Policy on Handling of Personal Information

Name of Business Operator Handling Personal Information
ROHTO Pharmaceutical Co., Ltd.

Purposes of Use of Personal Information

In collecting personal information, as a principle, we, the Company, will indicate the purpose and the extent of our use in each case by explaining in writing, on a website, verbally, or in other ways.

However, we may skip the step of indicating the purpose of using personal information obtained in cases where that purpose is explicit, such as obtaining contact information when we receive an inquiry or request from customers or exchanging business cards as a business practice. Even in those cases, we will use personal information obtained within the scope of the following purposes, in principle.

• To provide information on the Company's products and services.
• To respond to inquiries or requests from customers. (When we receive an inquiry by phone, we may record the conversation for accuracy.)
• To inform customers of dispatching the products.
• To dispatch the products ordered or applied for promotional campaigns or prize competitions.
• To provide registered or applied services, such as email newsletters and subscription-based services.
• To provide information from the Company by email or other means.
• To solicit customers to cooperate in a questionnaire survey and enlist testers for the Company's products.
• To analyze and utilize the questionnaire survey and product testing results.
• To inform customers about various sales promotions, such as contests and free-gift campaigns; to notify their results; and to dispatch gifts and other premiums.
• To inform customers about various publicity activities, such as trade shows, seminars, special programs, and other events.
• To analyze anonymized and unidentifiable advertising-related and statistical materials and marketing data.
• To process personal information in anonymized and unidentifiable data and utilize it for the Company's product development, marketing, and other activities and post on the Company's websites (“Websites”), brochures, and other media.
• To enlist customers who can assist our activities as a temporary job, such as product reviews from a user's viewpoint.

• We will use personal information submitted by applicants for employment with the Company only for our recruitment activities, such as contacting them and dispatching materials regarding those activities.

• In principle, we will use the personal information of the Company's officers and employees to the extent necessary for human resources management.

We will use the personal information of the Company's shareholders to the extent necessary for the following purposes, in principle.

• To enable our shareholders to exercise their rights and fulfill obligations under the Companies Act of Japan and related laws and regulations. (For example, to dispatch a convocation notice and a voting form for the General Shareholders' Meeting.)
• To offer various advantages to the status of our shareholders. (For example, to offer free- gifts of our products under the Company's shareholder special benefits.)
• To implement various measures to facilitate relationships between the Company and the shareholders. (For example, to perform a questionnaire survey to reflect their comments on formulating the Company's management policy and IR activities.)
• To conduct shareholder management, such as compiling data of shareholders under certain criteria specified by the relevant laws and regulations (For example, to compile and disclose a list of major shareholders in the Company's securities report.)
• To consider the Company's future policy on the shareholders.

• To have business talks and related communications with our business partners.

Contact for Inquires, Complaints, and Requests for Disclosure, etc. of Personal Information
The Company has the contact desk below to receive any inquiries, complaints, or requests related to personal information, such as information about the purpose of use, disclosure, correction, suspension of use and provision to third parties, and erasure of personal information retained by the Company.

Procedure to Request Disclosure, Correction, Suspension of Use and Provision to Third Parties, and Erasure of Personal Information
1) For Personal Information of Customers

• We will receive customer requests via phone, facsimile, or mail at the Customer Support Desk above.
  After verifying the requesting person's identity as a principal or a proxy, we will reply to the request. Depending on the content of the request, we may ask that person to fill out an application form predetermined by the Company. For the information of a member registered for the "Cocorohto Park" (the Company's online community site,) we ask the member to follow the steps specified on "My-page of Cocorohto Park." Please agree we may be unable to respond to the request not following the procedure specified above.

• Any request for disclosure, changes, and other handling of personal information of our shareholders will be received by the Company's shareholders registry administrator, Mitsubishi UFJ Trust and Banking Corporation ("MUFG Trust Bank"). Please contact and confirm with the MUFG Trust Bank below for a concrete procedure for making such a request.

  <Contact information>
  Mitsubishi UFJ Trust and Banking Corporation
  Osaka Stock Transfer Agency Department
  Address: 3-6-3, Fushimi-cho, Chuo-ku, Osaka-shi, Osaka 541-8502 (Japan)
  Telephone: 0120-094-777 (Toll-free number)

  
  

  For any stocks in the Company held in the account of a securities company or similar agency, please contact the relevant company.

The Company uses cookies on some content of the Websites to improve them, such as enriching the information and the services provided and increasing the sites' usability. The functionality of cookies on the Websites stores information that a user has browsed the Websites on the user's computer. Information collected through those cookies will never include any "information personally identifiable."

1) What is a Cookie?

A cookie is a mechanism to store information as small files on a user's computer when the user accesses a webpage. That information includes browsing history interactions between the user's browser and the server and the user's entries. When the user accesses the same webpage again, the webpage operator may change the webpage's display using the cookies information. In cases where a user accepts cookies transmission on their browser settings, the websites may obtain cookies from their browser. For privacy purposes, the user's browser will transmit only cookies the website server transmits and receives.

2) Purpose of Use of Cookies

The Company uses cookies for the purposes below and will never use them for collecting personal information.

• To provide the services customized for each user by referring to the user's registered information stored when the user logs in to the authentication service.
• To display the most appropriate advertising based on the user's interest and usage of the Websites.
• To encourage users to reenter (or reauthenticate) their password to ensure security if they have not accessed the Websites for a certain time.
• To survey the number of users and traffic of some content.
• To improve services provided through the Websites.
• To check how customers respond to and utilize our email messages (for example, to access any of our webpages, complete membership registration, and purchase our products) and improve the services on some content.
• We may combine the tags of some content and the information collected from cookies with other information previously collected from the user. We may use that combined information to improve the Websites, customize those pages to each user's need and preference, determine the means of communication suitable to the user, evaluate the effect of the Company's promotion and advertising, and for other internal activities.

When you want to refuse (opt-out) cookies, you can access the opt-out page of the relevant advertising delivery service provider and invalidate (opt-out) cookies. Please agree that some services may become unavailable after you decline cookies.

Opt-out pages of typical ad-delivery service providers:
・Google-Ad (Opt-out page)
・Network Advertising Initiative (Opt-out page)
・Google Analytics (Opt-out page)

April 21, 2021
ROHTO Pharmaceutical Co., Ltd.