DSB places great importance on protecting the personal information and privacy security of users (hereinafter referred to as “users” or “you”) who use our internet products and services (collectively referred to as “DSB Internet Services”). When you use DSB Internet Services, we may collect and use your relevant personal information. We aim to clarify through this DSB Internet Services Privacy Policy (hereinafter referred to as “this Policy”) the specific rules and other relevant matters governing how we collect and use your personal information, so as to better safeguard your rights and interests.

This Privacy Policy has been carefully crafted with full consideration of your needs, ensuring that you have a comprehensive understanding of our practices regarding the collection and use of personal information, while also enabling you to maintain ultimate control over the personal information you choose to provide to us. If you do not agree with the contents of this policy, it may result in our internet products and services failing to function properly; in such case, you should immediately cease accessing or using our products or services. By using or continuing to use DSB’s internet services, you signify your agreement to our collection, use, storage, and sharing of your personal information in accordance with this policy (including any updated versions).

If you have any questions, please contact us.

I. Collection and Use of Personal Information

In this Privacy Policy, “personal information” refers to data that can identify a specific individual either by itself or in combination with other information. We collect your personal data for various purposes during your interactions with us. Such interactions may include: registering an account on this website, ordering our products or services, making payments to us, contacting us when you have questions or issues, browsing our website, and configuring the settings of our website or your account settings. We primarily collect users’ personal information to optimize DSB’s internet services and provide users with personalized services, thereby enhancing user satisfaction.

(1) Personal information collected and obtained, and the methods used to collect it

1. Information provided by users: This includes information provided by users when registering for or using the DSB Internet service platform and system, as well as information that users have consented to us retaining; and information shared with other parties through the DSB Internet service platform and system, including but not limited to information uploaded or posted in publicly accessible areas visible to other users.

2. Information Agreed to Be Shared: Information shared with us by other parties with the user’s authorization;

3. Information We Collect: When you use DSB’s internet services, we collect, aggregate, and record information such as login logs, location data, IP addresses, device information, and more.

(2) Use of Personal Information

1. Create an account

To comply with legal and regulatory requirements and to provide you with more personalized and convenient services, you will need to provide at least a mobile phone number or an email address when registering, and create your account, username, and password, among other relevant information. For certain individual services, if you only wish to use basic functions such as browsing and searching, you do not need to register as a user of DSB Internet Services nor provide the aforementioned information.

During the registration and login process for certain individual services, if you provide additional information (such as your name, region, or workplace), it will help us deliver personalized recommendations and a better service experience. However, if you choose not to provide this information, it will not affect your ability to use the basic functions of DSB’s internet services. Furthermore, provided that you comply with the terms of our individual service agreements and relevant national laws and regulations, we also offer account deactivation services. You can contact us by sending an email to web#sanygroup.cn (replace # with @) to request account deactivation.

2. Perform the transaction or service

Including payment of deposits, fulfillment of orders, delivery of products or services, gift-giving, and more; making changes at your request or providing information you’ve requested (such as marketing materials for products or services, etc.); and offering technical support.

3. Improve our products and services

To maintain and improve the quality of our products or services and to provide you with personalized services, we may collect and use your information in compliance with applicable laws and based on your specific consent. For example, we may use your browsing and search history, information about construction machinery and equipment, location data, and other relevant information to recommend or display product/service information that may interest you, or to show you personalized goods and services through our system.

In addition, we may collect information you provide to us when you participate in product/service surveys, reviews, or events, as well as relevant information generated from your interactions with our affiliates and partners, so that you can submit user suggestions and complaints, and we can improve the quality and processes of our customer service.

4. Contacting you

We will send you information about products and services that may be of interest to you; invite you to participate in Desbo’s internet service activities (including promotional events), market surveys, or satisfaction surveys; or send you marketing messages and other important notifications. If you no longer wish to receive such information, you can contact us at any time to unsubscribe.

5. Providing you with security protection

To enhance the security of your use of our services, protect your personal and property safety as well as that of other users or the public from harm, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, cyberattacks, and unauthorized network intrusions, and more accurately identify instances of violations of laws, regulations, or the rules stipulated in the DSB Internet Services Agreement, we may collect, use, or integrate your account information, device information, log information, and information obtained by our affiliated companies and partners with your authorization or shared pursuant to law, in order to safeguard the legitimate rights and interests of you, other users, ourselves, or our affiliates, and to record certain links that we deem risky.

