(September 23, 2022)

TG ImmunoPharma (hereinafter referred to as “We”) respects the privacy of the users of our Website and of applications or services related to this Privacy Policy. This Privacy Policy explains what information we might collect about users and how we will collect, use and disclose personal information of users. By using this Website, you acknowledge and accept the terms of this Privacy Policy.

Ⅰ.   What personal information we will collect and use and the scenarios in which it is collected and used

(Ⅰ)   Definition of personal information

We may collect personal information about you from you or your device, as defined below.

Personal information refers to all kinds of information recorded electronically or by other means that can identify the identity of a particular natural person independently or in combination with other information.

Personal sensitive information refers to personal information that may endanger the personal and property safety, easily lead to damage to personal reputation, physical or mental health or discriminatory treatment in case of disclosure, illegal provision or abuse.

(Ⅱ)   Collection and use scenarios of personal information

Customer Service: If you contact us directly, we will collect your personal information. For example, when you contact us for support, we will collect your name, contact number, and email address.

Account security: In order to improve the security of the system when you use our products or services, we will record your service log information, including your IP address, device information, operating system version and browser type.

Job information processing: If you decide to send a job application, you may submit your contact information and resume online. We will collect the resume information you choose to provide, such as your contact information, education and employment history, as part of your job application. If you apply to us through a third party platform, we will collect the personal information you provide to us through the third party platform.

User feedback: To help us understand how you use our services and help us improve the content of our services, we will automatically receive information about your usage, such as the time you spend on a certain page, the objects you click on, and the date, number, and duration of the sessions. When we send you an email, we may follow up whether you read the email, so as to provide better customer experience.

(Ⅲ)   You are fully aware that we may collect and use your personal information without your authorization under the following circumstances

According to relevant laws and regulations, we may collect your personal information without your consent in any of the following cases:

1.  Information related to our performance of obligations under laws and regulations;

2.  Information related to national security and national defense security;

3.  Information related to public security, public health and significant public interests;

4.  Information related to criminal investigations, prosecutions, trial, judgment execution, etc.;

5.  Information collected to safeguard the life, property and other significant legal rights and interests of you or other individuals when it is difficult to obtain your consent;

6.  Personal information disclosed to the public at your will;

7.  Personal information collected from publicly disclosed information via lawful channels such as news report or government information release;

8.  Information necessary for maintaining the safe and stable operation of the products or services provided, such as for finding and handling the faults of the products or services;

9.  Other circumstances stipulated in laws and administrative regulations.

Ⅱ.   Use of Cookies and similar technologies

1.  When you use the services provided by us, we may collect and use Cookies to help us understand your access to and use of our Website over a period of time.

2.  A Cookie is a small text file that contains a string of alphanumeric characters. Cookies are often classified as “session” cookies or “persistent” cookies. “Session” cookies help you effectively browse our Website and track your page-to-page progress, so that you do not need to repeatedly provide the same information for the current visit.

3.  We do not use Cookies for any purpose other than those described in this Policy, and most browsers accept Cookies automatically. You can view “Help” file of the web browser to learn how to correctly modify your cookie settings. Please note that if you delete or choose not to accept cookies from a service, you may not be able to fully utilize the features of the service.

Ⅲ.   How do we share, transfer and disclose your information

（Ⅰ）   Personal information sharing

1.  We will strictly limit the sharing of information in accordance with laws and regulations, and we will not actively share your personal information with any company, organization or individual other than ourselves, except in the following cases:

1)  We may share your personal information with third parties who provide various services on our behalf in order to ensure our products and/or services;

2)  We may share your personal information with third party partners for marketing purposes;

3) We may share your personal information to comply with applicable laws, regulations, regulatory requirements, court judgments, arbitration awards, administrative orders or other legal procedural requirements, or to cooperate with the legal investigation requirements of government departments;

4)  We may share your personal information to protect the interests, property or safety of us, our affiliates or partners, you or other users and the public from damage within the scope permitted by laws and regulations when necessary;

5)  We may share your personal information to handle your disputes with others at your request;

6)  We may share your personal information in accordance with the relevant agreements signed with you (including the electronic agreements signed online and the corresponding user agreements) or other legal documents provided;

7)  We may share your personal information based on the public interests in accordance with laws and regulations.

