Otsuka Precision Health, Inc.
Privacy Policy
Contents
Otsuka Precision Health, Inc. Privacy Policy ........................................................................... 1
1.1 Purpose...................................................................................................................................... 2
1.2 Scope ......................................................................................................................................... 3
1.3 Mobile Messaging Programs .................................................................................................... 3
2.0 Transparency/Notice–What Personal Information We Collect and How We Use It................ 4
2.1 Individuals................................................................................................................................. 4
2.2 Information Otsuka Collects ..................................................................................................... 4
2.3 How Otsuka Collects Personal Information ............................................................................. 5
2.4 Information from External Sources .......................................................................................... 6
2.5 Research/Survey Solicitations .................................................................................................. 6
2.6 How Otsuka Uses Your Personal Information.......................................................................... 7
2.7 Social Media ............................................................................................................................. 8
2.8 Marketing Communication ....................................................................................................... 9
2.9 All Internet Users – Cookies, Pixel Tags/Web Beacons, Analytics Information, and InterestBased Advertising ........................................................................................................................... 92.9.1 Cookies .............................................................................................................................. 92.9.2 Pixel Tags/Web Beacons ................................................................................................ 10
2.9.3 Analytics Information.................................................................................................... 10
2.9.4 Interest-Based Advertising............................................................................................ 10
2.10 Mobile Devices ..................................................................................................................... 11
2.11 De-Identified and Aggregated Information .......................................................................... 11
3.0 Choice/Methods to Opt Out .................................................................................................... 12
3.1 Communications ..................................................................................................................... 12
3.2 "Do Not Track" ....................................................................................................................... 12
3.3 Advertising Choices ................................................................................................................ 12
4.0 Onward Transfer: .................................................................................................................... 13
4.1 Information We Disclose ........................................................................................................ 13

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4.1.1 Service Providers ........................................................................................................... 14
4.1.2 Business Partners ........................................................................................................... 14
4.1.3 Information Disclosed to Non-affiliated Parties for Our Protection and theProtection of Others ................................................................................................................ 14
4.1.4 Information Disclosed in Connection with Business Transactions ........................... 15
4.2 Data Transfers ......................................................................................................................... 15
5.0 Your Privacy Rights................................................................................................................ 15
5.1 Supplemental Notice for Residents of Certain U.S. States ..................................................... 16"Sales" of Personal Information ........................................................................................... 24
Sensitive Personal Information.............................................................................................. 26
Additional Privacy Rights for Virginia, Colorado, and Connecticut Residents ............... 26
5.2 Supplemental Notice for Nevada Residents ........................................................................... 27
5.3 Washington & Nevada My Health My Data Act Disclosures. ............................................... 27
6.0 Retention ................................................................................................................................. 28
7.0 Security ................................................................................................................................... 29
8.0 Redress/Compliance and Accountability ................................................................................ 29
9.0 Other Rights and Important Information ................................................................................ 29
9.1 Information Regarding Children ............................................................................................. 29
9.2 Links to External Websites ..................................................................................................... 30
9.3 Compliance ............................................................................................................................. 30
9.4 Changes to the Privacy Policy ................................................................................................ 30

Overview
1.1 Purpose
Otsuka Precision Health, Inc. ("Otsuka," the "Company," "we", "our" or "us") issensitive to privacy issues, and it is important to us to protect the information
provided to us. Accordingly, Otsuka provides this privacy and information practices
policy ("Privacy Policy") to inform you about our online and mobile information
practices, the kinds of information we may collect, how we intend to use and sharethat information, and how you can correct or change such information. We encourage
you to read this Privacy Policy in its entirety before submitting any information.

