is necessary for the normal operation of our products and / or services, and you must authorize us to collect it. If you refuse to provide such information, you will not be able to use our products and / or services properly; for the second type, i.e. additional business functions of our products and / or services, the information we may need to collect is required for non-core business functions, and you can choose whether to authorize us to collect it. If you refuse to provide such information, the additional business functions may be unimplementable or fail to realize the designed effects, however, your normal use of core business functions will not be affected.
We would like to remind you that: you understand and agree that since we aim to provide you with perfect products and services, we will keep improving our products, services and technologies, which means that as products and services are iterated, expanded, upgraded, etc., we may introduce new business functions or redivide existing ones, and thus may need to collect new personal information or change the purpose or manner of personal information usage. If a particular function or product / service requiring collection of your personal information is not covered herein, we will separately explain to you the purpose, content, use and scope of the information collection by any one or all of such means as update to this Policy, prompts on startup or browsing interface, pop-ups, website announcements, internal messages, emails and text messages, and offer you the option to provide your own consent, and collect your personal information with your consent. During this process, if you have any doubts or concerns regarding these matters, please contact us through the way provided at the end of the text, and we will give you an answer as soon as possible.
You are required to authorize us to collect and use your personal information for the following functions / scenarios:
(I)Search
When you use the search function, we will automatically collect some of your information, including search words (including voice messages), browsing history and time, search time. We collect such information to provide you with the content you need and services that may be of interest to you, as well as to improve our products and services.
(II)Account registration / login
When you use the account registration function, we will collect some information that you provide to us actively and can be used to identify your real identity alone or in combination with other information, including mobile phone number, verification code matching result, and password created. Your password will be automatically stored, transmitted and verified in encrypted form, and we will never store, transmit and verify your password in plaintext. When you keep, enter or use your password, please carefully assess the physical and electronic environment to prevent password leakage. We collect such information to complete the registration process, provide you with exclusive products and / services for registered users in a sustainable and stable manner and protect the security of your account. You should note that your mobile phone number and verification code matching result are sensitive personal information, the collection of which is to meet the requirements of relevant laws and regulations. If you refuse to provide such information, this function may be unavailable to you. Please consider it prudently before providing such information.
(III)Identity authentication
When you use the identity authentication function or service in our products and / or services, we may collect your real identity information (which may include name, identity document information, mobile phone number, email, (sensitive personal information)) to complete real-name authentication in relevant business scenarios such as purchasing products and / or services, registering products and other services, applying for product-related services and other scenarios where identity authentication is necessary, so as to meet the relevant legal and regulatory requirements, ensure the authenticity of user identity, implement anti-fraud and other risk control measures, protect system and service security, and provide services. To complete real-name authentication, you agree that we may independently or engage a third party to submit, inquire and verify your aforementioned identity information with relevant institutions (such as personal credit agencies and government agencies). After successful real name authentication, you cannot modify your real identity information without valid reasons. If such modification is necessary, please contact us for assistance.
(IV)Obtain or handle information for purchasing products and / or services
When you purchase products and / or services from Cornerstone Robotics, we will collect some or all of the following personal information, including consumer name, contact number, shipping / invoice address, country, nationality, postal code, consumption time, consumption amount, order generated, order number, order status, settlement mode, settlement status, settlement amount and other transaction-related information, to help you smoothly complete service transaction, ensure the security of your service transaction, and provide order inquiry, customer service, etc.
(V)Customer service and other functions that require responses
When you interact with our customer service agent or use other functions that require responses (including submitting feedback online, communicating with online / human customer service agent, making after-sales service requests for our products and / or services, exercising your related personal information control rights, and other customer complaints and needs), we may require you to provide account information first and match it with your previous personal information to verify your user identity. When you use customer service or other functions that require responses, we may also collect the following sensitive personal information: contact information (phone number / email address you use to contact us or other contact information you voluntarily provide to us), your communications with us (including text / picture / audio and video / call record) and other necessary information related to your needs. To ensure a quality service experience and handle after-sales service issues, your communications with the customer service agent may be recorded, and we will access and use these recorded communications as a reference for resolving issues. We collect such information to investigate the facts and help you settle issues. If you refuse to provide such information, you may be unable to use our customer service and other response mechanisms.
