Privacy Policy

This Privacy Policy supersedes and replaces all prior versions.

Smilelinked HealthTech Limited (hereinafter referred to as "Smilelinked," "we," and "our") understands the importance of privacy to you and respects your privacy. We have established this Privacy Policy (hereinafter referred to as the "Privacy Policy" or "this Policy") to inform you how we handle personally identifiable information and other information collected and stored through the Smilelinked website or mobile application ("https://smilelinked.com,""https://www.smilelinked.com," collectively referred to as the "Smilelinked Website").Please read and understand this Policy before submitting personal information to Smilelinked Technology. This Policy applies solely to information collected by Smilelinked Technology through the Smilelinked Website and does not apply to information you post in public areas or on third-party websites, except as otherwise provided herein. When using the Smilelinked Website and Smilelinked Technology services, your personal information will be governed by the privacy-related laws and regulations of the People's Republic of China, where Smilelinked Technology has its principal place of business.

This Policy describes how SmileLinked processes your personal information, but it may not cover all possible data processing scenarios. Information regarding the collection of specific data for particular products or services may be provided in dedicated privacy notices or supplemental statements issued by SmileLinked for those specific products or services, or in notices provided at the time of data collection.

If you are a minor, you should read this Privacy Policy with your guardian before using our products and/or services. You should ensure you have obtained your guardian's consent before using our services and providing us with your information. We will focus on protecting minors' personal information in accordance with relevant national laws and regulations.

1. Why We Collect Personal Information (Purpose)

SmileLinked collects personal information to provide optimized and personalized services by verifying users' identities and their intent to use SmileLinked services. During initial membership registration, SmileLinked collects only the minimum information necessary to perform the basic functions of SmileLinked services. Subsequently, based on users' usage of services provided by SmileLinked, additional necessary information related to payments, product delivery, and refunds may be collected.

Certain required data may be mandated by law (e.g., tax laws, medical device regulations) or contractual obligations. Such personal information will be collected, processed, stored, used, and disclosed in accordance with relevant legal provisions. Unless required by law to collect, process, store, or disclose certain personal information, your provision of personal information is voluntary.

2. Methods of Collecting Personal Information

Personal information refers to any information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding information that has been anonymized. We may collect your personal information when you use SmileLinked products and services or interact with us. The specific types of data collected will vary depending on the products and services you use and the nature of your interactions with us.You are not required to provide personal information to SmileLinked. However, in certain circumstances, if you choose not to provide it, SmileLinked may be unable to provide you with relevant products or services, or respond to or resolve issues you encounter. SmileLinked will only collect and use your personal information for the purposes described in this Statement. The personal information we may collect includes:

2.1 Information You Provide to SmileLinked

(1) Account registration information. When registering an account, we will ask you to provide relevant personal information, including your name, account, password, email address, contact number, etc.

(2) Personal contact information. When you contact us, provide feedback, suggestions, or inquiries, participate in our online or offline activities, or subscribe to marketing materials, you may provide your contact information, including your name, company name, job title, email address, phone number, etc.

2.2 Information obtained during your interactions with us or use of our products and services

(1) Device and Network Information. We collect information about the device you use when interacting with SmileLinked products and services, such as device type, device name or model, device identifier, operating system type and version, browser type and version, screen resolution, language settings, IP address, internet service provider, and other technical information specific to the product.

(2) Interaction Records. This information is directly submitted to us when you use our websites, products, or services, or interact with us. Examples include information requests you provide, such as queries you enter or questions/details submitted for customer support. It also encompasses communication records from online interactions, phone calls, emails, or participation in online/offline events.

(3) Log Information. When you use SmileLinked's products and services or view content provided by SmileLinked, SmileLinked automatically collects and stores necessary log information. This includes each service access time, page paths visited, client IP addresses, and event information (such as errors, crashes, restarts, or upgrades).

2.3 Third-Party and Publicly Available Information

Where permitted by law, we may also obtain data from public and commercial third parties or public sources. For example, we may purchase statistical data from other companies to support our services.

SmileLinked may also collect and use non-identifiable data. Non-identifiable data refers to information that cannot be used to identify an individual. For example, SmileLinked collects aggregated statistics such as website traffic. The purpose of collecting this data is to understand how users interact with our websites, products, and services.This enables SmileLinked to improve its services and better meet customer needs. SmileLinked may collect, use, process, transfer, or disclose non-identifiable data for other purposes at its sole discretion. We strive to keep your personal information and non-identifiable data separate and use them independently. If personal information is mixed with non-identifiable data, it will still be treated as personal information.