2.  We may share your personal information with our affiliates. However, we will only share necessary personal information for the purposes stated in this Privacy Policy, and we will guarantee that our affiliates abide by the same principles of external sharing.|

3.  You agree that we may share your personal information with third party partners for purposes such as external processing, so that they may process the above information for us in accordance with this Privacy Policy and other relevant confidentiality and security measures and for the following purposes:

1)  to provide you with our services;

2)  to realize the purposes set forth in the above section “What personal information we will collect and use and the scenarios in which it is collected and used”;

3)  to fulfill our obligations and exercise our rights under the User Agreement and this Privacy Policy;

4)  to understand, maintain and improve our services.

However, we will only share your personal information for lawful, legitimate, necessary, specific and explicit purposes, and will only share the personal information necessary for providing our services.

We may also share your personal information with third parties that support our features, including providing infrastructure technical services, maintenance and repair and data processing for our products and services. We share this information for the purpose of implementing core functions of our products and/or services or improving and optimizing our products and/or services.

4.  For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements requiring them to handle your personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

(Ⅱ)   Personal information transfer

We will not transfer your personal information to any company, organization or individual except in the following circumstance:

1.  Transfer with your express consent;

2.  We provide your personal information according to applicable laws and regulations, or the requirements of legal procedures, or mandatory administrative or judicial requirements;

3.  We may transfer your personal information in accordance with the relevant agreements signed with you (including the electronic agreements signed online and the corresponding user agreements) or other legal documents;

4.  When any merger, acquisition or bankruptcy liquidation is involved, we will require any new company or organization holding your personal information to continue to be bound by this Policy in case of any transfer of personal information; otherwise we will require such company or organization to re-seek your authorization or consent.

(Ⅲ)   Personal information disclosure

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

1.  Disclosure with your express consent;

2.  Disclosure of your personal information for the purpose of implementing the User Agreement or this Policy, safeguarding the national security or public interests, and protecting the personal and property safety or other legitimate rights and interests of our customers, ourselves or our affiliates, other users or employees, and other reasonable and necessary purposes;

3.  Subject to laws and regulations, when we receive a request for such disclosure required by laws, regulations, mandatory administrative enforcement or judicial requirements, we will require that a legal document, such as a subpoena or letter of inquiry, be issued. We will carefully review relevant requests to ensure that they have a legal basis and the information disclosed is limited to data that law enforcement has a legal right to obtain for specific investigative purposes;

4.  According to legal provisions, sharing and transferring personal information that has been anonymized, on condition that it is ensured that the data receiver cannot recover and re-identify the subject of the personal information, are not considered as external sharing, transfer and public disclosure of personal information, and the storage and processing of such data will not need to be notified to you and obtain your consent.

Ⅳ.   How do we store your personal information

(Ⅰ)   Information storage and cross-border transmission

Your personal information we collect will be stored in the territory of the People's Republic of China. For cross-border transmission, we will obtain your authorization and consent separately. Before cross-border transmission, we will take appropriate measures to protect your personal information in accordance with relevant laws and regulations. You may withdraw the consent at any time, but the withdrawal of consent will not affect the legality of processing under the consent prior to withdrawal.

(Ⅱ)   Information storage period

In order to maintain the continuity of our services and your user experience, we will retain your personal information for a reasonable period of time based on the purpose of providing the services. You may contact us for information deletion in accordance with Article 11 of this Policy.

Ⅴ.   How do we protect your personal information

1.   Security measures we take to protect your personal information

We will protect your personal information by physical and electronic security measures to improve the security of the personal information we maintain.

We will use SSL encryption protocols in our network transmission services to protect your personal information, and provide secure browsing services using HTTPS to ensure the security of data during transmission.

We also make strict management on employees or outsourcing personnel who may have access to your information, including but not limited to taking different authority controls according to different positions, signing confidentiality agreements and monitoring their operation. Users can query and manage user information and resources only after being authenticated and cannot manage the user resources without authentication.

We have special information security protection department and information security emergency response organization to promote and protect personal information security.

We will regularly launch training courses on security and personal information protection to enhance employees' awareness of the importance of protecting personal information.