(VI)Product security assurance
We need to collect some of your information to assure the security of your account and system when you use our products and / or services, and to help improve the security and reliability of our products and / or services so as to prevent any actions that may harm users, Cornerstone Robotics or the society. Such information includes your personal information like account login location, common device information (hardware model, device MAC address, IMEI, IMSI), login IP address, product version number, language mode, browsing history, network usage habits and service failure information, and sensitive personal information like transaction information. We will, based on the information mentioned above, comprehensively assess risks of your identity, account and transaction, verify your identity, perform customer service, detect and prevent security issues, monitor fraud, archive and backup data, as well as take necessary actions, including recording, audit, analysis and disposal, in accordance with the law. Once we detect or suspect that there is an account security risk, we will use the relevant information for security verification and risk mitigation to ensure the security of the products and services we provide to you, thereby protecting your rights and interests from infringement. At the same time, if there are account or system security issues, we will collect such information to optimize our products and services.
You may provide personal information of your own choice in the following situations:
(I)Your personal information is collected indirectly from external third parties
You understand and agree that we cannot obtain the personal information you provide to external third parties (excluding Cornerstone Robotics’ affiliates) or collected by external third parties, and will not use software programs to obtain your personal information in unconventional ways (such as malicious interference with other party's App data) without proper authorization. If it is necessary for business development to indirectly collect your personal information from a third party (by sharing, etc.), and we provide you with products or services directly or jointly, we (or the third party) will clearly inform you of the source, type, purpose and mode of use of your personal information as well as the business function for which your personal information will be used and the scope of authorization before such collection (where the mode and scope of use are beyond the scope of your original authorization with the third party, we will obtain your authorization again).
(II)You accept to receive marketing and promotional messages
If you opt to receive our marketing and promotional messages, we will collect and use the following personal information about you: email address, Cornerstone Robotics account, interactions with Cornerstone Robotics (such as subscription or unsubscription of marketing and promotional messages, or personal information you provide when participating in our activities). With your above personal information, we may send you relevant messages about Cornerstone Robotics’ products, services, activities and marketing campaigns that you may be interested in through email, SMS and other digital channels like mobile applications and social media. You may withdraw your consent to receive marketing messages at any time through the unsubscribe link at the bottom of the promotional email you may receive or by other means we provide to you. Also, you may contact us as specified in “Contact Us” to withdraw your consent.
(III)Other situations
If a particular function or product / service requiring collection of your personal information is not covered herein, or if we go beyond the stated purpose and the scope related directly or indirectly to the collection of your personal information, we will give you an explanation before collection and use of your personal information by such means as update to this Policy, prompts, pop-ups, messages and notifications, website announcements or in other ways that are convenient for you, offer you the option to provide your own consent, and collect and use your personal information with your express consent. Please be aware that if the information cannot identify or be associated with your identity when used alone or in combination with other information, it does not legally constitute your personal information; if your information can identify your identity when used alone or in combination with other information, and if we use your personal information in combination with any data that cannot be linked to any specific personal information, such data will be treated and protected as your personal information in accordance with this Policy during the period of combined use.
Exceptions
Furthermore, you fully understand and agree that we may collect and use your personal information without your authorization in the following circumstances:
□ Necessary for the performance of statutory duties or obligations;
□ Directly related to national security and national defense security;
□ Necessary to deal with public health emergencies, or to protect the life, health and property safety of natural persons in response to emergencies;
□ Directly related to criminal investigation, prosecution, trial and execution of judgment; or as required by laws and regulations, or by competent authorities such as administrative organs or public security bureaus, procuratorates, people’s courts;
□ Necessary to protect the life, property and other significant legitimate rights and interests of you or other individuals, but difficult to get your consent;
□ The information collected is voluntarily disclosed to the public by yourself or collected from legal public channels (such as legal news reports and government information disclosure);
□ Necessary for the conclusion and performance of relevant agreements or other written documents with you;
□ Necessary to maintain the safe and stable operation of our products and / or services, such as discovering and dealing with faults in our products and / or services;
□ Other circumstances as stipulated by laws and regulations.
III.How We Use Cookie and Similar Technologies
(I)Cookie and similar technologies
Cookie is a small file containing strings that are sent to and stored on your computer, mobile device or other devices (usually encrypted) when you log in and use a website or other online content. Similar technologies to Cookie are other technologies that can be used for purposes similar to Cookie, such as Web Beacon, Proxy, and embedded scripts.
Currently, we collect your personal information with Cookie mainly. You understand and agree that as technology evolves and our products and services further develop, we may also use technologies similar to Cookie.
