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Legal and privacy

Privacy Policy

Document version: 1.1.0

Effective: August 2, 2026

Last updated: August 2, 2026

Contents

1. Scope and handler 2. Information we process 3. Sensitive information 4. Purposes and legal bases 5. Cookies and analytics 6. Processing and sharing 7. Overseas processing 8. Retention 9. Security 10. Your rights 11. Minors 12. Updates and contact

Key points

  • For an initial enquiry, share only low-sensitivity information such as your country or city, treatment goal and expected travel window.
  • Do not send CBCT scans, medical records, diagnoses, identity documents or financial account details through public email, WeChat or WhatsApp.
  • If medical and health information is necessary, we will separately explain why it is needed, how it will be used and who may receive it, and obtain separate consent where required by law.
  • We do not sell personal information or distribute your enquiry to clinics or marketers without appropriate authorization.

1. Scope and personal information handler

This Policy applies when you visit Bozhun's public website at bozhundental.com, use the browser-based cost calculator, or make an initial enquiry or request pre-contract appointment coordination through the public email, WeChat or WhatsApp contact options shown on the website.

In this Policy, “Bozhun,” “we,” “us” and “our” refer to the following personal information handler:

  • Operator: Beijing Zhiqi Chuangxiang Technology Co., Ltd.
  • Registered address: Room 215-16, No. 9 Jingtong Street, Taihu Town, Tongzhou District, Beijing, China
  • Unified Social Credit Code: 91110112MADPTJ492G
  • Contact email: [email protected]

The Phase 1 public website does not provide account login, CBCT or medical-record uploads, or clinic, travel-partner or administration portals. This Policy does not cover a future live private system. Separate rules, authorizations and secure submission arrangements will be provided before any such functions go live.

Clinics, licensed dentists, WeChat, WhatsApp, email providers and other third-party websites may process information for their own purposes and under their own rules. This Policy does not replace their privacy notices.

2. Information we process

We apply the principles of specified purpose, minimum necessity and transparency. The current public website may involve the following information:

CategoryExamplesMain purposeIndicative retention
Initial enquiry information Name or preferred form of address, country or city, email or messaging account, treatment goal, expected travel window and the enquiry text you choose to provide Responding, understanding your needs and arranging pre-contract communication or appointment coordination Normally no more than 24 months after the last substantive communication, unless a dispute or legal obligation requires longer
Visit and analytics data Timestamp, page path, referrer, convention-based UTM parameters, country or region, device type, operating system, browser, and language and placement values attached to anonymous click events Website operation, aggregate traffic analysis, content improvement and performance measurement According to analytics account settings, the period necessary for the stated purpose and applicable legal requirements; reviewed periodically
Network and security logs IP address, request time, browser identifier, requested path, errors and abnormal-access records Network delivery, security, troubleshooting and abuse prevention Retained by hosting and security providers for the period needed to provide and secure the service and meet legal obligations
Rights request and complaint records Identity-verification information, request or complaint, correspondence and outcome Responding to privacy rights, handling complaints and demonstrating the handling process Normally no more than 3 years after the request is closed
Sensitive material received unexpectedly Medical records, images, diagnoses, identity documents or financial account information sent through a public channel without our request Giving a safety warning, confirming deletion or arranging a secure submission route If continued processing is unnecessary, normally removed from actively used systems within 30 days after identification

The country, procedure and quantity entered in the cost calculator are used only for calculations in your browser. If you actively select a service and continue to contact options, the page only moves to the public contact section of the relevant language homepage. That navigation does not transmit the country, procedure, quantity, estimate or medical information. We do not link the result to your identity unless you separately contact us and provide it.

3. Medical and health information and other sensitive personal information

Public contact channels are not medical-record submission channels

Medical and health information, identity documents, precise location, financial accounts and information about a child under 14 may be sensitive personal information. Misuse or disclosure may create elevated risks to personal, financial and dignity interests.

At the initial-enquiry stage, do not send CBCT or X-ray images, medical records, diagnoses, prescriptions, identity cards, passports or bank-card details through public email, WeChat or WhatsApp. If clinical records become necessary, we will first explain the purpose, exact categories, retention period, possible clinic or dentist recipients and potential effects on your rights. We will then provide an appropriate secure submission method and obtain separate consent where required by law.

