PRIVACY POLICY

ROHTO Pharmaceutical Co., Ltd. (“ROHTO” or “we”) fully acknowledges that it is our critical social responsibility to protect personal information. To be deserving of trust from our stakeholders, we will strive to protect personal information according to the following policies (“Policy”):

1. Obtainment of Personal Information
   ROHTO will obtain personal information by legitimate and fair means.

2. Use of Personal Information
   ROHTO will use the personal information within the scope of purposes of use informed at the time of obtaining the personal information and only to the extent necessary to carry out our business.

3. Joint Use of Personal Information
   ROHTO will inform or publicly announce in advance when we share personal information with a third party.

4. Provision of Personal Information to A Third Party
   Except in any of the following cases, ROHTO will not provide or disclose the personal information to any third party:

   • When obtained the prior consent of a person to whom such personal information pertains on the disclosure of their personal information,
   • When required by laws and regulations, or
   • When we provide or disclose to a service provider to the extent necessary to achieve the purposes of use.

5. Security Management of Personal Information
   ROHTO will strive to keep personal information accurate and up to date to the extent necessary to achieve the purposes of use.
   ROHTO will also take proper information security measures against unauthorized access, computer virus threats, and the like to prevent any incident, including loss, destruction, falsification, or leaks of personal information.

6. Supervision of Officers, Employees, and Third Parties Entrusted
   ROHTO will perform the necessary and adequate supervision over our officers and employees to ensure the security management of personal information.
   When ROHTO entrusts a third party with the handling of the personal information, we will provide the necessary and adequate supervision over the said third party to ensure the security management of the personal information entrusted to the same.

7. Disclosure, Correction, Discontinuance of Use, Erasure, etc., of Personal Information
   When ROHTO receives a request for the notice of the purposes of use of personal information retained by us, or the same for the disclosure, correction, discontinuance of use, erasure, or other processing thereof from the person or their representative, we will promptly and faithfully respond to such request in compliance with laws and regulations.

8. Contact for Inquiries, Complaints, Requests for Disclosure, etc.
   ROHTO will set up a section to receive any inquiry and complaint about handling personal information and a request for disclosure or other processing. We will faithfully respond to such inquiries, complaints, and requests.

9. Personal Information of Minors
   ROHTO will work to protect the personal information of minors equally with adults. However, in any event, a minor under 16 years old is required to provide their personal information to us with the consent of their parental guardian.

10. Organization and Structure for the Protection of Personal Information
    ROHTO will appoint a Manager for Personal Information Security Management and a Personal Information Controller to implement the proper management of personal information.

11. Establishment of Rules on Handling of Personal Information
    To practice the Policy, ROHTO will set rules on handling personal information (“Rules”). ROHTO will have all our officers and employees well informed of and follow the Policy and the Rules. We will also audit their compliance with the Policy and the Rules from time to time and improve them as needed.

12. Education and Training
    To manage personal information properly, ROHTO will provide all our officers and employees with education and training on the Policy and the Rules.

13. Compliance with Laws, etc., on the Protection of Personal Information
    ROHTO will strive to protect personal information in compliance with the Act on the Protection of Personal Information and other relevant laws and regulations.

14. Review of Privacy Policy
    ROHTO will review and improve the contents of the Policy as needed and promptly post on our official website and publicly announce any change or revision of the Policy.