Privacy Policy

Updated: November 16, 2022

Effective date: November 16, 2022

Prompt terms:

Smilener attaches great importance to you and the personal information you provide. We will process you and your personal information in strict accordance with the requirements of the relevant laws and regulations of the people's Republic of China and the provisions of this Privacy Policy.

This Privacy Policy applies to all products and / or services provided by Smilener (Jiangsu) Medical Technology Co., Ltd. (registered address: 4 / F, Building 20, Chuangzhi Road, Kunlun Street, Liyang City) (hereinafter referred to as "Smilener" or "we"). All products and / or services provided by you to visit or use this website also apply to this Privacy Policy.

Therefore, before you visit or use this website or the products and / or services provided by Oriental Hyatt, please read carefully and fully understand the contents of this Privacy Policy, especially those that remind you to pay attention to in bold and black form. As long as you click the "confirm" button or check "agree", you fully understand and agree to this Privacy Policy. If you have any questions, comments or suggestions about the terms or contents of this Privacy Policy, please contact us through the contact information provided at the bottom of this Privacy Policy. We are more than happy to provide you with feasible assistance.

Part I Definition

1. Personal information: refers to any data related to an identified or identifiable natural person (information subject); an identifiable natural person refers to a natural person who can be identified directly or indirectly, especially through identifiers such as name, location data, network identifier, or through specific physical, psychological, genetic, mental, economic, cultural, social and other personal attributes.

2. Data processing: refers to any operation or series of operations on personal data, whether or not it is carried out by automated means, such as data collection, recording, organization, construction, storage, adaptation or modification, restore, query, use, disclose through dissemination, distribution or other operations that make personal data available to others to obtain, arrange or combine, restrict, clear or destroy.

Part II Privacy Policy

This Privacy Policy will help you understand how Oriental Hyatt may collect, retain, process, share and transfer your personal information when you visit our website or use our system, but does not include websites or services that we do not own or control.

I. How do we collect and use your personal information?

II. we share and publicly disclose you and the personal information you provide

III. How do we store and protect you and the personal information you provide?

IV. How should you manage yourself and the personal information you provide?

V. How do we protect children's personal information?

VI. How do you and the personal information you provide transfer around the world?

VII. How do we revise and update this privacy policy?

VIII. How to contact us?

一、 How do we collect and use you and the personal information you provide?

We may obtain your personal information or other people's personal information from a variety of sources. You can provide us with personal information about you or others on our web page, through our social media page and Mini Program, or while participating in one of our events. When you visit our web pages, our social media pages or use our Mini Program services, we also collect certain information about your device or usage in an automatic way, including using Cookies, Web server logs and web beacons. We may also collect your personal information indirectly from other sources.

1、 Personal information collection

(1) The personal information about you and others that you voluntarily provided to us.

- Smilener Club System account opening and related services

As a doctor, doctor assistant / consultant or medical student, you need to provide us with your personal information when you open an account with Oriental Hyatt Smilener Club system. Including but not limited to: your name, profile picture, telephone number, WeChat account, contact email address, doctor's practice certificate and other related qualifications, the name, address, telephone number, contact email address of your clinic or hospital, bank account number and other information based on the reasonable requirements of Oriental Hyatt.

- Smilener Club System product and / or service acquisition

As the account user, in order to obtain the corresponding products and / or service processes of Oriental Hyatt, you will provide us with (unprocessed) personal information of the patient, including, but not limited to: the patient's name, sex, date of birth, photo, case information, including: doctor's information, patient's teeth, face, body photos, X-rays, oral scan data and other case information based on Oriental Jiayue's reasonable requirements.

- Web smile test

In order to conduct the smile test, you need to provide us with your identity (an adult or a parent looking for a solution for your child), name, email address, mobile phone number, city, corrective claims and other information based on the reasonable requirements of Oriental Hyatt.

- Looking for a job

In order to arrange an interview to join Oriental Hyatt, you need to provide us with: your name, date of birth, city, mobile phone number, email address, educational background and other information based on the reasonable request of Oriental Hyatt.

- Webpage retention of funds

Collect your user name or name, mobile phone number, date of birth, city, email address and other information based on the reasonable requirements of Oriental Jiayue through the web page retention interface. Oriental Jiayue is allowed to assist you in booking a clinic, sending you information about Oriental Hyatt related activities and customized customer service by phone or text message.

