1. Introduction

Nu-Tek and its affiliates and subsidiaries (“Nu-Tek”, “our”, “we” or “us”) respect your right to privacy and Personal Information protection. Nu-Tek appreciates the interest you have shown in our company, products and services by visiting our websites such as www.nutekmedical.com or other related communication channels, including, but not limited to, our social media pages, channels, mobile apps and/or blogs (together “Nu-Tek Pages”). This Privacy Notice applies to all the Personal Information Nu-Tek collects online and offline when you interact with Nu-Tek, such as when you visit Nu-Tek Pages, when you use the products or services offered by Nu-Tek, when you purchase products of Nu-Tek, when you subscribe to newsletters and when you contact our customer support, either as a visitor, a customer or a potential customer, or an agent of our suppliers or business partners, etc.

 

We may also provide you with separate privacy notices to inform you how we collect and process your Personal Information for some specific circumstances like products, services or projects offered by Nu-Tek, for example when you attend our clinical research programs, or when you use our mobile apps. Such separate privacy notices shall in principle prevail over this Privacy Notice if there is any conflict or inconsistency between the separate privacy policies and this Privacy Notice, unless mentioned or agreed otherwise.

 

If you are from the United States or Canada, please visit our North American Privacy Notice. If you are a resident of the European Economic Area (EEA) or UK, please refer to our corresponding Privacy Notice that applies to you.

 

2. What Personal Information Do We Collect and for Which Purpose?

The term “Personal Information” in this Privacy Notice refers to information relates to you or allows us to identify you, either directly or in combination with other information that we hold. We encourage you to keep your personal settings and Personal Information complete and current.

 

 

 

Nu-Tek Account Data

You can create an online Nu-Tek account for a better service experience, such as online device registration or providing your feedback through Nu-Tek Pages.

 

When you create an account on Nu-Tek Pages, we collect the following Personal Information:

 

Username;

Password;

Email address;

Country/Region;

You may also choose whether to provide the following Personal Information about you to your account, such as the company you work for, the city that you are located in, your address, postal code and telephone number.

We use this Personal Information in order to create and maintain your Nu-Tek Account. You can use your Nu-Tek Account for various services. When you do so, we may add additional Personal Information to your Nu-Tek Account. The following paragraphs inform you of the services you may use and what Personal Information we will add to your Nu-Tek Account when you use the respective services.

 

 

 

Promotional Communication Data

You can choose to sign up for marketing and promotional communications. If you do so, we will collect and use the following Personal Information about you:

 

Your email address;

Your Nu-Tek Account Data;

Your interactions with Nu-Tek, such as the subscription or un-subscription of newsletters and other promotional communications, the Personal Information you provided during your attendance of our events.

We use this Personal Information to send you promotional communications – based on your preferences and behavior – about Nu-Tek products, services, events and promotions.

 

We may contact you with promotional communications via email, SMS and other digital channels, such as mobile apps and social media. To be able to tailor the communications to your preferences and behavior and provide you with the best, personalized experience, we may analyze and combine all information associated with your Nu-Tek Account Data and data about your interactions with Nu-Tek. We also use this information to track the effectiveness of our marketing efforts.

 

Nu-Tek will give you the opportunity to withdraw your consent to receiving promotional communications at any time via the unsubscribe link at the bottom of each promotional email you may receive from us or otherwise contained in the communications we send you. You may also contact us to withdraw your consent via the contact information specified in the section “How to Contact Us”.

 

 

 

Marketing Activities Data

You may wish to attend certain events, webinars, exhibitions or fairs (“Marketing Activities”) held by Nu-Tek or other organizers. You may register for the Marketing Activities through Nu-Tek Pages, via our distributors or directly with the organizer of the Marketing Activities. We may send you invitation of such Marketing Activities. For this purpose we may need the following Personal Information from you:

 

Name;

Nationality;

Company/Hospital you work for;

Department;

Email;

Phone;

The product/service that you are interested in;

Furthermore, we may need the following additional information when you interact with Nu-Tek as a professional, which includes but is not limited to your ID number and passport number, in order to communicate with you about the Marketing Activities or for other purposes depending on the actual situation. We will give you specific notice or otherwise inform you about purpose and collection and use of your Personal Information.

