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1. 信息处理者及联络信息Responsible party and contact information

信息处理者Responsible party:

保赫曼(上海)贸易有限公司PAUL HARTMANN Shanghai Trade Co., Ltd.

联系电话 Phone:+86-21-54263226

个人信息保护负责联系人Contact Data Protection: 龚丹丹女士Ms. Dandan Gong

保赫曼(上海)贸易有限公司PAUL HARTMANN Shanghai Trade Co., Ltd.

部门Department: 合规部 Compliance Dept.

2. 处理合法基础和目的Legal bases and purposes of data processing


We process your personal data in accordance with the provisions of the Personal Information Protection Law of People’s Republic of Chinahereinafter refer to as “PIP Law” and other applicable data protection regulations. You will find details under the following explanations.

2.1履行合同必须 (根据《个保法》第13条(2)款)

Where it is necessary for the conclusion or performance of a contract (cf. Art. 13(2) of PIP Law)


We process your personal data in particular for the following purposes:


Implementation of registration processes;


Fulfilment of contractual obligations and services, memberships;


Execution of payment transactions;


Delivery of contractually ordered products and services;


Transfer of address data to logistics companies for the delivery and collection of goods;


Transfer of billing data to billing centres and forwarding to cost units.

2.2 取得您同意的目的(根据《个保法》第13条(1)款)

Purposes within the scope of your consent (cf. Art. 13 (1) of PIP Law)

在您同意的情况下,您的个人信息也可能会出于某些目的进行处理。 这可能包括作为服务提供商的我们特别是出于咨询目的(例如在电话的情况下)处理您的健康数据及提供交付我们的产品以及护理辅助工具(如果适用)。 在这种情况下,除其他信息外,我们会处理有关补救措施和药物的处方信息(您发送给我们或上传到您的帐户)以及(您通过电话或通过您的帐户)作为关于失禁类型、适应症、失禁概况、护理程度等的病史信息。

Your personal data may also be processed for certain purposes on the basis of your consent. This may include – for us as a service provider – in particular the processing of your health data for consulting purposes (e.g. in the context of a telephone call) and supply or delivery of our products and, if applicable, care aids. In this context, we process, among other things, information on prescriptions (which you have sent to us or uploaded in your account) about remedies and medicines and information (which you have given us in a telephone call or via your account) as part of the collection of medical history forms on the type of incontinence, indication, continence profile, degree of care, etc.


We process your personal data in particular for the following purposes:


Transfer to group companies for internal administrative purposes;


Sending of interesting information about products and promotions;


Forwarding to manufacturers, suppliers and service companies for custom-made products and for instruction and maintenance of the respective product;


Business partner due diligence;


Obtaining creditworthiness information;


Statistical evaluations for corporate management;


Customer satisfaction survey;


Exclusive customer information on products and advertising materials;


Product training courses;


Measures for controlling and optimizing business processes;


Measures for the further development of services and products;


Testing and optimisation of procedures for demand analysis;


Enrichment of our data, e.g. by using or researching publicly available data as far as necessary;




Assertion of legal claims and defence in the event of legal disputes which are not directly attributable to the contractual relationship;


Building and plant security, securing and exercising of the right to the building by taking appropriate measures (e.g. access controls) and, if necessary, by video surveillance to protect third parties and our employees and to prevent criminal offences and to secure evidence for the investigation of criminal offences, insofar as this goes beyond the general duty of care;


Further development of existing systems and processes;


Internal and external investigations, security checks, publications;


Obtaining and maintaining certifications of a private or official nature.

您可以随时撤回您的同意。原则上,任何时候撤回同意仅对将来有效。 撤回前进行的处理不受影响,因此仍然合法。 这意味着在退出之前的一段时间内对您的健康数据的处理用于上述目的仍然有效。

You can withdraw your consent at any time. In principle, the withdrawal of consent at any time is only valid for the future. Processings that took place before the withdrawal are not affected and therefore remains lawful. This means, for example, that the processing of your health data in the period prior to the withdrawal – among other things for the aforementioned purpose – remains effective.


In all other respects you are not obliged to grant consent and you will not suffer any legal disadvantages from the refusal of consent.

2.3 履行法定义务或为公共利益目的(根据《个保法》第13条(3)、(4))

Purposes to meet legal requirements or purposes in the public interest (cf. Art. 133)(4of PIP Law)

参与经济活动中,我们也承担着各种法律义务。 这些主要是法律要求以及适用的监管或其他官方要求(例如,社会保险)。 此外,为了收集证据、刑事起诉或执行民法索赔,在官方/司法措施范围内可能需要披露个人信息。

Like everyone who is involved in the economic process, we are also subject to a variety of legal obligations. These are primarily legal requirements, but also, where applicable, regulatory or other official requirements (e.g. employers' liability insurance). In addition, the disclosure of personal data may become necessary within the scope of official/judicial measures for the purpose of gathering evidence, criminal prosecution or the enforcement of civil law claims.