- Product or service consultation, evaluation, feedback

You can consult, evaluate, suggest and feedback on our products or services, and we will collect your advice, evaluation, suggestions and feedback.

- Participate in activities

We may invite you to participate in filling out our survey questionnaire. You need to provide information related to your name, email address, mobile phone number, occupation, rank and research content. At the same time, you can also book all kinds of online and offline activities (including our training, meetings and courses). For this purpose, we will collect your name, email address, mobile phone number, remarks, courseware content, appointment date, and participation time.

(2) Personal information collected by Smilener during your use of our products or services

In order to ensure the safe operation of Smilener web pages and provide you with convenient, reliable and reliable products / services and use environment, we may collect your operation, usage log, network and device information (including but not limited to device model, device identification number, operation web page, IP address, operator, etc.). And personal information collected based on your mobile device's web page permissions (including, but not limited to, service recommendation functions based on location permissions, photo upload functions based on camera permissions, etc.). If you turn on these permissions, you authorize us to collect and use these personal information to achieve the above functions, and if you turn off the permissions, you will no longer be able to collect and use these personal information. nor can we provide you with the functions that correspond to these authorizations. Your decision to turn off permissions will not affect the previous processing of personal information based on authorization. At the same time, in order to prevent malicious programs and secure operations, we will collect information about installed applications or running processes, overall application operation, overall installation usage and frequency, application crashes, application sources, performance data, and so on.

(3) Personal information collected offline

When you use our products and / or services offline to interact and communicate with us, we may collect and use information related to the use of our products and services by you or your patients, including, but not limited to: name, age, occupation, birthday, work experience, educational experience, etc.

(4) Personal information collected indirectly by Smilener through third parties

In order to provide you with more professional, higher quality and more personalized products or services, or jointly provide services for you, or for the purpose of preventing Internet fraud, our affiliated companies and partners will share personal information with legitimate sources with us in accordance with the provisions of the law of the people's Republic of China or with your agreement or consent. You confirm that we have the right to obtain the personal information provided by you and to process the personal information provided by you within your authorization.

We understand that if you are a doctor, you provide us with the aforementioned patient's personal information for the purpose of providing Smilener products or services to the patient, and you have the right and qualification to use it in accordance with the laws of the people's Republic of China, and provide us with and authorize us to process the aforementioned patient's personal information. Further, we understand that before you provide us with the above patient's personal information, you have signed a relevant informed consent with the patient, authorizing you to provide and manage the patient's personal information to us, and allow us to process the patient's personal information in the manner described in this Privacy Policy.

You should obtain the express consent of the minor and his guardian before collecting the patient data of the minor who has reached the age of 14; if you are under the age of 14, you should obtain the express consent of the guardian. If you fail to obtain the above consent, you may not collect relevant personal information.

You have an obligation to provide true and effective personal information about you and your patients, and personal information that changes should be updated in a timely manner so that we can verify your identity and provide relevant products or services. If you submit other people's personal information, you should obtain the legal authorization of others. The above information you provide will continue to authorize us to use this service during your use of this service.

2、 Purpose of use of personal information

By providing Smilener with your personal information, you agree that Smilener may use such personal information, either alone or in combination with existing information, for the following purposes:

(1) Allows you to use, purchase and subscribe to Oriental Hyatt products and services. Smilener may list your or patient's name, address, telephone number and other contact information on the product and data label.

(2) Provide you with information about our products, services, news and activities

(3) Provide patients with information about you or your medical institution and allow them to contact you

(4) You are invited to participate in our questionnaire.

(5) Analyze our products and services, develop new products and services, and customize our products, services and other information we provide;

(6) Help you establish and manage Smilener patient information and files, and produce and customize products and services according to your treatment plan.

(7) In order to solve the problem of failure of our web pages and services

(8) Internal audit, data analysis and research to improve our products or services

(9) For the needs of transactions such as mergers, acquisitions or asset sales, we may transfer the personal information you provide, and we will give you appropriate notice before transferring the personal information you provide. and ensure that the personal information you provide is protected as much as this Privacy Policy after transfer.

(10) Used for purposes required by laws and regulations, court orders or other legal proceedings, or authorized government agencies

(11) For other legitimate purposes.