 

By registering for a Marketing Activity with Nu-Tek, you agree to receive communications from Nu-Tek directly related to the Marketing Activity, such as where the Marketing Activity will be hosted, when the Marketing Activity takes place.

 

 

 

Purchase & Registration Data

When you purchase products and/or services from Nu-Tek, or when you register Nu-Tek product and/or services, or when you activate or install Nu-Tek products, we may collect the following Personal Information:

 

Name;

Telephone number;

Company/Hospital you work for;

Department;

Position;

Email;

Country;

Nation;

Shipment/Invoice Address;

Postal Code;

Fax;

Invoice history, which includes an overview of Nu-Tek products/services purchased by you;

Details of conversations that you may have with the Customer Service around your purchase;

Details of your registered Product/service, such as the name of the product/service, the product category it belongs to, the product model number, date of purchase, proof of purchase.

We collect this Personal Information to help you complete your purchase and/or registration of your product and/or services and/or product activation and installation.

 

 

 

Customer Service Data

When you interact with our Customer Service through our call center, WeChat official accounts, WhatsApp, email or other Nu-Tek Pages, we will collect or use the following Personal Information about you:

 

Your Nu-Tek Account Data;

Name;

Telephone;

Email;

Position;

Department;

Company and hospital that you work for;

Your call recording and history, purchase history, the content of your questions, or requests that you addressed.

We use this Personal Information to provide you customer support related to the product and/or service you purchased from Nu-Tek, such as to respond to your inquiries, fulfil your requests as well as repair or replace products.

 

We may also use this Personal Information to improve our products and services, to solve any potential disputes with you, and to educate our customer service representatives during training.

 

 

 

User Feedback Data

You could choose to submit any comments, questions, requests or complaints about our products and/or services (“User Feedback Data”) through various channels (such as satisfaction surveys, etc.) offered by Nu-Tek Pages. When you do so, we may collect the following Personal Information from you:

 

Your Nu-Tek Account Data

Name;

Telephone;

Email;

Title;

Department;

Details of your comment/ questions/ requests/ complaints.

We use this Personal Information to respond to your questions, fulfil your requests, resolve your complaints, ask for your opinion as well as to improve our Nu-Tek Pages, products and services.

 

 

 

Business Partner Contact Data

When you provide products and/or services to Nu-Tek, we may collect the following Personal Information through various channels such as contracts based on cooperative relations:

 

Name;

Telephone number;

Company/Hospital you work for;

Department;

Position;

Email;

Country;

Shipment/Invoice Address;

Postal Code;

Fax;

Details of conversations that you may have with Nu-Tek’s contact person around Nu-Tek’s purchase of your products or services;

We collect this Personal Information in order to successfully complete the cooperation between you and us on related products and/or services.

 

 

 

Usage Data

We may use Personal Information we collect from you while you use Nu-Tek products, services and/or our Nu-Tek Pages for analytical purposes. We do this in order to understand your interests and preference, to improve our Products, Services and/or our Nu-Tek Pages and to enhance your user experience.

 

 

 

Online Activities Data

Nu-Tek may use cookies or similar techniques which store information about your visit to Nu-Tek website to make your online experience and interaction with our websites more informative and supportive. For further information about the use of cookies or similar techniques used and your choices regarding cookies, please read our Cookie Notice.

 

 

 

Recruitment Data

You can learn about and apply for our open positions through the career portal of our website and other recruitment channels. For more information about how we collect and process your Personal Information when you apply for our position, please visit our “Recruitment Privacy Policy”.