3. How We Use Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

(1) To fulfill or satisfy the purpose for which you provided the information. For example, if you provide your name and contact details to request a quote or inquire about our services, we will use this personal information to respond to your inquiry. If you provide personal information to purchase services, we will use it to process your payment and arrange delivery. We may also retain your information to facilitate future product orders, returns, or warranty processing.

(2) To provide, support, personalize, and improve the Smilelinked website, SmileLink Technology services, and all existing and new services.

(3) To create, maintain, customize, and secure any account you may register with us.

(4) To process your requests, purchases, transactions, and payments, and to prevent transaction fraud.

(5) To provide you with support and respond to your inquiries, including investigating and resolving your issues, and monitoring and improving our responses.

(6) To personalize your Smilelinked website experience and provide relevant content and services based on your interests, including delivering targeted offers and advertisements to you via the Smilelinked website, third-party websites, and via email or SMS (where required by law, with your prior consent).

(7) To maintain the security, integrity, and reliability of the Smilelinked website, products, and services.

(8) For testing, research, analysis, and product development, including improving the Smilelinked website and SmileLinked Technology services.

(9) To respond to requests from law enforcement agencies and comply with applicable laws, court orders, or government regulations.

(10) To use your personal information for the purposes described at the time of collection or for other purposes permitted by applicable privacy laws.

We will not collect additional categories of personal information without notifying you, nor will we use collected personal information for purposes that are materially different, unrelated, or incompatible with the original purpose.

4. How We Use Uploaded Data

When you upload data to this product, we may use such data to improve our products and services, including:

(1) Training and optimizing machine learning models;

(2) Conducting data analysis and research to enhance the product experience;

(3) Enhancing product features and optimizing services.

If your data contains personal information, we will obtain your explicit consent before use and anonymize the data to the greatest extent possible to prevent identification of individuals.

We commit to using your data solely for the purposes described above and implement reasonable technical and administrative measures to protect data security. You may withdraw your consent at any time and request deletion of your data.

5. Cookies Policy

5.1 Cookies

Cookies are small text files that enable us to distinguish you from other users by reading the information they contain. This facilitates your visit, collects statistical data, and supports personalized online experiences.

When you visit the Smilelinked website, we may assign one or more cookies to your computer. By accessing the Smilelinked website, you consent to our placement of cookies on your computer or device.

The Smilelinked website currently uses cookies for purposes including but not limited to: detecting your web browser's multimedia capabilities, tracking promotional advertisements displayed to you, storing current login and purchase information in secure sections of the website, and providing your computer or device with a unique identifier so we can generate statistics regarding Smilelinked website usage.

Most browsers automatically accept cookies, but you can refuse cookies by modifying your browser settings. For details about cookies and changing browser settings to refuse cookies, visit your browser's "Help" menu. If you do not accept cookies from the Smilelinked website, you may not be able to use all features of the website, resulting in certain functions being limited or unavailable.

5.2 Website Beacons and Pixel Tags

In addition to cookies, we use other similar technologies on our website, such as web beacons and pixel tags. For example, emails we send to you may contain click-through URLs linking to Smilelinked website content. If you click such a link, we track the click to help us understand your product or service preferences and improve customer service.Web beacons are typically transparent images embedded in websites or emails. Pixel tags in emails allow us to determine whether an email has been opened. If you do not wish your activities to be tracked in this manner, you may unsubscribe from our mailing list at any time.

5.3 Do Not Track

Many web browsers include a Do Not Track feature that sends a Do Not Track request to websites. Currently, major internet standards organizations have not established policies requiring websites to respond to such requests. However, if your browser has Do Not Track enabled, all our websites will respect your choice.

6. Entrustment, Sharing, Transfer, and Disclosure of Personal Information

6.1 Entrusted Processing

To enhance service efficiency, we may entrust third parties to process the personal information you provide on our behalf. For third parties entrusted with processing personal information, we will enter into entrustment processing agreements requiring them to process your personal information in accordance with the terms of the agreement, this Policy, and relevant Chinese data laws and regulations.