3. 我们处理个人信息的种类和来源Categories and origin of the personal data we process


Insofar as it is necessary for the decision on the establishment of a contractual relationship with you, we process, in addition to the personal data received directly from you, any legally obtained personal data from third parties (see Art. 132of PIP Law).


We process in particular the following data categories:


Stock data (e.g. first and last name, title, residential address, country, company address, date of birth, full legal capacity, industry);


Contact data (e.g. e-mail address, telephone number fixed/mobile, fax number);


Content data (e.g. text input contact form, photographs, videos);


Contract data (e.g. subject matter of the contract, duration, customer category, user name), in particular for the fulfilment of our contractual obligations and services and on the basis of your consent (e.g. in the context of customer satisfaction surveys


Payment data (e.g. bank details, account details, credit card details, payment history);


Health data (e.g. severely disabled status, general physical condition, diagnosis).

4. 您的个人信息的接收方类别

Recipients or categories of recipients of your personal data

我们仅在公司内部处理您的个人信息。 需要个人信息来实现处理范围内的目的,我们公司内部部门会收到您的个人信息。 内部数据接收者有义务仅在上述范围内使用您的个人信息。

We only process your personal data within the company. Within our company, those internal departments or organisational units receive your personal data insofar as they need it to fulfil the purpose and within the scope of processing. Internal data recipients are obliged in each case to use your personal data only to the aforementioned extent.

若我们将您的个人信息转移给其他人、公司或其他第三方(例如公共健康保险)或授予他们对个人信息的其他访问权限,只有在获得法律许可的情况下才会这样做。 如果我们委托第三方根据“处理协议”处理个人信息,会确保对个人信息的处理和使用具有必要的影响或控制权, 我们仍然处理数据的合法性对您负责。

If we transfer your personal data to other persons, companies or other third parties (e.g. public health insurance) or grant them other access to the personal data, this is only done on the basis of a legal permission. If we commission third parties to process personal data on the basis of a so-called "contract processing agreement" and thereby secure the necessary powers of influence or control with regard to the processing and use of the personal data, this is done on the basis of Art. 21 PIP Law. However, we remain responsible to you for the legality of the data processing.

5. 您个人信息的存储Storage of your personal data



We process or store your personal data in principle for the duration of the contractual relationship. The above information on deletion does not apply if, among other things, legally prescribed retention periods prevent immediate deletion and/or a further case of Art. 13 of PIP law exists and/or a new purpose justifies further processing.

Incorrect and/or incomplete data will be deleted or - if possible - corrected immediately in accordance with Art.46,47 of PIP Law.

6. 跨境处理您的个人信息Processing your personal data in a third country



Where possible, we will process your personal data on the territory of the People’s Republic of China. If, however, processing – and thus at the same time transfer – of your personal data to third countries is necessary, especially in connection with the use of service providers in the context of contract processing, we will ensure that the special legal requirements for such processing operations are met and that an adequate level of data protection prevails in the respective third country.

In particular, this includes conducting an impact assessment on personal information protection to protect your personal data.

7. 您的权利Your rights


You have the right to withdraw your consent to the processing of your personal data in accordance with Art.47 of PIP Law at any time with effect for the future. Processing that took place before the withdrawal therefore remains lawful.


In accordance with Art. 45 , you can request information about your personal data processed by us.


In accordance with Art. 46 of PIP Law, you can demand the immediate correction of incorrect or incomplete personal data stored by us.


In accordance with Art. 47 of PIP Law, you can request the deletion of your personal data stored by us in accordance with the conditions stated therein, unless legally prescribed retention periods prevent immediate deletion and/or another case of Art. 13 of PIP exists and/or a new purpose justifies further processing.


Pursuant to Art.47 of PIP Law , you may request the restriction of data processing where the storage period as stipulated by laws and administrative regulations does not expire, or the deletion of personal information is difficult to be realized technically in such case ,we will stop the processing other than storage and necessary security protection measures.


In accordance with Art. 45 of PIP Law, under the conditions stipulated by the CAC,you can request to transfer your personal information to a third processor , we will provide a way for the said transfer.


we would ask you to address any complaints first to us via the contact details given under 1. above. Where we refuse your request for exercising your rights, you may file a lawsuit with a people's court in accordance with the law.

