Introduction
Welcome to Ono's privacy policy.
Ono respects your privacy and is committed to protecting your personal data. This privacy policy will informyou as to how we look after your personal data when you visit our website (regardless of where you visit itfrom) and tell you about your privacy rights and how the law protects you.

1.

Important information and who we are

Purpose of this privacy policy
This privacy policy aims to give you information on how Ono collects and processes your personal data
through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing
policy we may provide on specific occasions when we are collecting or processing personal data about you
so that you are fully aware of how and why we are using your data. This privacy policy supplements othernotices and privacy policies and is not intended to override them.
Ono is made up of different legal entities. This privacy policy is issued on behalf of the Ono Group so when
we mention "Ono", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in theOno Group responsible for processing your data. Ono Pharmaceutical Co., Ltd is the controller andresponsible for this website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to thisprivacy policy. If you have any questions about this privacy policy, including any requests to exercise yourlegal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy
manager in the following ways:
Full name of legal entity: Ono Venture Investment, Inc.
Email address: info@onoventure.com
Postal address: 930 Brittan Avenue, Suite 303, San Carlos, CA 94070, USA
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on December 25th , 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if
your personal data changes during your relationship with us.

1Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control
these third-party websites and are not responsible for their privacy statements. When you leave our website,
we encourage you to read the privacy policy of every website you visit.

2.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person
can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together as follows:Identity Data includes [first name, maiden name, last name, username or similar identifier,marital status, title, date of birth and gender].

Contact Data includes [billing address, delivery address, email address and telephonenumbers].

Technical Data includes [internet protocol (IP) address, your login data, browser type andversion, time zone setting and location, browser plug-in types and versions, operating systemand platform, and other technology on the devices you use to access this website].

Profile Data includes [your username and password, purchases or orders made by you, yourinterests, preferences, feedback and survey responses].

Usage Data includes [information about how you use our website, products and services].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as
this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific website feature. However, if we combine orconnect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat
the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about yourrace or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data). Nor do we collect any
information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you
fail to provide that data when requested, we may not be able to perform the contract we have or are trying
to enter into with you (for example, to provide you with goods or services). In this case, we may have tocancel a product or service you have with us but we will notify you if this is the case at the time.

3.

How is your personal data collected?
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We use different methods to collect data from and about you including through:

4.

Direct interactions. You may give us your Contact Data by filling in forms or by corresponding
with us by post, phone, email or otherwise. This includes personal data you provide when you:
create an account on our website;request marketing to be sent to you;

give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we willautomatically collect Technical Data about your equipment, browsing actions and patterns. We
collect this personal data by using cookies, server logs and other similar technologies. Pleasesee our cookie policy for further details.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal
data in the following circumstances:Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interestsand fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will getyour consent before sending third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data,
and which of the legal bases we rely on to do so. We have also identified what our legitimate interests arewhere appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specificpurpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out inthe table below.
Purpose/Activity
To registercustomeryou

Type of dataasa

Lawful basis for processing including
basis of legitimate interest

new (a) Identity

Performance of a contract with you(b) Contact

To process and deliver your order (a) Identity
including:(b) Contact(a) Manage payments, fees and(c) Financialcharges(d) Transaction(b) Collect and recover money(a) Performance of a contract with you(b) Necessary for our legitimate interests(to recover debts due to us)

3owed to us(e)MarketingCommunicationsTo manage our relationship with (a) Identity
you which will include:(b) Contact(a) Notifying you about changes(c) Profile
to our terms or privacy policy(d)Marketing(b) Asking you to leave a review
Communications
or take a survey

and(a) Performance of a contract with you(b) Necessary to comply with a legal
obligation
andTo enable you to partake in a (a) Identity
prizedraw,
competitionor(b) Contact
complete a survey(c) Profile(c) Necessary for our legitimate interests(to keep our records updated and to study
how customers use our products/services)(a) Performance of a contract with you(b) Necessary for our legitimate interests(to study how customers use ourproducts/services, to develop them andgrow our business)(d) Usage(e)MarketingCommunications

andTo administer and protect our (a) Identity
businessand
thiswebsite(b) Contact(including troubleshooting, dataanalysis,testing,system (c) Technicalmaintenance, support, reportingand hosting of data)(a) Necessary for our legitimate interests(for running our business, provision ofadministration and IT services, network
security, to prevent fraud and in thecontext of a business reorganisation orgroup restructuring exercise)(b) Necessary to comply with a legal
obligation

