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About the handling of personal information*

■1 Privacy Policy

·Basic Policy on the protection of personal information and information security of Linical.

Linical as the company related to medical and health industries, acknowledging importance and sociality of personal information, will comply with laws and any regulations of personal information and make efforts to protect personal information by every executive and employee.

·Scope of Application

This Privacy Policy is applicable to any personal information and personally identifiable information.

·Management System

Linical, accelerating to take security measures from any points of view, will prevent illegal access and loss, misuse, destruction, and alternation of personal information.

·Handling Information of outsourcing

When Linical is entrusted with the service with presentations of information, Linical will provide articles regarding the confidentiality obligation of personal information, sharing of responsibilities for the accident and, return and deletion of personal information on contract expiry.

·Disclosure of Personal Information

Linical will not disclose any personal information to third parties without the prior consent of the individual concerned.

·Continued improvement of the Compliance and Management System of personal information.

Linical will comply with laws and regulations of personal information and review and improve this Privacy Policy from time to time.

■2 Handling of Personal Information

(1)Name of business operator:

Linical Co., Ltd.

(2)Purposes of use

①Personal Information of pharmaceutical companies, hospitals, universities and various research institutes, site management organizations and any other persons related to the clinical trials or clinical research (“medical personnel”);

·To execute the entrusted business;

·To consider business opportunities;

·To conduct research and study in medical and pharmaceutical fields;

·To contact and provide information to medical personnel;

·To respond to the government sector.

② Personal Information of applicants for employment

·To conduct screening of candidates for employment;

·To go through the procedure and notify the result of recruitment;

·To prepare for joining and provide any necessary information;

·To contact and provide information to applicants of internship.

③ Personal Information of employees (including former employees) and their family

·To plan the strategy about company organization, personnel affairs, welfare, education, safety and health;

·To contact and communicate regarding the business;

·To manage and provide services about recruitment, performance appraisal, benefits and compensation, commendation, disciplinary processes, attendance management, development and training;

·To audit to carry on business properly;

·To respond to the government sector;

·To contact and communicate with a person having a business relationship;

·To entrust to third parties for the purpose above;

·To deal with any other relevant matters associate with the purpose above.

④ Dispatched Worker

·To perform obligations (including the obligation of payment) and rights regarding the Worker Dispatch Contract between Linical and a dispatch company;

·To deal with any other relevant matters associate with the purpose above.

(3)Provision to third parties

Linical shall not provide personal data to third parties without the prior consent of the individual concerned except under the following circumstances.

① Cases in which the concerned person's prior consent is obtained;

② Cases in which the personal information is disclosed in a manner that cannot identify the concerned person;

③ Cases in which Linical entrust to a third party to the extent necessary to achieve a utilization purpose;

④ Cases in which Linical takes necessary action required by laws;

⑤ Cases in which disclosure or provision is requested by legal demands.

(4)Joint use of personal information

Linical shall jointly use the personal information of employees (including former employees) and their family as follows;

① Name of the entities responsible for the management of the personal data:

Linical Co., Ltd.

② Purpose of the use

Purpose prescribed in “The purpose of use of the personal information”

③ Range of the joint users

Group companies (both within and outside of Japan) belonging to Linical Co., Ltd.

④ Items of personal data jointly used

Date of birth, name, sex, address, zip code, phone number, employee category, employee number, joining date, educational background, belonging company, department (including dispatched employees and transferred employees), title, position, mail address, condition of personnel or labor management and others items required for the purpose set forth above.