8. 您必须向我们提供您个人信息的范围

Scope of your obligations to provide us with your personal information

您仅必须向我们提供订立、履行和终止合同关系所必需的个人信息,或者我们通常需要执行我们的服务或我们有法律义务需要收集的个人信息(例如,向监管部门提供证据)。 如果没有这些个人信息,我们一般将无法与您缔结和履行合同关系或提供我们的服务,也包括合同关系建立后或提供服务的范围内后来会需要的个人信息。我们的表格中标有星号 (*) 的方框是必须的。如果我们要求您提供除此之外的个人信息,您可以自愿选择提供或不提供。

You only need to provide us with the personal data that is necessary for the initiation, execution and termination of a contractual relationship or that we generally require for the execution of our services or that we are legally obliged to collect (e.g. to provide evidence to authorities). Without this personal data, we will generally not be able to conclude and carry out the contractual relationship with you or provide our services. This may also refer to personal data that will later become necessary within the scope of the contractual relationship or the provision of services. Boxes marked with an asterisk (*) in our forms are mandatory. If we request personal data from you in addition to this, your details are always voluntary.

9. 自动化决策(包含用户画像)

Automated decision making in individual cases (including profiling)


We do not use purely automated decision-making procedures in accordance with Art.24 of PIP Law. Should we nevertheless use such a procedure in individual cases in the future, we will inform you of this separately if this is required by law.

10. Cookie或同类技术 Cookie and Similar technologies

为提高我们的网络服务,我们会在您的计算机或移动设备上存储名为 Cookie 的小数据文件。Cookie 通常包含标识符、站点名称以及一些号码和字符。Cookie主要的功能是便于您使用网络平台产品和服务,以及帮助我们网络平台统计独立访客数量等。运用Cookie技术,我们能够为您提供更加周到的个性化服务,并允许您设定您特定的服务选项。

To improve our web service, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. The main function of cookies is to facilitate your use of our online platform products and services, and to help our online platform to count the number of individual visitors. Using cookie technology, we can provide you with more personalized services and allow you to set your specific service options.

当您使用本公司的产品和服务时,您同意我们使用Cookie或同类技术。Cookie 和其他技术用于为我们的网站服务提供某些功能,例如用户识别、用户预设的存储、向用户明确分配临时进程或交易相关数据、在您登录到用户帐户期间,存储附加安全信息或收集有关网站使用情况的信息,并改进网站设计和功能。几乎所有网站均使用这些技术来识别使用相同的终端设备和相同的浏览器访问过的用户,以便它们可以调整显示的内容,并在某些情况下进行相应的更改。 我们和我们第三方服务提供商也使用 Cookie 和其他技术。

By using our web service, you agree to our use of cookies and similar technologies. Cookies are sent to your device. Cookies and other technologies are used to give our website service certain functions, e.g. the recognition of a user, the storage of the presettings of a user, the clear assignment of temporary process-related or transaction-related data to a user, the storage of additional security information during a user login to his/her user account or the collection of information about website usage, and to improve website design and functionality. These technologies are also used by almost all websites to recognise if the website has already been accessed previously with the same terminal equipment and the same browser so that they can adjust the displayed contents and, in some cases, vary them accordingly. Cookies and other technologies can be used by us and by our third-party service providers.

您可以清除计算机上保存的所有 Cookie,大部分网络浏览器都设有阻止 Cookie 的功能。我们也可能增加按钮,让您确定是否同意在特定网络服务范围内同意使用Cookie 的功能。如果您阻止、删除或退出Cookie 的功能,则您可能会无法使用我们提供的一些网络提供服务或功能。

You may clear all cookies saved on your computer, and most web browsers have function to block cookie. We may also add a cookie banner that allows you to confirm your consent to the use of cookies within the scope of the respective website service by clicking on a button. Please note that it is possible that not all functions of our web service will be available to you if you block, delete or disable cookies.

11. 保护未成年人的信息 Protection of Minors’ Personal data


We attach great importance to the protection of minors' personal data. If you are a minor under the age of 14, we will protect the confidentiality and security of your personal data in accordance with relevant laws and regulations.


If your guardian does not agree with you to use our services or provide us with information in accordance with this notice, please stop using our services immediately and notify us immediately so that we can take corresponding measures.

12. 本通知的更新 Revision of the Notice

我们可能适时修订本通知,一旦本通知内容发生变更,我们会在 保赫曼中国网站】公布最新的通知,敬请留意。

We may revise this notice from time to time. Please note that we will announce the latest revision on PH China Website