(II)How We Use Cookie and Similar Technologies
When you use our products and / or services, we may use Cookie and similar technologies to collect some of your personal information, including your habits of visiting the website, browsing information, and login information, to facilitate your use of our products and / or services, simplify your operations (such as registration, login), and allow you to view your usage history (such as viewing task history), as well as provide you with services and content that better suit your needs and interests, protect your information and account security, improve our products and services, etc. We promise to use Cookie and similar technologies only for the purposes specified herein.
If supported by your browser, you may manage, (partially / fully) reject Cookie and similar technologies through your browser settings, or delete Cookie and / or similar technologies that are already stored on your computer, mobile device or other devices, thereby preventing us from tracking all or part of your personal information. For details on how to change your browser settings, please check the relevant setting page of the browser you use. You understand and acknowledge that some of our products and / services can be realized only with Cookie or similar technology, and that if you refuse to use or delete them, you may be unable to use our products and / or services normally or to get the best service experience through our products and / or services, and meanwhile, the protection of your information and your account security will be impacted to some degree.
IV.How We Share, Transfer and Publicly Disclose Your Personal Information
(I)Sharing
Sharing refers to the process in which Cornerstone Robotics provides personal information for other personal information controllers and both parties have independent control over personal information. Under normal circumstances, Cornerstone Robotics will not share your personal information with any companies, organizations or individuals. However, to provide you with better and quality products / services, we may share some of your personal information with third-party partners in accordance with the principles of “legality, minimum necessity and clear purpose”. The details are as below:
1.Sharing with explicit consent: With your explicit consent, Cornerstone Robotics will share information within the scope of your authorization with the third party specified by you;
2.Sharing required for the performance of legal obligations: Cornerstone Robotics may share your personal information with external parties as required by laws and regulations, for the resolution of lawsuits and disputes, or in response to lawful requests from administrative and judicial authorities, and for the performance of other legal obligations;
3.Sharing with Cornerstone Robotics’ affiliates: Your information may be shared with Cornerstone Robotics’ affiliates. We will only share your information with Cornerstone Robotics’s affiliates for specific, clear and legitimate purposes, and we will only share the information necessary to provide services;
4.Sharing with business partners: Cornerstone Robotics may share your order and account information with partners and other third parties to ensure the smooth completion of the services provided to you. However, we will only share your personal information for legitimate, lawful, necessary, specific and clear purposes, and will only share the personal information necessary to provide services. Our partners include:
5.Sharing with commodity suppliers and technical service providers: To ensure your successful payment when you pay for an order at Cornerstone Robotics, Cornerstone Robotics may share your personal information with third parties who support our functions, including those providing us with infrastructure technology service, payment service and data processing service. We need to collect your order information, reconciliation information and other necessary information required by law and share such information with above partners to verify your payment instructions and help you complete the payment.
Cornerstone Robotics will enter into a strict confidentiality agreement with the companies, organizations and individuals with whom personal information is shared, requiring them to process personal information in accordance with this Policy and to take relevant confidentiality and security measures.
(II)Transfer
Transfer refers to the process of transferring the control over personal information from Cornerstone Robotics to another personal information controller. Cornerstone Robotics will not transfer your personal information to any companies, organizations or individuals, except in the following cases:
1.You request the transfer yourself;
2.With your prior express consent, we will transfer your personal information to other parties;
3.Where it involves transfer of personal information for merger, division, dissolution or bankruptcy, we will inform you of the name and contact of the receiver, and require the new company or organization holding your personal information to be bound by this Policy; otherwise, we will ask the company or organization to obtain your authorization again.
4.Other circumstances as stipulated by laws and regulations.
(III)Public disclosure
In principle, Cornerstone Robotics will never disclose your information publicly. If public disclosure is indeed necessary, Cornerstone Robotics will inform you of the purpose of public disclosure, the type of information to be disclosed and the sensitive information that may be involved, and obtain your explicit consent. However, the following exceptions apply:
1.Public disclosure with your express consent;
2.Public disclosure based on law or reasonable grounds: Cornerstone Robotics may publicly disclose your information when required by laws, legal procedures, litigations, or by public and government authorities.
How Cornerstone Robotics protect your personal information
With a high priority on the security of personal information, Cornerstone Robotics adopts industry-standard practices to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss. Therefore, Cornerstone Robotics has taken the following measures:
1.We take all reasonable and feasible measures to minimize the collection of personal information and ensure that personal information unrelated to the accomplishment of the stated purposes is not collected. We retain your personal information only for the period necessary for the purposes described herein, unless retention period is extended or permitted by law;
2.We keep the data transmission and storage confidential with encryption technology. We adopt reliable protection mechanisms to protect data and server where data is stored from malicious attacks.