6. Other uses

You understand and agree that, after collecting your personal information, we may use technical means to de-identify the data. The de-identified information will no longer be able to identify your identity. Under these circumstances, we are entitled to use the de-identified information to analyze the user database and exploit it commercially, without needing to obtain your separate consent.

Please note that if we intend to use your personal information for other purposes not specified in this policy or to collect additional personal information not mentioned herein, we will obtain your separate consent through page prompts, interactive processes, website announcements, or other means. Once you give your consent, such additional uses will be deemed part of this policy, and the additional information collected will also be subject to this policy.

II. Use of Cookies

To ensure the website functions properly, we sometimes store small data files called cookies on your computer or mobile device. A cookie is a plain-text file that a web server stores on your computer or mobile device. The contents of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile app. Typically, a cookie contains an identifier, the name of the site, and some numbers and characters. With the help of cookies, websites can store data such as user preferences. By using cookie technology, we can provide you with more thoughtful, personalized services and allow you to customize your specific service settings.

The purpose of enabling cookies by us is the same as that of most websites or internet service providers: to enhance user experience. Other third parties set cookies on our website—for example, Google and Baidu. These third parties use cookies to collect your IP address, information about your browser configuration, and browsing activity, but they do not collect any personally identifiable information about you. They use cookies to understand how you interact with our website. You can learn more about how these third parties use cookies by visiting their respective websites.

You can manage or delete cookies according to your preferences. For more details, please visit AboutCookies.org. You can clear all cookies stored on your computer, and most web browsers offer a feature that allows you to block cookies. However, if you do so, you’ll need to manually adjust your user settings each time you visit our website.

III. Sharing, Transfer, or Disclosure of Personal Information
(1) Share

We will not share your personal information with any third party outside of DSB, except in the following circumstances:

1. Obtain your explicit consent or authorization in advance;

2. We may share your personal information with external parties in accordance with applicable laws and regulations, or as required by mandatory directives from government authorities or judicial rulings.

3. We share your information with our partners to enable the functionality of our products and/or services, allowing you to use the services you need without any issues. For example, the DSB Internet service platform integrates a wide range of third-party services. When you choose to use these third-party services, you authorize us to provide your information to the third-party service platforms or service providers so that they can deliver services to you based on the relevant information.

4. Necessary sharing with affiliates. To enable us to provide you with consistent services based on a unified account system, facilitate your unified management, deliver personalized recommendations, and ensure the security of our systems and accounts, your personal information may be shared as necessary between us and our affiliates.

5. To achieve the purposes set forth in Section 1 of this policy, “Collection and Use of Personal Information”;

6. To fulfill our obligations and exercise our rights under this policy or other agreements we have entered into with you;

7. To the extent permitted by laws and regulations, in order to comply with the law and safeguard the interests, property, or safety of ourselves, our affiliates or partners, you, other users, or the general public—such as to prevent fraudulent or other illegal activities and reduce credit risks—we may exchange information with other companies and organizations. However, this does not include information that is sold, rented, shared, or otherwise disclosed for profit purposes in violation of the commitments made in this policy.

8. Provided in accordance with the individual service agreement signed with you (including electronically signed agreements online as well as the corresponding platform rules) or other legal documents;

We will share your personal information only for lawful, legitimate, necessary, specific, and explicit purposes. With respect to the companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements requiring them to process the information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.

(2) Transfer

We will not transfer your personal information to any company, organization, or individual other than DSB, except in the following circumstances:

1. Obtain your explicit authorization or consent in advance;

2. To comply with the requirements of laws and regulations, legal procedures, mandatory government requirements, or judicial rulings;

3. If we or our affiliates are involved in transactions such as mergers, splits, liquidations, or the acquisition or sale of assets or businesses, your personal information may be transferred as part of such transactions. We will ensure the confidentiality of this information at the time of transfer and require the new entity or organization that holds your personal information to continue to be bound by this Privacy Policy. Otherwise, we will ask that entity or organization to obtain your renewed consent.