 

3. Cookies or Other Similar Technologies

We use cookies or similar technologies when you interact with and use the Nu-Tek Pages – for instance when you visit our websites, receive our emails and use our mobile apps and/or connected devices. In most cases we will not be able to identify you directly from the information we collect using these technologies.

 

The information collected is used to:

 

Ensure that the Nu-Tek Pages function properly;

Analyze Nu-Tek Pages usage so we can measure and improve performance of Nu-Tek Pages;

Help better tailor advertising to your interests, both within and beyond Nu-Tek Pages.

For further information about the use of cookies or other similar technologies used and your settings regarding cookies, please read our Cookie Notice.

 

4. Sharing Your Personal Information with Others

Affiliates and subsidiaries

We may share your Personal Information with our affiliates and subsidiaries within the Nu-Tek Group for the purposes described in this Privacy Notice.

 

 

 

Service providers and other third parties

We may share your Personal Information with our third party service providers, in accordance with this Privacy Notice and applicable laws, in order for them to assist us in providing certain services, such as website hosting, information technology and related infrastructure provision, cloud service, order fulfilment, customer service, email delivery, auditing and other services. We will require these service providers to protect your Personal Information that they process on our behalf with contract or other manners.

We may share your Personal Information with third parties, for them to send you marketing communications, if you agreed to receive marketing communications from them.

We may also share your Personal Information with our business partners where it is necessary for the purposes listed in this Privacy Notice, for example where we may sell a product or offer certain services to you together with our business partners.

 

 

Other uses and disclosures

We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.

 

In addition, Nu-Tek may also share your Personal Information to a third party (including any agent, auditor or other service provider of a third party) in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

 

5. Third-Party Services

During your online journey across Nu-Tek Pages, you may encounter links to other service providers or directly use services offered by third party service providers, which may include social media platform provider, other app developer or other website operator (such as WeChat, Youtube, LinkedIn, Facebook, etc.). These contents, link or plug-in are added on our websites for the purpose of facilitating your log-in to our Websites, sharing information to your account on these third party services.

 

These service providers normally operate independently from Nu-Tek, and may have their own privacy notices, statements or policies. We strongly suggest that you review them beforehand to understand how your Personal Information may be processed in connection with those sites, as we are not responsible for the content of non-Nu-Tek-owned or -managed sites or apps, or the use or privacy practices of those sites. For example, we may use and direct you to a third-party payment service to process payments made through Nu-Tek Pages. If you wish to make such a payment, your Personal Information may be collected by such third-party and not by us and will be subject to the third-party’s privacy policy, rather than this Privacy Notice.

 

6. How We Protect Your Personal Information

Nu-Tek uses a variety of technical and organisational measures and procedures under the guidance of ISO/IEC 27001 information security management system (ISMS) and ISO/IEC 27701 privacy information management system (PIMS) to protect your Personal Information. For example, we implement access controls, use firewalls, secure servers and we anonymize, pseudonymise or encrypt certain types of data, such as financial information and other sensitive data. Furthermore, Nu-Tek will regularly test, assess and evaluate the effectiveness of the technical and organisational measures to ensure the security of your Personal Information. You have the responsibility to properly keep your account name and password safe.

 

However, please be aware and understand that we cannot ensure an absolute secure network. If you find that your Personal Information are breached, please contact us using the contact details provided in “How to contact us” immediately so that we can take corresponding measures.

 

In the event of any accident, force majeure event or other circumstances leading to the breach of your Personal Information, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and you can take and other relevant information. In the event of a security incident related to Personal Information, we will report to the competent authorities in accordance with the requirements of relevant laws and regulations, promptly investigate the problem, and take emergency measures.

 

7. How Do We Store Your Personal Information

Location of Storage: Nu-Tek is a Hong Kong company. For the purposes specified in this Privacy Notice, we may transfer your Personal Information to Nu-tek Health (Hong Kong) Limited. Your Personal Information may also be transferred to Nu-tek Health (Hong Kong) Limited or our third-party service providers located in countries other than where you are located that assist us in processing your Personal Information for the purposes described in this Privacy Notice.