3.We implement access control mechanisms to ensure that only authorized personnel have access to personal information; to control the number of authorized personnel and manage their permission level based on business needs and personnel levels; and to log the access to personal data, which will be regularly audited by the administrator;
4.We strictly select business partners and service providers,. and implement the requirements on personal information protection into the business contract or audit, assessment and other activities of the two parties;
5.We conduct security and privacy protection trainings, tests and education campaigns to enhance employees’ awareness of the importance of protecting personal information.
In all, Cornerstone Robotics will do its best to protect your personal information. Nevertheless, no measures can be completely foolproof, and this is also no product, service, website, data transmission, computer system or network connection that is absolutely secure.
To control the potential risks such as leakage and loss of and damage to personal information, Cornerstone Robotics has established multiple systems and control measures, defined the classification criteria and corresponding response flow of security incidents and vulnerabilities, and established special web pages for security notification and warning. Besides, Cornerstone Robotics has set up a special emergency response team for security incidents, which activates security plans, carries out stop-loss, analysis and localization, develops remedial measures and works with relevant departments for backtracking and enforcement in response to different security incidents in accordance with the requirements of security incident response standards.
In the event of an unfortunate personal information security incident, Cornerstone Robotics will, according to laws and regulations, inform you of the basic details and possible impacts of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and mitigate risks, remedies for you and so on. We will report to you the incident by such means as email, SMS and push notification; where it is impossible to notify each subject of personal information, we will make an announcement in a reasonable and effective manner. Additionally, we will report the response to personal information security incident to regulatory authorities as required.
(IV)Delegated processing
In order to improve the efficiency of information processing, reduce information processing cost or enhance the accuracy of information processing, we may delegate our competent affiliates or other professional organizations to process user information on our behalf; however, we will require such delegate to comply with strict confidentiality obligations and take effective confidentiality measures, and prohibit such delegate from using the information for unauthorized purposes by written agreements, on-site audits and other means. Upon termination of such delegation, the delegate will no longer retain your personal information.
Exceptions
Please be aware that, according to laws and regulations, we may share, transfer and publicly disclose your personal information without your prior authorization in the following circumstances:
Necessary for the performance of statutory duties or obligations;
Directly related to national security and national defense security;
Necessary to deal with public health emergencies, or to protect the life, health and property safety of natural persons in response to emergencies;
Directly related to criminal investigation, prosecution, trial and execution of judgment; or as required by laws and regulations, or by competent authorities such as administrative organs or public security bureaus, procuratorates, people’s courts;
Necessary to protect the life, property and other significant legitimate rights and interests of you or other individuals, but difficult to get your consent;
The information collected is voluntarily disclosed to the public by yourself or collected by us from legal public channels (such as legal news reports, government information disclosure);
Necessary for the conclusion and performance of relevant agreements or other written documents with you;
Other circumstances as stipulated by laws and regulations.
(V)Responsibilities or liabilities related to sharing, transfer and public disclosure
We will, in strict accordance with provisions herein as well as relevant laws and regulations, carry out sharing, transfer and public disclosure of your personal information; for damages to your legitimate rights and interests due to our fault, we are willing to bear the corresponding liability for damages to you within the scope prescribed by law. If we share, transfer or publicly disclose your personal information with a third party in breach of laws and regulations or our agreement with you, you are entitled to request us to delete it, and we will immediately stop such sharing, transfer or public disclosure upon receipt of your request, and notify the third party to delete it in a timely manner.
V.How to Manage Your Personal Information
We understand your concern about your personal information, and we make every effort to ensure your rights to access, correct and delete your personal information and to withdraw your consent, so that you have the full capacity to protect your privacy and security. Your rights include:
(I)Access, correction, deletion and copy acquisition
You are encouraged to update and modify your information to make it more accurate and effective. You may contact us to access or inquire about your information through the customer service on our website, and upon receipt of your application and completion of account verification (we need you to provide your account, password, registered mobile phone number, text verification code and other information to verify your identity as the account owner), we will assist you in modifying, supplementing and deleting information. We will take proper technical measures to, as possible as we can, ensure that you can access, update and correct your own information or other information provided when using our services. You may contact us by the contact person and email provided herein to obtain a copy of your personal information. If you have troubles during your access or need to obtain other personal information that is not available above, please contact us through the means provided in this Policy.
