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Privacy Policy: Personal Information Protection Policy

Ascella Bio JAPAN (hereafter “ Ascella ”), recognizing the importance of protecting personal information, hereby establishes the Personal Information Protection Policy (this “Basic Policy”) in order to ensure the proper protection of personal information.

1. Policy

Ascella complies with the Act on the Protection of Personal Information (Act No. 57 of 2003, the “Act”) and other laws and regulations, as well as the guidelines of the Personal Information Protection Commission and other guidelines. In addition, Ascella complies with this Basic Policy and handles personal information in an appropriate and safe manner.

2. Acquisition and Use of Personal Information

(1) Acquisition of personal information

Ascella acquires personal information within the scope of business conducted by Ascella, for clearly defined purposes of use and by appropriate means. When Ascella directly acquires personal information stipulated in a contract or other written documents (including electromagnetic records) from each person, the purpose of use shall be clearly stated in advance, and the information shall be acquired by lawful and fair means.

(2) Use of personal information

Ascella will use personal information to the extent necessary for the purpose of use. Personal information will not be used for any purposes other than the stated purpose of use, without the consent of the person in concern.

3. Purpose of Use of Personal Information

Ascella will use the personal information listed below for each respective purpose of use. If personal information is acquired for a purpose not listed below, the purpose will be clearly stated each time of acquisition.

(1) Personal information of members of entities or organizations that have business relationships with Ascella

To solicit, propose and carry out business and transactions
To contact, provide and exchange information in relation to our business and services
To perform contracts with our business partners
To manage access to our facilities

(2) Personal information of visitors to our consultation service, website and webinars.

To examine, investigate and respond to consultation or enquiries
To contact and provide information to manufacturers, sellers, medical professionals, etc.
To provide information of our events, campaigns, webinars, etc.

(3) Personal information relating to media representatives, securities analysts, investors etc.

To collect and provide information for public relations and investor relations purposes
To manage access to our facilities

(4) Personal information of shareholders

To fulfill our obligations under the Companies Act and to enable the shareholders to exercise their rights when necessary
To implement shareholder policies in the context of the relationship between shareholders and the company
To manage shareholder information in accordance with laws and regulations

(5) Personal information of applicants for employment

To contact the applicant regarding the selection and results of the recruitment process
To carry out pre-employment procedures
To manage access to our facilities

(6) Personal information of directors and employees (including retired employees) and their families

To ensure the proper implementation of payroll payments, labor management, benefits, health and safety measures and related measures for employees
To provide education and training to employees
To contact and provide information to labor unions, health insurance associations, affiliates and other related parties
To contact retired employees and respond to enquiries
To submit notifications and reports relating to social insurance, labor insurance, etc., to government offices
To contact and provide information in the event of emergency
To carry out other procedures and communications necessary in the course of business

4. Provision of Personal Information

Ascella will not provide personal data to third parties except in one of the following cases.

When the consent of the person in concern has been obtained.
Disclosure to subcontractors to the extent necessary to achieve the purpose of use.
When necessary in order to protect the rights and interests of Ascella and its officers and employees, including their life, body and property, as well as the rights and interests of Ascella’s customers (including for the purpose of detection and prevention of irregularities).
When Ascella sells or transfers all or part of its business or assets to its affiliates or other third parties.
When provided pursuant to laws and regulations, or when there are other legitimate reasons.

5. Sharing of Personal Information within the Group

Ascella may share personal information within the Group only to the extent necessary to achieve the purposes of use set out in Section 3 and within the following scope.

Items of personal information to be shared

Items described in Section 2(1) “Acquisition of personal information” of this Basic Policy

Scope of joint users

AXEL MARK INC.

Purpose of use

Items described in Section 3 “Purpose of use of Personal Information” of this Basic Policy

Name or title, address and representative of the entity responsible for the management of personal data

Name: Ascella Bio JAPAN Inc.,
Address: 2-5-1 Atago, Minato-ku, Tokyo
Preseident and CEO: Takahiro Suzuki

6. Supervision of Contractors

Ascella may outsource the management of personal information to third parties in order to achieve the purpose of use of such personal information. In such cases, Ascella will require the appropriate management of personal information by such third party and supervise such third party.

7. Disclosure, Correction and Deletion of Personal Data

If Ascella receives a request for disclosure, correction or deletion of personal data from the person in concern or from a legally designated representative, Ascella will handle such request without delay within a reasonable time in accordance with the law, subject to the prescribed and proper identification procedure.

8. Contact

Enquiries regarding personal information can be made at the following contact points.

Ascella Bio JAPAN
2-5-1 Atago, Minato-ku, Tokyo
Phone: 81-3-6868-0466

9. Management of Personal Information

(1) Ascella appoints a person responsible for the management of personal information and strictly manages personal information to prevent the improper use within the company. Ascella also takes appropriate and reasonable security measures against risks such as unauthorized external access or the loss, destruction, falsification or leakage of personal data.
(2) Ascella will endeavor to keep the personal data in its possession as accurate and up-to-date as possible.

10. Review of Basic Policy

Ascella will review this Basic Policy from time to time and improve it as necessary. Any changes will be promptly published in a reasonable manner.