 

These countries may have different data protection rules than that in the country in which the information was collected. In this case, we will transfer the Personal Information only for the purposes described in this Privacy Notice. If we need to transfer your Personal Information abroad, we will fulfil the procedures specified in relevant laws and regulations and protect your Personal Information with standards no lower than those required by applicable data protection laws and regulations.

 

Retention Period: Except as provided otherwise by laws or regulations, we will retain your Personal Information for the following periods:

 

We will store your Personal Information only to the extent as necessary to the proper business needs of our company (e.g. for the purposes of providing service to you or complying with the requirements of laws, tax and finance).

When there is no such business need to use your Personal Information or the time limit for retention expires according to applicable laws or regulations, we will delete or anonymize your Personal Information.

 

8. Your Rights

With respect to your Personal Information, unless otherwise provided by laws and regulations, you have the following rights:

 

You have the right to know and decide the processing of your Personal Information, and you have the right to restrict or reject our processing your Personal Information;

You have the right to access and copy your Personal Information;

If you find your Personal Information incorrect or incomplete, you have the right to ask us to rectify and supplement your Personal Information;

Where we process your Personal Information based on your consent, you may withdraw such consent. Your withdrawal of consent does not affect the validity of the Personal Information processing activities that we have carried out based on your consent prior to the withdrawal;

You have the right to request us to transfer the Personal Information to other Personal Information Handler of your choice;

You have the right to request us to explain related Personal Information processing rules;

You have the right to request us to delete your Personal Information under certain circumstances;

If you disagree with our Personal Information processing activities or this Privacy Policy, you have the right to solve the disagreement by other means.

In your request, please make clear what Personal Information you would like to access or have changed, whether you would like to have your Personal Information limited from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information.

 

We will respond to all requests we receive to exercise the data subject's rights in accordance with the requirements of applicable data protection laws within the required time limit. To the extent as permitted by laws and regulations, we may not be able to respond to your request to exercise your rights in the following circumstances:

 

If your request is contrary to our obligations under laws and regulations;

If the requested data is directly related to national security or national defense security;

If the requested data is directly related to public safety, public health, or significant public interest;

If the requested data is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.;

If we have sufficient evidence of your subjective malice or abuse of rights;

If it is in the interest of safeguarding your or other individuals' significant legitimate rights and interests, such as life and property, but it is difficult to obtain your authorization or consent;

If responding to your request to exercise your rights would result in serious harm to your or other individuals' or organizations' legitimate interests;

If the requested data involves trade secrets.

If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Information after termination of services or operations.

 

9. Special Information Regarding Minors

While Nu-Tek Pages are not generally targeted at minors under the age of 18, it is Nu-Tek’ policy to comply with the law when it requires parent or guardian permission before children’s Personal Information is collected, used or disclosed. If we become aware that we have collected Personal Information from a minor, we will immediately delete the data from our records.

 

Nu-Tek strongly recommends parents or guardians to take an active role in supervising the online activities of their children. If a parent or guardian becomes aware that his or her child has provided us with his or her Personal Information without their consent, please contact us as specified in the How to Contact Us section of this Privacy Notice.

 

10. How Do We Update This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, depending on the significance of the changes we make. We will obtain your consent to any material changes to this Privacy Policy if and where this is required by applicable data protection laws.

 

You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this Privacy Policy. If you continue to use the relevant functions on the Nu-Tek Platform or contact us through the contact information shown on the Platform, you are deemed to have accepted the updated Privacy Policy.

 

11. How to Contact Us

Contact us at service@nutekmedical.com if you have any questions, comments, concerns or complaints related to your Personal Information held by us or in case you wish to exercise any of your data privacy related rights. Please note that this email address is strictly for privacy related queries. We will review your problem without delay and make timely reply according to the applicable laws and regulations.

 

Alternatively, you always have the right to approach the competent data protection authority with your request or complaint.