(II)Change of the scope of your authorized consent
As mentioned above, some features of our products and services require your authorization. You may withdraw (or stop) the continued authorization for permissions at any time. Some information is necessary for using our services, and we are unable to unilaterally withdraw the authorization to disclose necessary information, but the provision of most of other information is at your discretion. You may contact us to change the scope of your authorization for our continued collection of information, or withdraw your continued authorization.
You should understand that upon your withdrawal of authorization, we will no longer provide you with the service corresponding to the withdrawn authorization, and no longer process the corresponding information. However, your withdrawal of authorization will not affect the previous information processing that was conducted based on you authorization.
(III)Deregistration of your account
You may apply to deregister your account through our customer service or by other manners publicly disclosed by us. After deregistration of your account, you will no longer be able to log in and use our products and services with this account; the content, information, data and records under the account will be deleted or anonymized (except as otherwise provided by laws and regulations or otherwise required by the regulatory authorities; for example, your network operation log will be retained for at least six months according to the provisions of the Cybersecurity Law of the People's Republic of China); the account cannot be restored once deregistered.
(IV)Notice regarding sensitive information
Certain information may be considered sensitive due to its unique nature, such as your race, religious belief, personal health and medical information, as well as identification documents, personal biometric information, property information, and transaction information.
Please note that the content and information you provide when enjoying our services (such as photos or information about your identity) may disclose your sensitive information. Please carefully consider whether to disclose your sensitive information when using our services.
You agree that your sensitive information will be processed for the purposes and in the manner described herein.
Exceptions
Please understand and acknowledge that, according to laws and regulations, we may not respond to your requests for rights of inquiry, correction / modification, deletion, withdrawal of consent, deregistration, copy acquisition, etc. in the following circumstances:
□ Directly related to national security and national defense security;
□ Directly related to public safety, public health and major public interests;
□ Directly related to criminal investigation, prosecution, trial and enforcement of judgment, etc.;
□ With sufficient evidence to indicate your subjective malicious or abuse of rights;
□ Resulting to serious damages to the legitimate rights and interests of other individuals or organizations due to response to your request;
□ Involving trade secrets;
□ Other circumstances as stipulated by laws and regulations.
VI.Retention Period of Personal Information and How We Protect Your Personal Information
(I)Retention period of personal information
We will retain your personal information only for the period necessary for the purposes described herein, unless as required by legitimate business or as otherwise permitted or required by laws and regulations; for example, according to the E-commerce Law of the People’s Republic of China, the information about goods, services and transactions should be retained for at least three years from the date of completion of transaction. After the retention period has expired, we will delete or anonymize your personal information as required by applicable law.
We determine the retention period of personal information based primarily on the following criteria:
1.The completion of transaction purposes related to you, maintenance of relevant transaction and business records, and response to your possible inquiries or complaints;
2.The assurance of security and quality of services we provide to you;
3.Your consent to a longer retention period;
4.The existence of other special agreements or laws and regulations regarding retention period.
(II)We will take security measures in line with industry standards to protect the personal information you provide from unauthorized access, disclosure, use, modification, data damage or loss. We will take all reasonably feasible measures to protect your personal information. For example, we adopt SSL to encrypt and protect data (such as credit card information) exchanged between your browser and the “Service”; we use encryption technology to ensure data confidentiality; we employ reliable protection mechanisms to prevent data from malicious attacks; and we implement access control mechanisms to ensure that only authorized personnel can access personal information.
(III)We will take all reasonably feasible measures to ensure that no irrelevant personal information is collected. We will retain your personal information only for the period necessary for the purposes described herein, unless retention period is extended or permitted by law.
(IV)The Internet is never an absolutely secure environment, and user's communications via email, instant message and other means are not encrypted. Thus we strongly recommend you do not send personal information through such means. Please use a complex password to further protect your account.
(V)The Internet environment is not completely safe, and we will do our best to ensure or guarantee the security of any information you send to us. For the damages to your legitimate rights and interests caused by unauthorized access, public disclosure, alternation or damage to information due to our destroyed physical, technical or administrative protection facilities, we will bear corresponding legal responsibilities.
(VI)Response to security incident
In the event of an unfortunate personal information security incident, we will, according to laws and regulations, timely inform you of the basic details and possible impacts of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and mitigate risks, remedies for you and so on. We will report to you the incident without delay by such means as email, telephone and push notification; where it is impossible to notify each subject of personal information, we will make an announcement in a reasonable and effective manner.
Please understand that due to restrictions on technologies and risk control, though we have tried our best to enhance security measures, we cannot guarantee the absolute security of information at all times. You should understand that the system and communication network you use to access our services may fail due to situations beyond our control.
