Personal Information Collection List

Scenario Personal Information Types Creating User Profiles First and last name, email address, mailing address, professional title, organizational affiliation, phone number Identity Verification and Compliance Management National identification number, tax identification number, passport number, driver's license, images of related identification documents Customer Support Communication content when submitting questions or feedback Marketing Preferences and Event Participation Marketing preferences, interaction history Financial Assessment and Service Matching Income, economic status, financial account numbers, investment holdings and preferences, and ability to invest Data Obtained from Third-Party Sources Public records, social media platform information, demographic data, contact data provided by partners, etc. Device Information Collected During Access/Use of Services Operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city or geographic area Behavioral Records During Access/Use of Services Page or screen view history, visit timestamps, referring websites, page navigation paths, on-page or on-screen activity information, visit duration, marketing email open and click records

 

 

Specifically, this includes the following personal information:

 

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

● Contact data, such as your first and last name, email address, mailing address, professional title, organizational affiliation, and phone number.

● Identity data, such as national identification number, tax identification number, passport number, driver’ s license, and images of related identification documents. This information is processed to fulfill legal obligations, verify customer identity, and prevent financial fraud. Such processing is necessary to ensure compliant operations.

● Communications that we exchange with you, including when you contact us with questions or feedback, through the Service, social media, or otherwise.

● Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

● Financial data, such as your income, economic status, financial account numbers, investment holdings and preferences, and ability to invest. This information is processed to assess investment suitability and provide tailored services. Such processing is necessary to protect your financial interests.

● Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

 

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

● Public sources, such as public records, social media platforms, and other publicly available sources.

● Data providers, such as information services and data licensors that provide demographic and other information.

● Business and marketing partners, such as joint marketing partners and event co-sponsors.

 

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

● Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city or geographic area.

● Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

 

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

 

Data about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

 

2. How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

● provide, operate and improve the Service and our business, including researching prospective and current portfolio companies and financing them;

● establish and maintain your user profile on the Service;

● conduct Know Your Customer checks and other screens permitted by law;

● process payments and transactions with you;

● enable security features of the Service, such as by sending you security codes, and remembering devices from which you have previously logged in;

● communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;

● understand your needs and interests, and personalize your experience with the Service and our communications; and

● provide support for the Service, and respond to your requests, questions and feedback.

 

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

 

Marketing. We and our service providers may collect and use your personal information for marketing purposes. We may send you Pivotal China-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

● comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

● protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

● audit our internal processes for compliance with legal and contractual requirements or our internal policies;

● enforce the terms and conditions that govern the Service; and

● prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

 

Exceptions to Obtaining Consent. According to applicable laws and regulations, we may collect and use your personal information without obtaining your prior consent under the following circumstances:

• When it is related to our fulfillment of legal or regulatory obligations;
• When it concerns national security or national defense;
• When it is related to public safety, public health, or significant public interest;
• When it is necessary for the investigation, prosecution, trial, or enforcement of court judgments in criminal matters;
• When it is necessary to protect the vital legitimate interests of you or others, such as life or property, and it is difficult to obtain your consent;
• When it is necessary to enter into or perform a contract at your request;
• When the personal information has been voluntarily disclosed to the public by you;
• When the personal information is collected from legitimate and publicly disclosed sources, such as lawful news reports or government disclosures;
• When it is necessary to ensure the safe and stable operation of the products or services provided, for example, to detect or resolve product or service malfunctions;
• When it is necessary for legitimate news reporting;
• When it is necessary for statistical or academic research conducted by academic institutions in the public interest, and the results of such research are de-identified when provided externally; and
• Other circumstances as provided by laws, regulations, or national standards.

 

3. Cookies and Similar Technologies

Like many online services, we use the following technologies:

● Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.

● Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

● Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

For more information about cookies and similar technologies, including how to see which cookies have been set on your browser and how to manage and delete them, please refer to the help documentation or settings page of the browser you use. You can clear all cookies saved on your computer or mobile device, and most web browsers offer options to block cookies. However, if you do so, you will need to manually change your user settings each time you visit our Service.

 

4.  How We Share Your Personal Data

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, email delivery, marketing, and website analytics).

Investment partners. Portfolio companies, investors, and others who may be interested in you or your business.