After collecting the personal information you provide, we will de-identify the personal information through technical means, and the personal information will not be able to identify the subject without the help of additional information. Please understand and agree that we have the right to use the de-identified information in this case, and we have the right to analyze and commercialize the user database without disclosing the personal information you provide. We will use the collected personal information in accordance with the terms of this Privacy Policy and for the implementation of our product and / or service functions. We will seek your prior consent if we use your personal information for other purposes not specified in this Privacy Policy, or if we use information collected for a particular purpose for other purposes.

3、 How do we use Cookie

(1) Cookie is a small text file that is stored on your computer or mobile device when you visit our website. Our websites, applications, and other services send this data to your browser the first time you request to browse the web, and then store the data on your computer or other device so that when you first request to browse the web, the website or application can access, store or collect information on your device. Browsers support cookie and similar technologies (such as local storage and pixels) so that our website can remember information about your visits and can use that information to improve your experience and create aggregate anonymous statistics about website usage. In this Privacy Policy, we use the word "cookie" to refer to cookie and similar technologies;

(2) You can manage or delete Cookies according to your preferences. You can refuse to accept Cookies by modifying your browser settings, or you can clear all Cookies saved in your mobile device. However, if you do so, you may need to repeat the login steps, change user settings, etc., each time you visit this page, which will affect your use of this page to some extent. For further details of Cookies, please click here for

二、 How do we share and publicly disclose you and the personal information you provide

1、 The personal information provided by you will be kept confidential and kept strictly in accordance with the relevant laws and regulations of the people's Republic of China, and will not be provided or displayed to any third party in any way, except in the following cases:

(1) Obtain your express consent or authorization in advance, if the patient's personal information is involved, obtain the patient's authorization consent through you or by us.

(2) When judicial or administrative organs require this website to disclose personal information in accordance with legal procedures and legal functions and powers, we will provide relevant information in accordance with the law. We will be exempt from liability for any disclosure in this case.

(3) We are exempt from liability for the disclosure, loss, misappropriation or tampering of personal information caused by any force majeure event that affects the normal operation of the web page, such as a hacker attack, a computer virus invasion or outbreak, or a temporary shutdown caused by government control.

(4) We are not responsible for any disclosure, loss, embezzlement or tampering of personal information caused by telling others your personal password or sharing your registered account with others.

(5) We are not responsible for the disclosure, loss, embezzlement or tampering of personal information of any other web pages linked to this page.

2、 By providing us with personal information, you agree that Oriental Hyatt may share your personal information with third parties for the purposes specified in this Privacy Policy under the following circumstances:

(1) We may share the personal information you provide with our affiliated companies. However, we will only share the necessary personal information if necessary and are subject to the purposes stated in this Privacy Policy. If our affiliated company wants to change the purpose of processing personal information, it will seek your authorization again. If the patient's personal information is involved, the patient's authorization will be obtained through you or by us.

(2) We may share your order information, account information, equipment information, location information and other relevant personal information with partners and other third parties to ensure the smooth completion of the products and services provided to you. However, we will only share your personal information for legitimate, legitimate, necessary, specific and specific purposes, and will only share the personal information necessary to provide products and services. Our partners do not have the right to use shared personal information for any other purpose. Our partners include the following types:

- A supplier of goods or technical services

We may share the personal information you provide with third parties who support our features. These supports include providing or providing infrastructure technical services, logistics and distribution services, payment services, data processing, etc., for our supply, cooperative products and services.

- Partners who work with us to promote

In order to enhance your experience of browsing and using this website and to keep you informed of products and / or services in a timely manner, we sometimes entrust other enterprises to provide joint promotion of our products and services. We may use the personal information you provide and the non-personal information you provide to share with our joint promotion partners, for this reason, we will inform you separately and obtain your consent, if the patient's personal information is involved, then obtain the patient's authorization consent through you or by us.

- Third-party component

In order to better provide you with products and services, we may share your personal information with third-party components embedded in web pages and APP.For more information, please click here

- Other purposes you agree to

For purposes that you agree to from time to time, including any other purposes stated when collecting personal information (for example, we may share the collected information with your medical institution or other users of this web platform)

- Other

Provide the personal information you provide to the court or government agency in accordance with laws and regulations, court orders or other legal procedures, or at the request of an authorized government agency.

We will sign strict confidentiality agreements with companies, organizations and individuals with whom Smilener shares personal information, requiring them to process personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

3、 We will not transfer the personal information you provide to any company, organization or individual, except in the following cases:

(1) Transfer with express consent: with your express consent, we will transfer the personal information you provide to other parties. If the patient's personal information is involved, the patient's authorization will be obtained through you or by us.

