Modalis Therapeutics Corporation ( “we,” “us” or “our”) recognizes that properly handling personal information obtained through business activities is the importance for business operations and is the social responsibility. We will faithfully implement the following measures to protect personal information.

1. Compliance with laws and regulations

We will comply with relevant applicable laws and regulations, national guidelines and other norms, make internal regulations regarding information management, establish the information management system, make it known to all officers and employees, and endeavor to adequately handle personal information.

2. Acquisition of personal information

Unless otherwise specified by laws and regulations, we will appropriately acquire personal information in accordance with the following purposes without deception or other fraudulent means.

3. Purpose of using personal information

We will use personal information to the extent necessary to achieve the following purposes of use;

• ・Communication, examination, and investigation regarding inquiries;
• ・Screening recruitment candidates, employment management of employees, provision of information and communication with retirees;

Applicants' documents (resume, curriculum etc.) submitted during the selection process will be properly disposed of by us and will not be returned;

• ・Providing various conveniences to shareholders;
• ・Managing shareholders, such as creating data according to prescribed standards based on various laws and regulations; and
• ・Exercising rights and fulfilling obligations in accordance with laws and contracts.

4. Disclosure of personal information to third parties

We will not disclose personal information to third parties except in the following cases;

• ・When requested by law and regulations;
• ・When permission is granted by the person in advance;
• ・When it is necessary to protect human life, body or property, and it is difficult to obtain the consent from the person;
• ・When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain the consent from the person;
• ・When it is necessary to cooperate with national institutions or local public authorities or the entrusted person carrying out the affairs stipulated by laws and regulations, but obtaining consent from the person may interfere with the execution of the given affairs.; and
• ・When outsourcing all or part of the handling of personal data to third parties within the range necessary to achieve the purpose of using personal information.

5. Safety management of personal information

In order to ensure the accuracy of personal information, we will establish an information management system based on internal regulations regarding information management, and endeavor to prevent leakage, loss or damage of personal information handled and to manage other personal data safely. In addition, we will appropriately review the information management system and correct if any inadequacies are discovered.

6. For questions and complaints regarding the handling of disclosure, correction, suspension of use, notices of suspension of provision, please contact us using our inquiry form.

Contact information）otoiawase@modalistx.com

7. Revise this Privacy Policy

The contents of the Privacy Policy are subject to change without prior notice.
Revisions will take effect when they are posted on our website unless specified otherwise by us.

12/2019

Modalis