Privacy Policy

We are a Controller of the personal data you (data subject) provide us. We collect the following types of personal data from you:

• Name
• Account details and contact information
• Postal Address
• Telephone Number or fax number
• Email address and other identifying addresses for electronic communications
• Date of birth In the course of providing certain Services, we may also receive from you, or third parties, information including:
• Employment related information (salary information, stock options, shareholdings, pension, and CVs);
• Family information

We need to collect and process Personal Data in order to provide the requested Services, or because we are legally required to do. If we do not receive the information that we request, we may not be able to provide the requested Services. We may use Personal Data for our legitimate business interests, including the following:

• To validate authorized signatories when concluding agreements and transactions;
• To contact nominated individuals in connection with the existing transactions and contractual agreements;
• To respond to enquiries and fulfill requests from our clients and/or relevant third parties who require information as a necessary part of the provision of the Services, and to administer account(s) and manage our relationships;
• To inform our clients about products or services which we believe may be of interest, including tailored ads, marketing proposals or offers;
• To verify an individual’s identity and/or location (or the identity or location of our client’s representative or agent );
• To protect the security of accounts and Personal Data;
• For information and relationship management purposes, and business purposes, including data analysis, audits, developing and improving products and services, identifying usage trends and determining the effectiveness of promotional campaigns, and enhancing, improving or modifying our Services;
• For risk management, compliance with our legal and regulatory obligations and for fraud detection, prevention and investigation, due diligence and verification requirements and tax reporting;
• To comply with laws and regulations (including any legal or regulatory guidance, codes or opinions), and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions);
• To provide, and perform our obligations with respect to, the Services or otherwise in connection with fulfilling instructions; and
• To send administrative information to clients, such as changes to our terms, conditions and policies.

Your personal data is processed by us in each corresponding location. Personal Data may be disclosed to third parties in connection with the Services we are providing. The recipients of any such information will depend on the Services that are being provided. Subject to any restrictions around confidentiality we have expressly agreed with our client or other transaction parties, such disclosures may include disclosures:

• To affiliates and subsidiaries of Linical USA, Inc. and Linical Europe Holding GmbH;
• To our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services;
• To third party experts and advisers (including external legal counsel, notaries, auditors and tax advisers);
• To payment, banking and communication infrastructure providers, financial institutions or intermediaries;
• To third party distribution platforms and to operators of private and common carrier communication or transmission facilities, mail or courier services;
• To other deal/transaction participants including issuers, borrowers, potential investors and prospectuses and marketing materials and translation service providers;
• Other persons as agreed with our client or as required or expressly permitted by applicable law.

In additions, we may use, disclose or transfer Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business to third parties as requested by clients or their representatives.

We will retain Personal Data for as long as needed or permitted in light of the purposes for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our client and provide services; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory requirements).

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be 100% secure. If you have reason to believe that your Personal Data is no longer secure, please immediately notify us in accordance with the “What are your rights?” section below.

You have the right to request details about the information we collect about you. If you would like to request to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data (to the extent this right to data portability is provided to you by applicable law), you may contact us.

In the event that you wish to exercise your rights about how we have handled your personal data, please contact Data Protection Officer in writing at dataprotection@linical.com or at:Data Protection Officer Calle Las Norias 92, 2ª planta. Edificio Nuestra Señora del Pilar 28221 Majadahonda (Madrid) Spain

To help us to manage your query, please include your full name and the location of the Linical office that processed your personal data.

Personal Data may be stored and processed in any country where we have facilities or engage service providers to include the United States and Japan. If you are located in the European Economic Area (EEA): Some none-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries are available in this link: Adequacy decisions (europa.eu)).

For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect Personal Data. You may obtain a copy of these measures by following this link: Standard Contractual Clauses (SCC) (europa.eu).

Our services are not directed to individuals under the age of eighteen (18), we do not knowingly collect Personal Data from individuals under 18.

We do not typically collect sensitive Personal Data. Please do not send any Personal Data which would be categorized as special data under GDPR (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).

We may change this Privacy Notice, including the list of affiliates where required. Any changes will become effective when we post the revised Privacy Notice.