2.   Security incident handling

The Internet environment is not absolutely secure, but we will do our best to ensure or guarantee the security of any information you send us. Please note, however, that no data transmission or storage can be guaranteed to be absolutely secure.

In the event of an unfortunate personal information security incident, we will, as required by laws and regulations, promptly inform you of the basic information and possible impact of the security incident, the handling measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, and remedies for you. We will inform you of the relevant information by email, letter, telephone, SMS, push notification, or other means. If it is difficult for us to inform the subjects of personal information one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we may also report the handling of the personal information security incident in accordance with the requirements of the regulatory authorities.

3.   You are also obliged to secure your account

Please properly protect your personal information and only provide it to others when necessary. If you find that your personal information has been leaked or may leak, and may jeopardize your account security, or cause you other losses, please be sure to contact us by the contact information mentioned in this Privacy Policy as soon as possible, so that we can take corresponding measures to maintain the security of your account and prevent the occurrence or further expansion of losses

Ⅵ.   How do we handle minors' personal information

This Website is not designed for use by minors under the age of 18. If you are under 14 years of age, please do not submit any personal data through the Website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 14 has provided personal information to us through this Website, please contact us at contact@tgimmunopharma.com, and we will endeavor to delete that information from our databases.

Ⅶ.   Your rights and choices

1.  You may request access to and inquire about your personal information held by us, update and correct inaccuracies in your personal information, restrict or refuse the processing of your personal information, have your personal information deleted, and cancel your account.

2.  You may withdraw any consent you previously provided to us regarding the processing of your personal information at any time.

Ⅷ.   Response to your above request

You may exercise these rights by contacting us using the contact information in Article 11 of this Privacy Policy. Before satisfying your request, we may require you to provide a written application to verify your identity.

For the above request you make to us, we will process it within 15 days after you make the request.

In the following circumstances, we may not be able to respond to your request due to the requirements of laws and regulations:

1.  Such request is related to our performance of obligations under laws and regulations;

2.  Such request is directly related to national security and national defense security;

3.  Such request is directly related to public security, public health and significant public interests;

4.  Such request is directly related to criminal investigations, prosecutions, judgment and judgment enforcement;

5.  There is sufficient evidence that the subject of personal information has subjective malice or is abusing his/her right;

6.  The rejection is made to safeguard the life, property and other significant legal rights and interests of the subject of personal information or other individuals when it is difficult to obtain the consent of the subject of personal information;

7.  Responding to your request will cause your or other individuals’ or organizations’ lawful rights and interests to be seriously damaged;

8.  Such request involves any trade secret.

Ⅸ.   How is this Policy updated

1.  We reserve the right to amend this Policy at any time. We will post any changes to this Privacy Policy on our Website. You may inquire about these changes on our Website at any time, and you have the right to ask us to delete the personal information you previously provided to us.

2.  In case of any significant change, we will provide a more conspicuous notice (we will give notice by webpage reminder to explain the specific changed contents of the Privacy Policy).

For the purpose hereof, significant changes include, but are not limited to, the following:

1)  Significant change occurs to our service model, such as, the purpose of processing personal information, the type of processed personal information, and the manner of use of personal information;

2) Significant change occurs to our ownership structure, such as owners’ change arising from business adjustment or bankruptcy merger and acquisition;

3)  Change occurs to major subjects of public disclosure of personal information;

4)  Significant change occurs to your right to participate in the processing of personal information and the manner of exercise of such right;

5)  Change occurs to our department responsible for handling the security of personal information, our contact information and our complaint channel;

6)  A report on the security impact assessment of personal information shows that there is high risk.

Ⅹ.   Third-party disclaimer

Our services may contain links to other websites, products or services not operated or owned by us. We are not responsible for the privacy protection and advertising practices of these third parties. Please note that this Privacy Policy does not apply to your activities on these third-party services or to any personal information you disclose to these third parties. We advise you to read their privacy policies before providing them with any personal information.

Ⅺ.   Contact Us

If you have any doubt about this Policy or our privacy protection practices, you may contact us in the following manner:

Personal privacy protection email:  contact@tgimmunopharma.com

We will review the issue as soon as possible and respond to your request after verifying your user identity.