Business and marketing partners. Third parties with whom we collaborate on joint activities, with whom we have entered into joint marketing relationships or other joint ventures.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Pivotal China or our affiliates (including, in connection with a bankruptcy or similar proceedings).

 

5. How We Store Your Personal Information

(1) Storage Location

Personal information that we collect and generate within the People’s Republic of China (PRC) is stored within the territory of the PRC. However, as we may engage service providers located outside of China to provide certain technical or support services, your personal information may be transferred to and stored in overseas locations when necessary. For specific details on international data transfers, please refer to the section below titled “International Data Transfer”.

(2) Storage Period

We will retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless otherwise required by law. The determination of the retention period is based primarily on the following criteria, with the longest applicable period prevailing:

a. completion of the Service you have consented to;

b. ensuring the security and quality of the Service we provide to you;

c. a longer retention period as expressly agreed by you; and

d. any other special arrangements regarding the retention period.

After the retention period expires, unless otherwise required by laws or regulations, we will delete your personal information in a timely manner or anonymize it. If we cease operation of our website and related Service, we will promptly stop collecting your personal information and issue a public notice of service termination. At the same time, we will delete or anonymize all personal information we have stored.

 

6. Your rights

(1) Access and Correction of Your Personal Information

You may contact us using the contact details provided in this Privacy Policy to access or correct your personal information.

(2) Deletion of Your Personal Information

You have the right to request the deletion of your personal information in the following circumstances:

• We collected your personal information without your consent and such collection is in violation of laws and regulations;
• We processed your personal information in breach of applicable laws or regulations;
• We used or processed your personal information in violation of the agreement between us (if any);
• You no longer use our products or services; or
• We cease to provide Services to you.

You may contact us using the contact details provided in this Privacy Policy to request deletion of your personal information. Unless otherwise stipulated by laws or regulations, we will respond within 30 working days. Once your personal information is deleted from our servers, it may not be immediately removed from our backup systems, but it will be deleted as soon as reasonably practicable or upon the next backup update.

Please note that if the legal or regulatory retention period has not expired, or if it is technically difficult to delete the data, we may be unable to delete your personal information. In such cases, we will cease processing your personal information in a timely manner.

(3) Withdrawal of Your Consent

Each service function requires certain basic personal information to operate. For the collection and use of any additional personal information, you may give or withdraw your consent at any time.

Withdrawing your consent will not affect our previous processing of your personal information, but we will no longer continue to process it moving forward.

You may contact us using the contact details provided in this Privacy Policy to change the scope of your consent.

(4) Other Rights and Identity Verification Requirements

Under applicable laws, you may also have other rights regarding your personal information, such as the right to copy, transfer, supplement, or obtain a copy of your personal data.

You can exercise these rights by contacting us through the details provided in this Privacy Policy.

To protect your privacy, we may request additional information to verify your identity before processing your request.

(5) Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

 

7. Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

 

8. Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.  

 

9. International data transfer

As we are a global company, your personal information may be transferred outside of your region. In particular, we may transfer your personal information listed in section 1 above to our group headquarters in Hong Kong, i.e. Nan Fung Group, for the purposes which may include, for example, which may include, for example, centralized data management, administrative support, customer service, business operations, or compliance with legal and regulatory obligations, etc. We implement appropriate safeguards to ensure that all cross-border data transfers are conducted securely and in compliance with applicable laws and regulations. In some cases, courts, law enforcement agencies, regulatory authorities, or security agencies in those jurisdictions may have the legal right to access your personal information. We will handle such requests in compliance with applicable laws. Where consent is required by law, we will seek your explicit consent prior to transferring your personal information.

We are committed to protecting your privacy and ensuring that your personal information is handled securely and in accordance with this privacy policy, regardless of where it is processed. If you have any questions regarding cross-border data transfers or wish to exercise your personal information rights, please contact us using the details provided in this Privacy Policy.

 

10. Children

The Service is not intended for use by children under 14 years of age. If we learn that we have collected personal information through the Service from a child under 14 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us.

 

11. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

 

12. How to contact us

Pivotal bioVenture Partners China

● Email: info@pivotalbiovp.cn

● Mail:  Pivotal BioVentures Partners China, Rm 2001, Yi Fung Place, 99 West Ziyun Road, Changning, Shanghai.