Established January 15, 2009
Last Updated January 5, 2012
Shinya Kimura
Representative Director and President,
Japan Medical Data Center Co., Ltd.

<Our Approach to Protecting Personal Information>

We, as a company that provides medical databases, information analysis, and information provision services, believe that the proper management of personal information is an important duty. And we also understand that it is our social mission to handle personal information received from clients and employees with structured systems and rules.
All of us strictly comply with the laws and various guidelines relating to personal information. Through the following fundamental policies regarding personal information, we intend to construct, continuously improve and follow Personal Information Management System to protect the rights of individuals who provide us with their personal information under the following Privacy Policy.

<Privacy Policy>

1. We thoroughly recognize the importance of protecting personal information, and properly acquire, use, provide, and entrust personal information within the scope necessary for our business operations. In other words, when we handle personal information, we always identify the purpose of use, and do not handle personal information that is not necessary to accomplish the purpose of use.
   We also take measures to prevent the use of personal information beyond the purpose of use.
   However, the following cases do not apply:
   1. (1)When required by laws and regulations
   2. (2)When necessary to protect an individual's life, physical safety, or property, and when it is difficult to obtain the consent from the person concerned
   3. (3)When especially necessary to improve public health or to promote the healthy development of children, and when it is difficult to obtain the consent from the person concerned
   4. (4)When cooperating with national authorities, local public bodies, or those commissioned by such, on execution of work provided by laws and regulations, and when there is a possibility that obtaining the consent from the person concerned may obstruct the execution of said work
2. We establish internal rules, and execute reasonable safety measures, prevision schemes and corrective measures to the risks of unauthorized access, leakage loss and damage of personal information.
3. We comply with "Personal Information Protection Management Systems - Requirements (JISQ15001:2006)," the Personal Information Protection Law, nationally established policies, and other standards.
4. In order to manage personal information appropriately and protect it strictly, we continuously improve Personal Information Protection Management System and implement the improvements appropriately in consideration of the demands of person concerned and any changes in our business environment.
5. We respond quickly, accurately, and in good faith to complaints regarding the handling of personal information and requests for consultation and disclosure.
   If you have any complaints or requests for consultation, disclosure and so on, please contact our Privacy Team given below.
6. This Privacy Policy is posted on our website will be ready at any time.

<Handling of Personal Information>

■The purpose of use for the information which is not acquired by document or other equal sources directly

1. (1) Information entrusted from customers and clients
   For statistics and analysis of data
2. (2) Resumes of partner engineers
   For development and operation of systems entrusted from customers and clients

■Announcement of concerned Information regarding personal information for disclosure

1. Company name: Japan Medical Data Center Co., Ltd.
2. Person in charge of personal information protection management: Goro Akiba
3. Contact for questions and complaints regarding personal information for disclosure:
   

   Japan Medical Data Center Co., Ltd.
   
   Privacy Team
   Kojimachi 311 Building 2F, 3-1 Kojimachi, Chiyoda-ku, Tokyo 102-0083
   Phone: (81) 3-3511-6780 FAX: (81) 3-3511-6782 E-mail: privacy@jmdc.co.jp

   Authorized personal information protection organization name and complaint resolution report contact:
   We are a member of "Authorized Personal Information Protection Organization," according to the Personal Information Protection Law Article 37-1. If you have any problems should be resolved by a third-party, please contact this organization.
   

   Japan Institute for Promotion of Digital Economy and Community (JIPDEC)
   Personal Information Protection Consultation Service Office:
   Roppongi First Building, 1-9-9, Roppongi, Minato-ku, Tokyo 106-0032, Japan
   Phone: (81) 3-5860-7565 0120-700-779 (toll-free)

4. Personal information we use and the purpose of use
   "Personal information" is information related to an individual (name, birthday, address, and other information that can identify an individual), as well as information used in relation to a specific individual, such as an email address, user ID, password, credit card number, etc.
   We obtain and use personal information only in order to achieve the following purposes listed below.
   1. (1)Employees
      For personnel management
   2. (2)Job applicants
      For employment as a member of us
   3. (3)Registered web service users (portal site, etc.)
      For providing our web services
      For sales and marketing activities such as mail, telephone calls, and emails and visiting to provide information and services related to us
   4. (4)Customers' and clients' business cards
      For sales and marketing activities such as mail, telephone calls, and emails and visiting to provide information and services related to us
5. Requests for disclosure, etc., of personal information
   Once the identity of the person making requests can be confirmed as the owner of the personal information or his/her agent (e.g., a copy of driver's license of the owner of personal information, etc., or sending a power of attorney for an agent, etc.), we will respond quickly and accurately. Please make requests to the following:
   

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