(2) In the event of a merger, acquisition or bankruptcy liquidation, or other situations involving a merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will require new companies and organizations that hold your personal information to continue to be bound by this privacy policy, otherwise we will require the company, organization and individual to re-seek authorization from you, if patient personal information is involved. The patient's authorization can be obtained through you or by us.

4、 We will only publicly disclose the personal information you provide under the following circumstances:

(1) With your express consent or based on your active choice, we may publicly disclose the personal information you provide. If the patient's personal information is involved, we may obtain the patient's authorization through you or by us.

(2) If we determine that you have violated laws and regulations or seriously violated Smilener-related privacy policies or rules, or in order to protect the personal and property safety of users or members of the public of Smilener and its affiliated companies, we may disclose your personal information about you in accordance with laws and regulations or Smilener-related privacy policies and rules, or obtain the patient's own authorization through you or us if the patient's personal information is involved.

三、 How do we store and protect you and the personal information you provide?

1、 According to the relevant laws and regulations of the people's Republic of China, we will keep the network log information for at least 6 months. We retain you and other personal information provided by you only for the shortest period necessary to provide you with the purposes described in this Privacy Policy, except as otherwise provided by laws and regulations or as otherwise authorized by you. After the above storage period is exceeded, you and the personal information provided by you will be deleted or anonymized.

2、 Personal information collected and generated during our operations in the people's Republic of China is stored in China, except in the following cases: (1) it is clearly stipulated in laws and regulations; or (2) it is expressly authorized by you, if the patient's personal information is involved, then obtain the patient's authorization consent through you or by us.

3、 During your use of our products and / or services, we will continue to keep your personal information for you for the shortest period of time required to provide the products and services according to your business needs, unless you cancel the authorization, delete the information or cancel your account.

4、 We will take reasonable and feasible data security measures in line with industry standards to keep and protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We protect the security of your online submission through encrypted transmission; the storage system in the background is physically separated from the user information collection system in the foreground, and do not share the same server; regularly evaluate and audit the network equipment and security equipment on the security boundary, repair the loopholes in time, and put an end to weak passwords. Regularly scan web pages and code-level vulnerabilities to repair security vulnerabilities and configuration nonconformities found in time; all operators who access personal electronic information must go through a fortress machine with two-factor authentication before they can operate and fully record all operations.

5、 We have set up an information security management team, and established a detailed web security management system and a personal information confidentiality system, and we have passed the relevant national certification for data security.

6、 We will take reasonable and feasible measures to avoid collecting irrelevant personal information.

7、 The Internet is not an absolutely secure environment, and email, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send personal information through email, instant messaging, and communication with other users, although we have implemented encryption measures for some of the above. Please use a complex password to help us ensure the security of your personal information and your patient's personal information.

8、 We have established a management system for the reporting and disposal of network security incidents. if there is an unfortunate occurrence of personal information security incidents, we will deal with them in accordance with the four steps of reporting, response, post-analysis and rectification. And in accordance with laws and regulations to inform you of the specific situation and timely communication with you on remedial measures. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities. For the patient's personal information provided by you, you may need to further notify the appropriate personal information subject after you have received our security incident notification.

四、 How should you manage yourself and the personal information you provide?

1、 Query and change you and the personal information you provide: after successful registration, you will generate account information such as user name and password. You can log in to your account and send a written request to our company mailbox through the "personal Center" function or to send a written request to our company mailbox. Request to query and change the registration mailbox, password, address and other personal information. If you find that there is a security breach or illegal use of your account, please send a written request to our company mailbox to notify us in time and report to the relevant departments.

2、 Delete you and the personal information you provide, cancel your account: you have the right to ask us to delete the personal information collected on this page, and you have the right to request cancellation of your account. You can delete some of your personal information by editing your personal account information (login account, through the "personal Center" function), or you can submit the relevant request directly by sending an email. You understand that we will verify your identity information before deleting you and the personal information you provide or canceling your account. Unless otherwise provided by law, if the user logs out, we will delete you and your personal information, and stop providing services to you (including, but not limited to, stopping login, placing orders, etc., points in your account will be zero, etc.). Please note that when you delete the appropriate information from our service or we receive and agree to your deletion request, we may not immediately delete the appropriate information from the backup system, but will delete it when the backup update.