VII.Cross-border Data Transmission
Cornerstone Robotics is a company headquartered in China, with affiliates, business partners or suppliers located in different countries and regions around the world. Your personal information may be transmitted to our affiliates, business partners or service providers located outside your country so that they can assist us in processing your personal information for purposes stated herein. The rules for personal information protection in these countries and regions may differ from those in your country. In this case, we will transmit personal information only for the purposes stated herein. To the extent required by applicable law, we will take proper measures to protect your personal information when transmitting such information to these receiving parties in other countries.
VIII.Protection of Minor's Information
1.We highly value the protection of minor’s information. Minors should obtain consent from their guardians before using our products / services. If you are a minor, you should read this Policy under the guardianship and guidance of your guardian, and use our products / services and submit your personal information with the guardian's express consent and guidance. In cases where personal information of a minor is collected with the consent of a parent or legal guardian, we will only use or publicly disclose this information as permitted by law, with the express consent of the parent or guardian or as necessary to protect the minor.
2.If we discover that we have collected the personal information of a minor without the prior consent of the verifiable parent or legal guardian, we will make efforts to delete the relevant data as soon as possible.
IX.Update to This Privacy Policy
You are encouraged to review our Privacy Policy every time you use our products or services. In order to provide you with better service, we will update the provisions of this Privacy Policy based on product updates and relevant laws and regulations, which constitute an integral part hereof. If these updates result in substantial reduction or significant changes of your rights hereunder, we will notify you by prominent notifications, push messages or other means before they take effect; your continued use of our services indicates that you have thoroughly read, understood and agreed to be bound by the revised Privacy Policy. To safeguard your legitimate rights and interests, we encourage you to regularly check this Policy on the settings page of our platform.
The “significant changes” above include, but are not limited to:
1.Significant changes in our service model, such as the purposes of personal information processing, types of personal information processed, and the way in which the personal information is used;
2.Significant changes in our ownership structure, organizational structure and so on, including change of owner caused by business adjustment, bankruptcy, and merger and acquisition, etc.
3.Changes in main objects of personal information sharing, transfer or public disclosure;
4.Significant changes in your rights to participate in personal information processing and in how you exercise these rights;
5.Changes in the department responsible for personal information security, contact information and complaint channels;
6.A high risk as indicated by the personal information security impact assessment report;
7.Occurrence of other circumstances that are important or may affect your personal rights and interests seriously.
X.How to Contact Us
(I)For any doubts or concerns (including inquiries and complaints) regarding the implementation hereof or the privacy-related matters that you encounter when using our services, we have developed various feedback channels to provide you with a satisfactory solution:
1.Online feedback channel: you may submit feedback through the online feedback channel provided in “Contact Us”;
2.Human customer service channel: you may call any of our customer service hotlines to contact us;
3.Special email channel: to better protect your rights and interests, we have set up a special email address info@csrbtx.com, through which you can contact us.
(II)Upon receipt of your comments or suggestions, we will respond to you as soon as possible, generally within 15 working days after verification of your user identity or within the period specified by applicable laws and regulations, and we will not charge you for such service in general. However, you understand and acknowledge that we will not respond to your requests in the following situations:
1.Directly related to national security and national defense security;
2.Directly related to public safety, public health and major public interests;
3.Related to criminal investigation, prosecution, trial, etc.;
4.With sufficient evidence to indicate your subjective malicious or abuse of rights;
5.Necessary to protect the life, property and other significant rights and interests of you or other individuals, but difficult to get consent from you or such individual;
6.Resulting to serious damages to the legitimate rights and interests of you or other individuals or organizations due to response to your request;
7.Involving trade secrets;
8.Other circumstances as stipulated by laws and regulations.
(III)If you are unsatisfied with our response, or if we refuse to make improvements after your feedback that our processing of your personal information has infringed your legitimate rights and interests, you are entitled to file a complaint or report to regulatory authorities such as administration for industry and commerce, public security bureau.
XI.Miscellaneous
(I)The interpretation and dispute resolution of this Policy shall be governed by the laws of the mainland of the People's Republic of China. In the event of any dispute arising out of the execution and performance hereof, the two parties shall try to solve it through amicable negotiation; if such negotiation fails, either party may bring a suit to the people's court with jurisdiction in the place where Cornerstone Robotics is located.
(II)The headings used herein are provided for convenience and reading only, and do not affect the meaning or interpretation of any provisions in the text.