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By continuing to use our websites, or submitting or requesting information, you
acknowledge that you understand and agree with the provisions of this Privacy Policy.
If you are unable to review or access this Privacy Policy due to a disability, you may
contact us to request access to this Privacy Policy in an alternative format. Please call
1-833-468-7852 or email privacyofficer@otsuka-oph.com.
1.2 ScopeThis Privacy Policy applies to Personal Information that is collected, used, andretained by Otsuka in the course of our business, including on Company websites(together with any and all future websites) and through the short code mobile
messaging programs operated by or on behalf of Otsuka (collectively, the “Sites”). All
individuals whose responsibilities include the processing of Personal Information on
behalf of Otsuka are expected to protect that data by adherence to this Privacy
Policy.
1.3 Mobile Messaging Programs
You may decide to subscribe to one of our short code mobile message programs(each, a “Program” and together, the “Programs”) to receive SMS/text messages from
Otsuka. If you choose to opt-in and consent, such as by providing your telephone
number to us and clicking submit online, or texting the join code to join to any of our
five- or six-digit short code numbers, we will collect information about yourinteractions with the SMS/text messages that we may send to you from time to time aspart of the Program(s) in which you are enrolled.
By subscribing to a Program, you agree to our Terms of Service and the Mobile
Messaging Terms of Service applicable to that Program and authorize us to make or
initiate SMS/text messages to your telephone number using an automated system. If
you wish to receive SMS/text messages through multiple Programs, you must
separately opt-in to each Program.
Otsuka does not sell information that we obtain from you through our Programs,
including Personal Information you submit to us online to consent and opt-in to each
Program, and we do not provide that information with non-affiliated third parties forany purpose other than to provide the products, services, and other information
requested by you, or to fulfill our legal obligations under applicable law. To review
your Advertising Choices in greater detail, please see Section 3.3 of this Privacy
Policy.
For additional information and disclosures about the Program, please see the Mobile
Messaging Terms of Service applicable to you.
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2.0 Transparency/Notice–What Personal Information We Collect and How We
Use It
The types of Personal Information we may collect (directly from you or from externalsources) and our privacy practices depend on the nature of the relationship you havewith Otsuka and the requirements of applicable law. We endeavor to collectinformation only relevant for the purposes of processing. Below are the legal bases
and some of the ways we collect information and how we use it.

2.1 Individuals
Otsuka collects Personal Information regarding its customers, visitors and guests
including website visitors, patients or clinical trial subjects, healthcare providers,
employees, workers or job applicants (collectively "Individuals").

2.2 Information Otsuka Collects
The data we collect from or about Individuals include information that may bedeemed Personal Information (alone or in combination with other Information), suchas name, address, age, birth date, phone number, email address, username,government identification, and payment information.
In addition, if you participate in certain programs or services, we may collectinformation regarding your medications, medical history and other healthcare-related
information, including, without limitation, Protected Health Information (collectively,"Health Information"), from you or others. For example, we may indirectly collectinformation about your health condition, diagnosis, and treatment from yourhealthcare professional, but only where your healthcare professional has obtained
your consent to disclose that information to us, as required by law. Any Health
Information that is tied to an Individual's Personal Information will be treated as
Personal Information, provided that any Protected Health Information will beprotected in accordance with the requirements of HIPAA, if applicable.
For job applicants, we collect Personal Information as described in this Privacy Policy
in conjunction with your application, including: name, address, e-mail address, andother contact information; work authorization status, CV/resume, previous work

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experience and education information; information related to your knowledge andskills; and, other information that you elect to provide. This information is used toprocess your application.
For employees, we collect Personal Information as described in this Privacy Policy inconjunction with your employment with Otsuka, including: name, address, e-mailaddress, other contact information, bank account information, benefits information,and other work-related data. This information is used in connection with youremployment.