(3) Public Disclosure

We will disclose your personal information only in the following circumstances:

1. Obtain your explicit consent;

2. Based on mandatory requirements under laws, regulations, legal procedures, litigation, or by government authorities.

(4) Exceptions

According to relevant laws and regulations, your information may be collected in the following circumstances without requiring your prior consent:

1. Directly related to national security and defense security;

2. Directly related to public safety, public health, and significant public interests;

3. Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;

4. Where it is necessary to protect your or another person’s vital legitimate rights and interests, such as life and property, but obtaining the individual’s consent is difficult;

5. Personal information you voluntarily disclose to the public;

6. Collecting personal information from legally and publicly disclosed sources, such as legitimate news reports and government information disclosure channels;

7. Necessary for signing and performing the contract in accordance with the data subject’s request;

8. Necessary for maintaining the safe and stable operation of the products or services provided, such as detecting and addressing faults in the products or services;

9. Other circumstances prescribed by laws and regulations.

10. According to legal provisions, the sharing or transfer of personal information that has been de-identified, provided that the data recipient cannot reconstitute or re-identify the data subject, does not constitute an external sharing, transfer, or public disclosure of personal information. Therefore, no separate notification to you or your consent will be required for the storage and processing of such data.

IV. Retention and Protection of Personal Information
(1) Retention Period

We will retain your personal information only for the period necessary to achieve the purposes described in this policy and within the time limits required by applicable laws and regulations. If you deactivate your account or voluntarily delete the aforementioned information, we will continue to retain your information in accordance with the provisions of laws and regulations such as the Cybersecurity Law. After you deactivate your account or voluntarily delete the aforementioned information, we will no longer use your personal information for commercial purposes; however, we may still use your personal information after anonymizing it.

(2) Preserved Area

Your personal information is stored within the territory of the People’s Republic of China. If certain products or services involve cross-border data transfers, we will need to transmit your personal information to overseas locations. We will comply strictly with applicable laws and regulations and ensure the security of your personal information.

(3) Security Measures

1. We will collect, use, store, and transmit user information in accordance with established industry security standards and regulations, and will inform you of the purposes and scope of such information usage through our User Agreement and Privacy Policy.

2. We place great importance on information security and will adopt reasonable and feasible security measures and technical means that comply with industry standards to store and protect your personal information, thereby preventing your information from being lost, accessed without authorization, disclosed publicly, used, modified, damaged, lost, or leaked. We will take all reasonable and feasible measures to safeguard your personal information. We will employ encryption technologies to ensure the confidentiality of data; and we will utilize trusted protection mechanisms to guard against malicious attacks on data.

3. We will conduct awareness training and competency assessments on data security for our employees, enhancing their understanding of the importance of protecting personal information. We have implemented access control mechanisms to authenticate the identities of employees handling personal information and enforce strict access permissions. In addition, we will sign confidentiality agreements with employees and partners who come into contact with your personal information, clearly defining their job responsibilities and behavioral guidelines to ensure that only authorized personnel can access such information. Any violation of these confidentiality agreements will result in appropriate accountability.

4. We would like to remind you that the internet is not an absolutely secure environment. When you exchange information with other users via email, text messages, or other means, you cannot be certain that third-party software fully encrypts the transmission of your data. Therefore, please take extra care to ensure the security of your personal information. We advise against sending personal information through these channels to avoid any risk of leakage. Please use strong, complex passwords to help us safeguard the security of your account and personal information.

(4) Security Incident Notification

1. To address potential risks such as the leakage, damage, and loss of personal information, we have established corresponding security policies that clearly define classification and grading criteria for security incidents and vulnerabilities, as well as the associated handling procedures. We have also set up a dedicated emergency response team for security incidents. In accordance with the prescribed guidelines for handling security incidents, this team activates specific security plans tailored to different types of incidents, taking immediate measures to minimize losses, conduct thorough analysis, pinpoint the root causes, develop remedial actions, and collaborate with relevant departments to trace the source and take appropriate countermeasures.

2. In the event of an information security incident, we will promptly notify you, in accordance with applicable laws and regulations, of: the basic details and potential impact of the incident; the measures we have already taken or plan to take to address the incident; recommendations on how you can independently prevent and mitigate risks; and any remedial measures available to you. We will also promptly inform you of relevant incident details via email, letter, phone call, push notifications, or other appropriate means. When it is impractical to notify each data subject individually, we will publish a notice through reasonable and effective channels. Additionally, we will proactively report the handling status of information security incidents to the regulatory authorities as required by them.