If you send sensitive personal information before we request it, we will not treat that act as blanket consent to later sharing, publication, marketing or overseas processing. We will process it only as necessary to warn you of the risk, assess whether urgent action is required, delete it or arrange secure transfer. We will obtain the required authorization before any continued processing. If retention is unnecessary, we will delete or stop using it within the period stated in this Policy.

If you enquire for a parent, family member or another person, obtain lawful authorization first. Do not provide another person's medical, health or identity information without authority.

4. Purposes and legal bases

We process personal information only where a lawful basis applies, including:

  • where necessary to provide website access, browser-based estimates, enquiry responses or pre-contract communication that you request;
  • where necessary to conclude or perform a contract to which you are a party;
  • with your consent; where separate consent is required for sensitive personal information, disclosure to another personal information handler or overseas provision, we will obtain it separately;
  • where necessary to perform legal duties relating to cybersecurity, consumer protection, tax, records or other applicable obligations;
  • in an emergency, where necessary to protect a natural person's life, health or property; and
  • in other circumstances permitted by applicable laws and administrative regulations.

We may analyze visits and enquiry trends in anonymized or aggregate form to improve the website and our services. Information that has been anonymized so that a particular person cannot be identified and the process cannot be reversed is not personal information.

Accepting this Policy does not automatically subscribe you to marketing. If we wish to send promotional content, events or service marketing, we will obtain separate, affirmative consent and provide an easy opt-out. Refusing or withdrawing marketing consent does not affect basic website or enquiry functions.

5. Cookies, website analytics and the cost calculator

5.1 Cookies

The current Bozhun public website does not use advertising cookies or third-party analytics cookies to track you across websites or days. If we later introduce non-essential cookies that require consent, we will provide a separate notice and choice mechanism before enabling them and update this Policy.

5.2 Cloudflare Web Analytics and controlled events

The public website uses Cloudflare Web Analytics to understand aggregate traffic. Cloudflare describes this product as privacy-first and as not using client-side state, such as cookies or local storage, to collect or use visitors' personal data. Bozhun reviews aggregate trends such as page visits, referrers, country or region, device, browser and operating system.

If Cloudflare Zaraz is enabled for controlled click events, event properties are limited to language and page placement and must not include a name, phone number, email, health condition, case or order number, filename, estimate or free text. In Phase 1, public anonymous traffic is not automatically linked to an enquirer's identity, medical records or transaction history.

5.3 Cost calculator

The current calculator runs in your browser and requires no login. The country, procedure and quantity are used only for browser-based calculation. If you actively select a service and continue to contact options, the page only moves to the public contact section of the relevant language homepage. That navigation does not transmit the country, procedure, quantity, calculated amount or medical information. The output is a general comparison, not a diagnosis, formal quotation or savings guarantee.

6. Entrusted processing, sharing, transfer and publication

6.1 Entrusted processing

We may engage website hosting, security, analytics, email and technical providers to process necessary information within agreed purposes, duration and security requirements. Depending on the service, we use contractual restrictions, access limits and security reviews and require processors not to act beyond our instructions.

6.2 Provision to clinics or other service providers

Browsing or making a general enquiry does not automatically distribute your details to multiple clinics. Only after you make a clear selection or give authorization, and where necessary to obtain a plan, estimate or appointment, will we separately tell you the recipient's name or scope, contact details, purpose, method and information categories and obtain separate consent where required. A recipient must obtain renewed consent if it changes the processing purpose or method.

6.3 Business transfer

If a merger, division, dissolution, bankruptcy or business transfer involves personal information, we will identify the recipient and its contact details and require it to continue performing the obligations in this Policy. A new purpose or method requires renewed consent where applicable.

6.4 Public disclosure

We do not ordinarily disclose personal information publicly. If disclosure becomes necessary, we will separately explain the purpose, categories and possible effects and obtain separate consent, unless the law provides otherwise.

6.5 Legally required provision

We may provide information within the lawful scope where required by law, legal proceedings, regulators or law enforcement, or where necessary to protect the life, health, property and lawful rights of you, Bozhun or others. We retain appropriate records of such handling.

We do not sell personal information.