2.3 How Otsuka Collects Personal Information
Some of the ways that Otsuka may collect your Personal Information include:
Otsuka may collect Personal Information from you through various channels,
including Sites, in surveys, during business or marketing events, and when delivering
programs and services to you.
When you use the Sites, Otsuka may provide you with opportunities to sign up toreceive specific information or services and may ask for your contact information(e.g., name, home address, home phone number or personal email address), so that we
can send you specific information about our products, services, educational
information and specific health conditions, with your consent.
When you enroll in a program that Otsuka offers, we may obtain your contact
information, details of your health condition, and prescribing information relating toour products.
Otsuka is also obligated to collect certain Personal Information to comply withregulatory requirements, including information relating to adverse effects thatyou have experienced when using our products.
Otsuka may indirectly collect information about your health condition, diagnosis, andtreatment from your healthcare professional, but only where your healthcare
professional has obtained your consent to disclose that information to us, as requiredby law.
We may collect information from physicians and other healthcare providers who
register on our websites in order to verify their licensure status and identity.

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Otsuka may collect various information from healthcare professionals as part ofmarketing activities to healthcare professionals, including first name, last name, age,gender, home address, home phone number, medical specialization, professional
qualifications, license number and scientific society membership number.
As you navigate the Sites, certain passive information may also be collected,
including Internet Protocol addresses, cookies, navigational data, the name of thedomain and host from which you access the Internet, the browser software you use
and your operating system, the date and time you access our Sites, and the Internet
address of the website from which you linked directly to our Sites. This type of
information is used for the purposes of gathering data to provide improved
administration of our Sites, to improve the quality of your experience wheninteracting with our Sites, and to show you personalized content.

2.4 Information from External Sources
Otsuka may collect information about you from external sources to supplement
information provided by you. This supplemental information allows us to verify
information that you have provided to Otsuka and to enhance our ability to provide
you with information about our business, products, services, and educational
information. Otsuka's agreements with these external sources typically limit how the
Company may use this supplemental information.

2.5 Research/Survey Solicitations
From time to time, Otsuka may perform research (online and offline) via surveys. We
may engage external service providers to conduct such surveys on our behalf. All
survey responses are voluntary, and the information collected will be used forresearch and reporting purposes to help us better serve Individuals by learning more
about their needs and the quality of the products, services and educational information
we provide. The survey responses may be utilized to determine the effectiveness of
our Sites, various types of communications, advertising campaigns and/or
promotional activities. If an Individual participates in a survey, the information given
will be used along with that of other study participants. We may share de-identified
and/or aggregate data for research and analysis purposes.