6.2 Sharing

We strictly limit information sharing in compliance with laws and regulations. We will not proactively share your personal information with any company, organization, or individual other than ourselves, except in the following circumstances:

(1) We may share your personal information with other partner organizations upon obtaining your explicit consent;

(2) We may report or share your personal information externally as required by laws and regulations, or in response to mandatory requests from government agencies, judicial authorities, industry associations, or similar entities;

(3) Within the scope permitted by laws and regulations, we may provide your information when it is necessary to protect the interests, property, or safety of us, our affiliates or partners, you, other users, or the public from harm;

(4) Sharing your information is essential to enable the core functionality of our products and/or services or to provide services you request;

(5) To assist in resolving disputes or conflicts between you and others at your request;

(6) To fulfill obligations under agreements signed with you (including online electronic agreements and corresponding user agreements) or other legal documents;

(7) For academic research purposes;

(8) Use is based on public interests that comply with laws and regulations.

6.3 Transfer

We will not transfer your personal information to any company, organization, or individual outside of SmileLinked, except in the following circumstances:

(1) Transfer with explicit consent: We will transfer your personal information to other parties after obtaining your explicit consent;

(2) In cases of merger, division, dissolution, or bankruptcy declaration: If personal information transfer is involved, we will inform you of the name and contact details of the new company or organization holding your personal information. Such entity shall continue to be bound by this Privacy Policy and other legal obligations. Should such company or organization alter the original processing purpose or method, it must obtain your authorization and consent anew, unless otherwise stipulated by laws and regulations;

(3) When required by applicable laws and regulations, legal proceedings, or mandatory administrative or judicial requirements;

(4) When required to comply with the terms of relevant agreements signed with you (including online electronic agreements and corresponding user agreements) or other legal documents.

6.4 Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

(1) After obtaining your separate consent;

(2) Disclosure required by law: We may publicly disclose your personal information when required by law, legal proceedings, litigation, or mandatory requests from government authorities.

In compliance with applicable laws and regulations, when we receive requests for disclosure required by law, regulations, or mandatory administrative or judicial enforcement, we will require the relevant authorities to provide corresponding legal documents, such as subpoenas or letters of inquiry. We will conduct a careful review of such requests to ensure they have a legal basis, and the information we disclose will be limited to data that law enforcement agencies have a legitimate right to obtain for specific investigative purposes.

7. Storage of Personal Information

7.1 Location of Information Storage:

Personal information collected and generated during our operations within the People's Republic of China is stored within China, except in the following circumstances:

(1) Where explicitly required by laws and regulations;

(2) Where we have obtained your explicit authorization.

In the above circumstances, we will ensure that your personal information receives adequate protection in accordance with this Privacy Policy.

7.2 Duration of Information Storage:

We will retain your personal information only for the shortest period necessary to achieve the purposes stated in this Policy, unless mandatory retention requirements under applicable laws exist. Our criteria for determining the aforementioned period include:

(1) After your personal information exceeds the retention period, we will delete it or anonymize it in accordance with applicable legal requirements;

(2) To fulfill service purposes related to you, maintain corresponding service and business records, and address any inquiries or complaints you may have;

(3) Ensuring the security and quality of our services to you;

(4) Whether you have consented to a longer retention period;

(5) Whether there are other special agreements regarding the retention period.

7.3 Cessation of Operations

Should Smilelinked decide to cease operations, we will stop collecting your personal information after the relevant services are discontinued. We will notify you of the cessation of operations via public announcement and will delete or anonymize the personal information we hold about you.

8. Protection of Personal Information

8.1 We employ industry-standard security measures to protect the personal information you provide against unauthorized access, disclosure, use, alteration, damage, or loss. We take all reasonable and feasible measures to safeguard your personal information. For example:We also provide HTTPS secure browsing for the Smilelinked website; we use encryption technology to ensure data confidentiality (especially when involving children's personal information); we employ trusted protection mechanisms to prevent malicious attacks; we deploy access control mechanisms to ensure only authorized personnel can access personal information; and we conduct security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

8.2 We take all reasonable and feasible measures to ensure we do not collect irrelevant personal information. We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.

8.3 The internet is not an absolutely secure environment, and communications via email, instant messaging, and other methods with other SmileLinked users are not encrypted. We strongly advise against sending personal information through such channels. Please use complex passwords to help us ensure the security of your account.

