1. Privacy policy

Each of the OLBA Group companies

1. (1) clearly specifies a person responsible for protection of personal information, and properly handles personal information by establishing company regulations and consolidating management systems;
2. (2) appropriately responds to not only acquisition, usage, and provision, but also disclosure, correction, suspension, and so on of personal information;
3. (3) takes appropriate safety management measures to prevent leakage, damage, loss, destruction, and falsification of personal information;
4. (4) implements in-house educational and enlightenment activities in the Group companies, ensures all employees within our Group of the appropriate handling of personal information and the importance of protecting it, and continually reviews the management systems.

Yohei Maeshima,
President and COO
OLBA HEALTHCARE HOLDINGS, Inc.

Kawanishi Co., Ltd.
Sansei Medical Materials Co., Ltd.
Nikko Medical Materials Co., Ltd.
HOSNET-JAPAN INC.
Life Care Co., Ltd.
EXSOLA MEDICAL Inc.
Kawanishi BarcMed Co., Ltd.

2. Personal information collected and handled by our Company and our Group companies (hereinafter referred to as “our Group)

Personal information collected and handled by our Group is as follows:

1. (1) Personal information on those who have accessed the web, etc.
   Personal information related to those who have made inquiries and applied for employment, etc., by accessing our website or by e-mail.
2. (2) Personal information on shareholders
   Information related to shareholders
3. (3) Personal information on patients
   Personal information related to patients out of the information that has been obtained through our Group’s sales activities
4. (4) Personal information on employees, etc.
   Personal information related to our Group’s employees, etc.
5. (5) Other personal information
   Personal information other than the above

3. Classification of personal information and its usage

1. (1) Personal information on those who have accessed the web, etc.
   1. 1) Personal information on those who have accessed the web may be shared within our Group as necessary.
   2. 2) In principle, sharing of personal information is limited to within our Group to the minimum extent necessary.
   3. 3) Regarding provision of information to those who have accessed the web, they may select whether they would like to continue to receive information.
   4. 4) Personal information on those who have accessed the web is promptly erased after the purpose is accomplished.
2. (2) Personal information on shareholders
   1. 1) Personal information on shareholders is managed by the shareholder registry administrator designated by our Company.
   2. 2) In addition to various notifications to shareholders according to statutory and regulatory requirements, etc., personal information may be used to provide information that shareholders may be interested in. In this case, shareholders may select whether they would like to continue to receive information in the future.
3. (3) Personal information on patients
   1. 1) Purpose of use of personal information on patients
      The purpose is to give, receive, and preserve information between medical institutions, manufacturing distributors, dealers, and leasing companies to prevent the occurrence or spread of harm in terms of health and hygiene based on the Pharmaceutical Affairs Act, and provide safety information to the persons concerned.
   2. 2) Proper management of information
      Personal information that has been obtained is properly managed to fulfill our responsibilities stipulated in the Pharmaceutical Affairs Act as a medical equipment distributor.
   3. 3) Provision to third-parties
      Personal information is not provided to third parties without prior consent of the persons concerned, except in the following cases where:
      1. -1: based on laws and regulations;
      2. -2: it is necessary for protection of human life, body or property, and it is difficult to obtain the consent of the persons concerned;
      3. -3: it is especially necessary for improvement of public health or promotion of healthy development of children, and it is difficult to obtain the consent of the persons concerned;
      4. -4: it is necessary for cooperation among national organizations, local public organizations, or those who are commissioned by them to perform administrative work according to laws and regulations, and the performance of the administrative work in question may be hindered by obtaining the consent of the persons concerned.
4. (4) Personal information on employees, etc.
   1. 1) Personal information on our Group’s employees, etc., (including part-timers and other temporary employees) is collected based on laws and regulations, such as the Labor Standards Act and tax laws, and our company regulations, such as work rules.
   2. 2) This personal information may be shared within our Group as necessary for the purpose of enhancing our Group’s business efficiency. Personal information is handled only by a limited number of officers and employees.
   3. 3) Personal information on employees, etc., is never disclosed without the consent of the persons concerned, including inquiries from outside, except when based on laws and regulations.
   4. 4) Personal information on employees, etc., is retained for a specified period of time even after resignation or retirement according to laws and regulations. It shall be promptly erased after the expiration of the retention period.
5. (5) Other personal information
   Regarding handling of other personal information, it is strictly managed based on our privacy policy and information handling regulations in addition to relevant laws and regulations, such as the Act on the Protection of Personal Information.