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2.6 How Otsuka Uses Your Personal Information
Depending on how you interact with Otsuka, we, our affiliates Otsuka America
Pharmaceutical, Inc., Otsuka Pharmaceutical Development & Commercialization,Inc., Otsuka America, Inc., and Otsuka Pharmaceutical Co., Ltd. (collectively,“Selected Affiliates”), and our external service providers may also use Personal
Information in a variety of ways, including:
Providing Information and Services You Requested. Otsuka and its Selected Affiliates
may use the Personal Information about you to provide you information that you may
request, e.g., information about a product or program we are offering. Otsuka and its
Selected Affiliates may also use your Personal Information to deliver a specificprogram or service to you, when you enroll to receive the program or service. Suchuse may include: (a) generally managing your information and accounts; (b)responding to questions, comments and requests; (c) providing access to certain areas
and features of the Otsuka Sites; and, (d) permitting you to register for events orparticipate in webinars.
Administrative Purposes. Otsuka and its Selected Affiliates may use the Personal
Information about you for its administrative purposes, including, without limitation,to: (a) measure interest in Otsuka's Site, programs or services; (b) perform internal
quality control; (c) verify identity; (d) send communications regarding the Otsuka
Site, programs or services, your account, or any changes to any Otsuka policy orterms of service; (e) process payments; (f) prevent potentially prohibited or illegal
activities; and, (g) enforce our Terms of Use.
Marketing Products and Services. Otsuka and its Selected Affiliates may use the
Personal Information about you to provide you with materials about offers, products
and services offered by us, including new content or services on Otsuka Sites. Otsuka
may provide you with these materials by phone, postal mail, facsimile or email, as
permitted by applicable law. If you do not wish us to use your Personal Information
for marketing purposes, you may contact us at any time to opt out of the use of your
Personal Information for such purposes, as further described below.
Research and Development. Otsuka and its Selected Affiliates may use your Personal
Information to create de-identified information that we may use alone or in theaggregate with information obtained from other sources, in order to help us to
optimally deliver our existing products and services or develop new products,
processes and services.
Information Submitted Via Sites. You agree that Otsuka is free to use the content of
any communications submitted by you via the Sites, including any ideas, inventions,
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concepts, techniques, or know-how disclosed therein, for any purpose including
developing, manufacturing, and/or marketing goods or services. However, Otsuka
does not release your name or otherwise publicize the fact that you submitted
materials or other information to us unless: (a) you grant us permission to do so; (b)we first send notice to you that the materials or other information you submit to aparticular part of a site will be published or otherwise used with your name on it; or(c) we are required to do so by law.
Disclosing Content to Friends or Colleagues. Otsuka's Sites may offer various tools
and functionality. For example, Otsuka may provide functionality on its Sites that willallow you to forward or disclose certain content with a friend or colleague. Emailaddresses that you may provide for a friend or colleague will be used to send yourfriend or colleague the content or link you request, but will not be collected orotherwise used by Otsuka or any other non-affiliated parties for any other purpose. By
providing us with the information of another individual, you represent that you havethe authority to do so, and permit us to use the information in accordance with thisPrivacy Policy.
Pseudonymous Data. Including as discussed below in Section 2.11, Otsuka may use
and share your anonymized or de-identified information within the Otsuka group ofcompanies or with external vendors for public health, research, analytics and anyother legally permissible purposes.
Automated Profiling. We may use technologies considered automated decision
making or profiling. We will not make automated decisions about you that would
significantly affect you, unless such a decision is necessary as part of a contract wehave with you, we have your consent, or we are permitted by law to use suchtechnology. You may escalate any concerns you have by contacting us at the addressprovided below.
Other Uses. Otsuka may use your Personal Information for other purposes disclosed
to you at the time you provide Personal Information or with your consent.

2.7 Social Media
Generally, online social media resources are interactive tools that enable you tocollaborate with and disclose information to others. Social media resources include,
but are not limited to, social networks, discussion boards, bulletin boards, blogs,
wikis, and referral functions to exchange website content and tools with a friend orcolleague.
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Otsuka may collect Personal Information to enable you to use online social media
resources offered by Otsuka, its Selected Affiliates or an external vendor. We may
also enable you to use these social media resources to post or disclose Personal
Information with others. When using social media resources, you should take into
careful consideration what Personal Information you disclose to others.
If you use online social media resources offered by an external Social Media Resource("External SMR") through the Otsuka Site, you acknowledge that Otsuka may be able
to access any information you make public through such External SMR (such as yourusername, comments, posts and contacts) and other information your privacy settings
on such External SMR permit Otsuka to access. Otsuka will comply with the terms ofthis Privacy Policy and the privacy policies applicable to any External SMR
information Otsuka accesses.

2.8 Marketing Communication
Individuals who provide us with Personal Information, or whose Personal Information
we obtain from external vendors, may receive periodic marketing communications
such as emails from us with information on Otsuka, its Selected Affiliates or ourbusiness partners' products and services or upcoming special offers/events we believe
may be of interest. We offer the option to decline or opt out of these communications
at no cost to the individual.
Disclosure About Direct Marketing for California Residents. California Civil Code §1798.83 permits California residents to annually request certain information regarding
our disclosure of Personal Information to other entities for their direct marketing
purposes in the preceding calendar year. To make such a request, please send an email
to privacyofficer@otsuka-oph.com with the subject “Shine the Light Request.”

