Privacy Policy

Aculys Pharma, Inc. (“ACULYS,” “we,” “our” or “us”) has established the following privacy policy (this “Policy”) concerning the handling of the personal information obtained in connection with the website run by ACULYS /(the “Site”) from you as users of the Site (“Users,” “you” or “your”). The terms used in this Policy have the meaning as defined in the Act on the Protection of Personal Information (“Personal Information Protection Act”).

Article 1. Basic Policy on Privacy Policy

1.We will comply with the Personal Information Protection Act, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and any other laws and regulations applicable to the handling of personal information, and will take appropriate measures for security management of such information in accordance with this Policy.
2.We are committed to making every effort including training of the personnel engaged in our business to ensure the proper handling of personal information.
3.We will use our collected personal information for the Purposes of Use as defined in Article 3, and will not use the information beyond the scope necessary to achieve the Purposes of Use without the consent of the data subject or except as permitted by law.
4.We will take adequate security measures to prevent divulgation, loss or corruption of personal information for the implementation of security management thereof.
5.We will make our people aware of prevention of certain incidents including unauthorized access to, or divulgation, loss, damage or alteration of, personal information, and will improve and correct information security on an ongoing basis. We will seek to secure sufficient accuracy of personal information and keep the information updated to ensure that level of accuracy.

Article 2. How to Obtain Personal Information

1.We will collect personal information to the extent necessary to conduct business and in a lawful and appropriate manner. We may collect, from our business partners (including information providers, advertisers, advertising delivery destinations) and others, information on the records of transactions between Users and the business partners or the like and on the payments therefor, which contains the personal information of the Users.
2.In order to provide better services and content on the Site, we may obtain access log information. This is not intended to collect or identify personal information.

Article 3. Purposes of Collection and Use of Personal Information

We collect and use personal information to the extent necessary for the following purposes (“Purposes of Use”):

（1）proposals on or notice of the services that we offer or any other information provision deemed by us to be necessary;
（2）review of the suitability or appropriateness of our service provision;
（3）identity verification of the data subject or the agent thereof;
（4）exercise of rights and fulfillment of obligations under the contract with the data subject and applicable laws and regulations;
（5）research and development of products and services through data analysis and questionnaires, market research, publicity and public relations activities, marketing activities, surveys and feedback, and recruiting;
（6）maintenance, important announcements, and any other need-based communication for information provision aimed at investors and shareholders;
（7）handling of various types of inquiries about ACULYS or the Site (including requests for access, modification, deletion or the like to the registered information of or use by the User); and
（8）any other purposes incidental to any of those listed above.

Article 4. Change to Purposes of Use

1.We shall make a change to the Purposes of Use of personal information only if we can reasonably find that the new Purposes of Use will have relevance to the existing Purposes of Use.
2.If any change is made to the Purposes of Use, we shall notify the data subjects of the new Purposes of Use in our prescribed manner or publish them on the Site.

Article 5. Provision of Personal Information to Third Parties

1.We will not provide third parties with any personal information that we handle without the prior consent of the data subjects thereof unless:
1. （1）it is necessary to protect the life, body or property of an individual, and it is difficult to obtain the consent of the data subjects;
2. （2）it is particularly necessary to improve public health or promote the sound growth of children, and it is difficult to obtain the consent of the data subjects;
3. （3）it is necessary to cooperate with a government agency, local government or any person commissioned thereby in performing an affair as required by law, and obtaining the consent of the data subjects may interfere with the performance of the affair; or
4. （4）otherwise required by law.
2.Notwithstanding the provisions of the preceding paragraph, the recipient of the information shall not be deemed to be a third party if:
1. （1）we outsource the handling of personal information in whole or in part to the recipient to the extent necessary to achieve the Purposes of Use;
2. （2）personal information is provided to the recipient in connection with the transfer of our business as a result of a merger or any other event; or
3. （3）personal information jointly used with specified persons is provided to the persons, and we so notify the data subjects in advance along with the items of the jointly used personal information, extent of the joint users, the users’ purposes of use, name and address of the person responsible for management of the personal information, and in the case of a legal person, the name of the representative thereof, or we make the foregoing information readily available to the data subjects.

Article 6. Notification, Disclosure/Correction or Suspension of Use of Personal or Other Related Information

1.With regard to the request for the disclosure of personal data or record of provision to third parties in our possession, notification of the Purposes of Use of, correction, addition or deletion to, or suspension of use or provision to third parties of the personal data in our possession (“Request for Disclosure, Etc.”), the data subject of the personal data in our possession or the agent thereof may make such request; provided, however, that we may not disclose the data if:
1. （1）disclosing the data may harm the life, body, property or any other right or interest of the data subject or a third party;
2. （2）disclosing the data may significantly interfere with us in properly performing operations;
3. （3）disclosing the data constitutes a violation of law; or
4. （4）we are unable to verify that the Request for Disclosure, Etc. has been made by the data subject or agent thereof;
2.A Request for Disclosure, Etc. shall be directed to the contact point as set forth in Article 8.
3.If we receive a Request for Disclosure, Etc., we will ask the requester to fill in our prescribed form and as a general rule, respond to it in writing. We will charge prescribed fees for the requests for the disclosure of personal data or record of provision to third parties in our possession or for notification of the Purposes of Use of the personal data in our possession.

Article 7. Modification to Privacy Policy

The content of this Policy may be modified without notice to Users for continuous improvement unless otherwise required by law or set forth herein. Except as otherwise specified by us, any modified Policy shall become effective when it is posted on the Site.

Article 8. Contact Point

We intend to appropriately respond to any complaints or consultations regarding the handling of personal information and specific personal or other related information. If you have any inquiry or question concerning the handling of, or our security management measures for, personal information and specific personal or other related information, please submit an inquiry form .

The Terms were last updated on March 8, 2024.