8.4 In the unfortunate event of a personal information security incident, we will promptly notify you in accordance with legal requirements. This notification will include: the basic details and potential impact of the security incident; the measures we have taken or will take to address it; recommendations for you to independently prevent and mitigate risks; and the remedial measures available to you.We will promptly notify you of the incident via email, letter, phone call, push notification, or other means. When it is impractical to notify each individual data subject individually, we will publish an announcement through reasonable and effective channels. Additionally, we will report the handling of the personal information security incident to the relevant authorities as required by laws and regulations.

9. Transfer of Personal Information to Other Countries

In principle, personal information collected and generated within the People's Republic of China will be stored within the People's Republic of China, except where permitted by applicable Chinese laws and regulations or with your authorization and consent.

Due to our international operations, your personal information may be transferred and stored on servers outside the jurisdiction of your residence after meeting Chinese legal requirements and obtaining your authorization and consent. This is to enable our affiliated companies to process the personal information you provide to us under this Policy for the purposes and in the manner outlined herein. However, we will continue to protect your information in accordance with this Policy.You may exercise your rights under applicable Chinese law by contacting us at www.smilelinked.com@gmail.com.

This Privacy Policy and the collection and processing of information conducted pursuant to this Privacy Policy shall be governed by and construed in accordance with the laws of the People's Republic of China. Regardless of where we transfer, store, or process your personal information, we will take reasonable measures to protect the privacy of the personal information you provide.

10. Processing of Children's Personal Information

Our products, websites, and services are primarily intended for adults. Children (minors under the age of 14) may not create their own user accounts without parental or guardian consent. Where we collect children's personal information with parental consent, we will only use or disclose such data when permitted by law, explicitly authorized by the parent or guardian, or necessary to protect the child. If we discover that we have collected personal information from a child without first obtaining verifiable parental consent, we will make every effort to delete the relevant data as soon as possible.

11. Your (or Your Legal Representative's) Rights and Obligations Regarding Personal Information and How to Exercise Them

In addition to the rights specified in this Privacy Policy, you and your legal representative have the following rights:

(1) The right to object to the processing of your personal information for legitimate reasons;

(2) The right to inquire about, correct, modify, and withdraw the personal information you or your legal representative provided to SmileLinked;

(3) Upon providing identity verification, the right to access the following information: whether SmileLinked is processing your personal information, the purpose of processing, the categories of personal information being processed, recipients of the personal information, locations where the personal information is transmitted or processed, the means by which the personal information was transmitted to SmileLinked, and, where the personal information is processed automatically, information about the logic involved in the processing (to the extent such processing directly affects SmileLinked's decisions);

(4) The right to modify, correct, supplement, update, lock, or delete any inaccurate, incomplete, ambiguous, outdated, or expired personal information; or personal information prohibited from collection, use, transmission, or retention under applicable law; or personal information inconsistent with the original collection purpose or subsequent authorized purpose.

You and your legal representative may exercise the rights listed in this clause to SmileLinked via written correspondence, email, fax, or other communication methods. In accordance with Article 45 of the Personal Information Protection Law of the People's Republic of China, we will promptly process your request.

We may refuse to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (e.g., involving information on backup tapes), jeopardize the privacy or rights of others, are extremely impractical, or for which access is not required by law.

12. How This Policy Is Updated

Our privacy policy may change.

We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes to this policy on this page.

For material changes, we will also provide more prominent notice describing the specific changes to the privacy policy. Material changes to this policy include, but are not limited to:

(1) Significant changes to our service model, such as the purpose of processing personal information, the types of personal information processed, or how personal information is used;

(2) Significant changes in our ownership structure or organizational framework, such as changes in ownership due to business restructuring, bankruptcy, or mergers and acquisitions;

(3) Changes to the primary recipients of personal information sharing, transfer, or public disclosure;

(4) Significant changes to your rights regarding personal information processing and the methods for exercising those rights;

(5) Changes to the department responsible for personal information security, its contact information, or complaint channels;

( 6) When the Personal Information Security Impact Assessment Report indicates high risk.

Your continued use of the Smilelinked website after the revised Privacy Policy takes effect constitutes your acknowledgment that you have read, understood, and agreed to the current version of this Privacy Policy. The revised Privacy Policy takes effect on the date specified below. We will also archive previous versions of this policy for your reference.

13. How to Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, please contact us via the following methods:

Company Name: SmileLinked HeatlthTech Limited

Address: RM C03, 9/F KATO FACTORY BLDG, 2 CHEUNG YUE ST LAI CHI KOK, HONG KONG.

Email: www.smilelinked.com@gmail.com