Basic Policy

Linical Co.,Ltd. (hereinafter referred to as “Linical”) is, as a company involved in medical and health care, fully aware of the importance of personal information, and will comply with the Act on the Protection of Personal Information of Japan, applicable domestic and international laws, regulations, guidelines regarding protection of personal information (hereinafter collectively referred to as “Laws and Regulations”) and related company regulations, and will make efforts to properly protect and manage personal information based on this Privacy Policy.

Acquisition of Personal Information

Linical will acquire personal information in a lawful and appropriate manner.

Security Management

Linical will prevent the leakage, loss, or destruction of personal information by taking security control measures from all aspects, including institutional, human security control, physical, and technical measures in order to handle personal information appropriately. In addition, Linical will periodically review the security control measures.

Subcontracting

Linical may subcontract the acquisition, use, or handling of personal information to third parties. In those cases, Linical will appropriately supervise the contractors.

(1) Name of business operator: Linical Co., Ltd.
(Please refer to the company profile for the address and name of the representative.)
(2) Purposes of use
① Personal information of pharmaceutical companies, medical equipment manufacturing companies, various research institutes (including hospitals and universities), site management organizations and any other persons related to clinical trials or clinical research

• To execute the entrusted business
• To consider business opportunities
• To conduct research and study in medical and pharmaceutical fields
• To contact for business activities and other related matters
• To respond to the government sector

② Personal information of service providers and consultants

• To execute contracts with service providers or consultants
• To consider business opportunities
• To conduct vendor management
• To contact for business activities and other related matters
• To respond to the government sector

③ Personal information of applicants for employment and internships

• To screen candidates for employment, and provide information and procedures regarding internships
• To inform pre-employment procedures and other necessary matters after the employment decision
• To contact and provide information

④ Personal information of Linical’s and its affiliates’ former or present officers and employees and their families

• To manage personnel and labor affairs, evaluations, salary and compensation payments, benefits, awards, punishments, training, relocations, assignments　and other related matters
• To contact for business or in emergency
• To conduct business administration
• To fulfill the obligation of security, such as management of health and safety in the workplace
• To respond to government sectors
• To investigate and keep record in accordance with the Laws and Regulations

⑤ Personal information of shareholders and investors (hereinafter collectively referred to as “Shareholders”)

• To respond to the exercise of Shareholders' rights and fulfill the Linical's obligations, in accordance with the Companies Act (including other related laws and regulations)
• To manage shareholders, including the preparation of shareholder data in accordance with prescribed standards under the Companies Act (including other related laws and regulations)
• To provide various information and services to shareholders
• To implement various policies including questionnaire surveys, to facilitate the relationship between Shareholders and Linical
• To respond to various inquiries or offers
• To provide and communicate various information related to IR activities, including the provision and transmission of company publications

⑥ Personal information related to persons who use Linical's website or other contact points

• To examine, investigate and respond to inquiries
• To provide, collect, and review various types of information related to Linical's corporate activities

Linical shall not provide personal data to third parties except under the following circumstances.
① Cases in which the concerned person's prior consent is obtained
② Cases in which the information is disclosed or provided in a form in which the individual identities of persons concerned cannot be discerned
③ Cases in which Linical entrusts third parties to the extent necessary to achieve the purpose of use
④ Cases in which Linical takes necessary action required by law, and to the extent necessary to achieve the purpose of use
⑤ Cases in which the provision is requested by the Laws and Regulations
⑥ Cases in which the provision is permitted by any other conditions in law

Linical shall jointly use the personal information as follows;
① Name of the entities responsible for the joint use Linical Co., Ltd. (Please refer to the company profile for the address and name of the representative.)
② Purposes of use Purposes prescribed in “The Handling of Personal Information, (2) Purposes of use”.
③ Range of the joint use Group companies belonging to Linical Co., Ltd. (Please refer to the Linical Group page for a list of group companies.)
④ Items of personal information which are used jointly Name, gender, date of birth, address, zip code, phone number, e-mail address, work experience, personnel information, and other items required for the purposes of use set forth above.