Please be sure to keep your account, password, and other identity credentials securely. When you use the DSB Internet Services, we will use your account, password, and other identity credentials to verify your identity. Once you disclose the aforementioned information, you may suffer losses and could face adverse consequences. If you suspect that your account, password, and/or other identity credentials may have been or already have been compromised, please contact us immediately so that we can take appropriate measures in a timely manner to prevent or mitigate any related losses.

V. User Rights

In accordance with China’s relevant laws, regulations, and standards, as well as common practices in other countries and regions, we ensure that you can exercise the following rights with respect to your personal information:

(1) Access, Update, and Delete

We encourage you to update and modify your personal information to ensure it remains accurate and up-to-date. You can access your personal information through DSB’s online services and, depending on the management method applicable to each type of information, either make the necessary changes yourself or request that we carry out modifications, additions, or deletions on your behalf. We will employ appropriate technical measures or provide convenient channels for submitting requests, doing our utmost to ensure that you can access, update, and correct your personal information—or any other information provided when using DSB’s online services.

When accessing, updating, correcting, or deleting the aforementioned information, we may ask you to verify your identity to ensure the security of your data. If you would like to inquire about, modify, or delete some of your personal information, please send an email to web@sanygroup.cn, and we will respond to your request within 30 days.

(2) Openness and Sharing

Our various services allow you not only to share your personal information publicly with your social networks but also with all users who utilize these services—for example, information you upload or post when using DSB’s internet services, as well as location data and log information associated with such content. As long as you do not delete the information you have made public or shared, it may remain in the public domain indefinitely. Even if you delete the shared information, it could still be independently cached, copied, or stored by other users or third parties beyond our control, or retained by those users or such third parties in the public domain. We shall not be liable for any leakage of your information resulting from your posting or sharing of information through the channels mentioned above. Therefore, we strongly advise you to carefully consider whether to make your information public or share it via these channels.

(3) Deactivate account

Your service account for this particular DiSiBo internet service may be canceled or deleted, provided that it complies with the terms and conditions stipulated in the service agreement for that specific DiSiBo internet service and with applicable national laws and regulations. Once the account is canceled or deleted, all service records and data associated with that account under this particular service will be deleted or processed in accordance with the provisions of the service agreement for that specific service, unless otherwise provided by applicable laws and regulations.

(4) Change the scope of your consented authorization.

You can choose whether or not to disclose information. Some information is necessary for Desbo’s internet services, but providing most other information is up to you. You can delete the information or turn off your device.

You may change the scope of your authorization for us to continue collecting information or withdraw your authorization through features such as these.

Once you withdraw your authorization, we will no longer be able to provide you with the services corresponding to the withdrawn authorization, nor will we continue processing your relevant information. However, your decision to withdraw authorization will not affect any information processing that has already been carried out based on your prior authorization.

VI. Personal Data of Minors

Any minor participating in online activities must obtain prior consent from their parents or legal guardian (hereinafter referred to as the “guardian”). We will protect minors’ personal information in accordance with applicable national laws and regulations. If you are a minor, please inform your parents or guardian to read this policy and seek their consent and guidance before submitting any personal information.

7. Third-party service providers and their services

To enhance your service experience, you may receive content or web links from third parties outside of Desbo. We have no control over such third parties. You may choose whether to access or use the links, content, products, and services provided by these third parties. We cannot control the privacy and data protection policies of these third parties, and they are not bound by this statement. Before submitting any personal data to a third party, please review that third party’s privacy policy.

8. Policy Updates

We may update or revise this policy from time to time in response to changes in our services or data processing practices. If there are any updates, we will post the latest version of the privacy statement on the DSB website, and it will take effect immediately upon posting. We recommend that you review this statement periodically to stay informed of any changes. If we make any material changes to this statement—such as changes to the scope of personally identifiable data collected or the purposes for which such data is used—we will notify you through appropriate channels and obtain your consent.

9. Contact Us

If you would like to contact us, please reach out via the following methods:

Contact Information:service@dsbmedical.com