7. Overseas processing and third-party channels

Bozhun serves people outside China. Website hosting and some communication tools may involve processing outside the People's Republic of China. Current principal situations are:

Recipient or channelLocation and contactPossible informationPurpose and rights route
Cloudflare, Inc. United States; 101 Townsend St, San Francisco, CA 94107, USA; contact is available through Cloudflare's privacy page Network requests and security logs, page path, referrer, controlled UTM values, device and browser, approximate region and controlled anonymous analytics events Website hosting, content delivery, security and aggregate analytics. You may first exercise your rights through Bozhun using the details in this Policy and may also review Cloudflare's privacy notice
WeChat, WhatsApp or email Depends on the service you choose, account region and relevant provider Account identifiers, message content, timestamps and device or network information When you open an external contact option or send a message, the provider processes data independently under its own rules; rights may also be exercised through its privacy settings or support channel

This Policy provides transparency; it does not replace separate consent, a personal information protection impact assessment, standard contract, security assessment, certification or filing required by law. Before we actively provide an identifiable enquiry or medical and health information to an overseas recipient, we will identify the recipient, contact details, purpose, method, information categories and rights channel and complete applicable additional procedures.

You may choose not to use WeChat or WhatsApp and may submit a general privacy request through the contact email listed in this Policy. We will continue reviewing overseas website-hosting arrangements against the production architecture, provider changes and applicable law.

8. Retention

We retain personal information only for the shortest period necessary for the purposes in this Policy. Indicative periods are set out in Section 2. When a period expires, we delete or anonymize information. If law requires continued retention or deletion is technically difficult, we stop processing other than storage and necessary security protection.

Retention may be extended where necessary to handle an unresolved enquiry or complaint, perform a contract or legal duty, respond to litigation or a regulatory investigation, or protect life, health or property. Any extension is limited to relevant information and the necessary period.

You may request deletion during the retention period where the law permits. Withdrawing consent does not affect processing carried out lawfully before withdrawal or records that we must retain under another legal basis.

9. Information security and incident response

Based on the purpose, category and risk, we use organizational and technical measures appropriate to our present scale, including least privilege, access control, HTTPS transmission protection, security headers, backup, logging, confidentiality duties and incident response. The Phase 1 Cloudflare Pages public website does not provide a function for collecting or storing real medical records.

No internet service can promise absolute security. If personal information is or may be leaked, altered or lost, we will promptly take remedial measures and notify relevant authorities and affected individuals as required, including the categories, cause, possible harm, action taken, recommended risk-reduction steps and contact details. Notification may be omitted only where law permits and effective measures have prevented harm.

If you suspect misuse, misdelivery or disclosure, contact us immediately through the email listed in this Policy.

10. Your personal information rights

Subject to applicable law, you may:

  • know and decide how we process your personal information and restrict or refuse particular processing;
  • access and obtain a copy of your personal information and request transfer where statutory conditions are met;
  • correct or complete inaccurate or incomplete information;
  • withdraw consent-based processing;
  • request deletion where the purpose has been achieved, retention has expired, consent is withdrawn, processing is unlawful or another statutory ground applies;
  • ask us to explain this Policy and specific handling rules; and
  • complain or report concerns and pursue other lawful remedies.

Email [email protected] with the subject “Personal Information Rights Request.” To protect your information, we may verify identity and authority. Verification material is used only to process the request. We normally respond within 15 working days after receiving a complete request and completing necessary verification. If a complex matter requires longer, we will explain why and provide an expected timeframe.

If we refuse a request, we will explain the reason. You may still complain or report to the authority responsible for personal information protection or bring proceedings before a competent court.

11. Minors

This website is primarily intended for adults with full civil capacity and is not directed principally to minors. A person under 18 should use the website and make an enquiry with guidance from a parent, guardian or other lawful representative.

We do not intentionally collect personal information about a child under 14. If coordination for a minor becomes necessary, we will provide a specific rule, obtain consent from a parent or other guardian and apply stricter safeguards. Contact us promptly if you believe a minor has provided information without guardian consent.

12. Policy updates and contact

We may update this Policy when our services, technology, law or processing activities change. The page will show the version, effective date and last-updated date. We will provide a more prominent notice for material changes to purposes, information categories, recipients or individual rights and obtain renewed consent where required.

Contact:

  • Operator: Beijing Zhiqi Chuangxiang Technology Co., Ltd.
  • Registered address: Room 215-16, No. 9 Jingtong Street, Taihu Town, Tongzhou District, Beijing, China
  • Unified Social Credit Code: 91110112MADPTJ492G
  • Contact email: [email protected]

This Policy governs the current public website. It does not replace a formal paid-services contract, medical informed consent, separate consent for sensitive personal information or a dedicated cross-border data document.

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