To deliver relevant website
content and advertisements toyou and measure or understandtheeffectivenessoftheadvertising we serve to you(a) Identity

Necessary for our legitimate interests (tostudy
howcustomers
use
our
products/services, to develop them, togrow our business and to inform ourmarketing strategy)(b) Contact(c) Profile(d) Usage(e)MarketingCommunicationsand(f) Technical
To use data analytics to improve (a) Technicalour website, products/services,(b) Usage
marketing, customer relationships
and experiences

Necessary for our legitimate interests (todefine types of customers for our products
and services, to keep our website updated
and relevant, to develop our business andto inform our marketing strategy)Tomakesuggestionsand (a) Identity
recommendations to you about(b) Contact
goods or services that may be of(c) Technicalinterest to you

Necessary for our legitimate interests (todevelop our products/services and growour business)(d) Usage(e) Profile(f)Marketing4andCommunications
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with theoriginal purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain thelegal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliancewith the above rules, where this is required or permitted by law.

5.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.
Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

Third parties to whom we may choose to sell, transfer or merge parts of our business or ourassets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance withthe law. We do not allow our third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and in accordance with ourinstructions.

6.

International transfers

We share your personal data within the Ono Group.

7.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to yourpersonal data to those employees, agents, contractors and other third parties who have a business need toknow. They will only process your personal data on our instructions and they are subject to a duty ofconfidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you andany applicable regulator of a breach where we are legally required to do so.
58.

Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes wecollected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature andsensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of yourpersonal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy
which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated withyou) for research or statistical purposes, in which case we may use this information indefinitely without
further notice to you.

9.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.
These include the right to:

Request access to your personal data.



Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However,
we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively,
we could refuse to comply with your request in these circumstances.
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What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your rightto access your personal data (or to exercise any of your other rights). This is a security measure to ensurethat personal data is not disclosed to any person who has no right to receive it. We may also contact you to
ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than amonth if your request is particularly complex or you have made a number of requests. In this case, we will
notify you and keep you updated.

10.

Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business toenable us to give you the best service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your consent or are otherwise
required or permitted to by law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of acontract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary forcompliance with a legal obligation that we are subject to.
THIRD PARTIESInternal Third Parties
Other companies in the Ono Group acting as joint controllers or processors and who are based in Japan,United Kingdom, South Korea and Taiwan and provide IT and system administration services andundertake leadership reporting.
External Third Parties
Service providers acting as processors based in Japan, United States of America, UnitedKingdom, South Korea and Taiwan who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers,
auditors and insurers based in Japan, United States of America, United Kingdom, South Korea
and Taiwan who provide consultancy, banking, legal, insurance and accounting services.

YOUR LEGAL RIGHTS
You have the right to:7

Request access to your personal data (commonly known as a "data subject access request"). This
enables you to receive a copy of the personal data we hold about you and to check that we are lawfully
processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete
or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new datayou provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have the right to ask us to delete or
remove your personal data where you have successfully exercised your right to object to processing (seebelow), where we may have processed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not always be able to comply with yourrequest of erasure for specific legal reasons which will be notified to you, if applicable, at the time of yourrequest.
Object to processing of your personal data where we are relying on a legitimate interest (or those of athird party) and there is something about your particular situation which makes you want to object toprocessing on this ground as you feel it impacts on your fundamental rights and freedoms. You also havethe right to object where we are processing your personal data for direct marketing purposes. In somecases, we may demonstrate that we have compelling legitimate grounds to process your information which
override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend theprocessing of your personal data in the following scenarios:If you want us to establish the data's accuracy.



Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party
you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that
this right only applies to automated information which you initially provided consent for us to use or where
we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However,this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you
withdraw your consent, we may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.

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