3、 Revoke the license you have agreed to: under this Privacy Policy, you can withdraw the relevant web rights you have granted to this page, which requires you to set it in your device. The specific settings may vary depending on your mobile phone system, brand, model, and so on.

4、 When you cancel your authorization, delete your personal information or cancel your account, we will delete you and your personal information in accordance with the law, or anonymize it as permitted by law, making it inaccessible and inaccessible. However, we will still store some of your information in accordance with the law.

5、 Please take good care of your account information and be responsible for the security of your account information and the actions carried out through the account. Except as required by relevant law and with the consent of Smilener, your account is for your own use only and may not be borrowed, transferred, donated, inherited or allowed to be used by others in any way.

6、 In the following cases, we will not be able to respond to your request and reserve the right to close your account:

(1) Related to national security and national defense security.

(2) Related to public safety, public health and major public interests.

(3) Related to criminal investigation, prosecution, trial and sentence enforcement, etc.

(4) There is ample evidence of subjective malice or abuse of power.

(5) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.

(6) Involve trade secrets.

(7) Other circumstances prescribed by laws and regulations of the people's Republic of China.

7、 If this page decides to stop operation, we will stop collecting your personal information after the relevant services cease operation. We will send you a notice of suspension of operation in the form of an announcement. Personal information already held will be deleted or anonymized.

We will usually deal with your above request within 15 working days.

We do not charge for your reasonable request in principle, but we will charge a certain cost for repeated requests that exceed the reasonable limit as appropriate. We may reject requests that are repetitive for no reason, require too much technical means (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very unrealistic.

五、 How do we protect children's personal information?

Children (under the age of 14) are not allowed to create this web account without the consent of their parents or guardians. If your patient is a child, it is recommended that you ask the child's parent or guardian to read this Privacy Policy carefully and use our products or services or provide us with personal information with the consent of the child's parent or guardian. In cases where personal information is collected with the consent of a parent or guardian to use our products or services, we will only use, share, transfer or disclose this information as permitted by laws and regulations, with the express consent of the parent or guardian, or as necessary for the protection of the child.

六、 How do you and the personal information you provide transfer around the world?

1、 In principle, the personal information we collect and generate in the people's Republic of China will be stored in the territory of the people's Republic of China.

2、 Since we provide products or services through resources and servers around the world, this means that your personal information may be transferred to or accessed from outside the jurisdiction of the country in which you use the product or service. We share you and your personal information only when necessary and for the purposes indicated in this Privacy Policy. If any of our affiliates want to change the stated purpose, they need to obtain your consent separately, and if the patient's personal information is involved, the patient's authorization will be obtained through you or by us.

3、 In accordance with this Privacy Policy, you agree that the above personal information may be transmitted to any country in which our affiliated companies operate and may be processed by us and / or affiliated companies. If you and the personal information you provide will be shared / transmitted to affiliated companies or entrusted third parties outside China, we will ensure that: (1) provide a sufficient level of protection for you and your personal data in a foreign country; and (2) strictly abide by China's laws and regulations on cross-border data transmission.

This Privacy Policy and the processing of personal information data in accordance with this Privacy Policy shall be governed by and interpreted in accordance with the laws of the people's Republic of China. No matter where we process the data of you and the personal information you provide, we will take reasonable measures to protect the privacy of you and your personal information.

七、 How do we revise and update this privacy policy?

1、 We may revise or update this Privacy Policy (referred to as "changes") from time to time in accordance with the changes in laws and regulations of the people's Republic of China and the needs of maintaining transaction order and protecting the rights and interests of consumers, and inform you by public announcement or by means of push notice. You can check or download the latest version at any time from the bottom of this page.

2、 If you do not agree to the change, you have the right to give us feedback through our disclosed contact information. If the feedback is accepted, we will adjust the changes as appropriate.

3、 If you still disagree with the changes that have taken effect, you shall stop using this page from the effective date determined by the changes, and the changes shall not have effect on you; if you continue to use this page after the changes have taken effect, you shall be deemed to have agreed to the changes that have taken effect.

八、 How to contact us?

If you have any questions or suggestions about this page or this Privacy Policy, or if you wish to make any complaint about this page or its content, please contact us at dongfangjiayue@smilener.cn and we will deal with it within 15 working days.