2.9 All Internet Users – Cookies, Pixel Tags/Web Beacons, Analytics
Information, and Interest-Based Advertising

2.9.1 Cookies
Like many other websites, Otsuka, its Selected Affiliates or its external vendors orservice providers may employ a cookie, or small piece of computer code that enables
Web servers to "identify" visitors, each time an Individual initiates a session on the

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Company's Sites. A cookie is set in order to: identify Individuals; tailor our Sites toyou; measure and research the effectiveness of our Sites' features, offerings andadvertisements; and, authenticate users for registered services. In addition, Otsuka, its
Selected Affiliates or its external vendors or service providers may collect informationfrom your browser or device for interest-based advertising, using cookies or similar
technologies. Cookies can only access Personal Information that you have provided
on our Sites and cannot be accessed by other sites. You also have the ability to delete
cookie files from your own hard drive at any time by clicking on the Privacy or
History tab typically found on the Settings or Options menu in your internet browser.
However, please also be advised that cookies may be necessary to provide access tomuch of the content and many of the features of Otsuka's Sites. To learn more aboutcookies, visit http://www.allaboutcookies.org.

2.9.2 Pixel Tags/Web Beacons
Otsuka may use "pixel tags," also known as "web beacons," which are small graphic
files that allow us to monitor the use of our Sites. A pixel tag can collect informationsuch as: the Internet Protocol ("IP") address of the computer that downloaded the pageon which the tag appears; the URL of the page on which the pixel tag appears; thetime the page containing the pixel tag was viewed; the browser type and language; thedevice type; geographic location; and, the identification number of any cookie on thecomputer previously placed by that server. When corresponding with you via HTMLcapable email, we or our external vendors or service providers may use "format
sensing" technology, which allows pixel tags to let us know whether you received andopened our email.

2.9.3 Analytics Information
We may also use Google Analytics and Google Analytics Demographics and Interest
Reporting to collect information regarding visitor behavior and visitor demographics
on some of our Sites, and to develop website content. For more information about
Google Analytics, please visit www.google.com/policies/privacy/partners/. You can
opt out of Google's collection and processing of data generated by your use of theServices by going to http://tools.google.com/dlpage/gaoptout.

2.9.4 Interest-Based AdvertisingThrough our Sites, in certain instances, such as with your consent, Otsuka allows ouradvertising partners to set tracking tools (e.g., cookies) to collect information
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regarding your activities (e.g., your IP address, page(s) visited, time of day). We may
also share such information we have collected with our advertising partners. These
advertising partners may use this information (and similar information collected fromother websites) for purposes of delivering targeted advertisements to you when you
visit non-Otsuka related websites within their networks. This practice is commonlyreferred to as "interest-based advertising" or "online behavioral advertising."

2.10 Mobile Devices
Otsuka may provide websites and online resources that are specifically designed to becompatible with and used on mobile devices. Otsuka will collect certain informationthat your mobile device sends when you use such websites or online resources, like adevice identifier, user settings and the operating system of your device.
Mobile versions of Otsuka's Sites may require that users log in with an account. In
such cases, information about use of each mobile version of the website may be
associated with user accounts. In addition, Otsuka may enable Individuals to
download an application, widget or other tool that can be used on mobile or othercomputing devices. Some of these tools may store information on mobile or otherdevices. These tools may transmit Personal Information to Otsuka to enable
Individuals to access user accounts and to enable Otsuka to track use of these tools.
Some of these tools may enable users to email reports and other information from thetool. Otsuka may use personal or non-identifiable information transmitted to theCompany to enhance these tools, to develop new tools, for quality improvement andas otherwise described in this Privacy Policy or in other notices Otsuka provides.

2.11 De-Identified and Aggregated Information
Otsuka may use your Personal Information and other information about you to create
de-identified and aggregated information, such as de-identified demographic
information, de-identified location information, information about the computer or
device from which you access the Otsuka Site or other online services, or otheranalyses we create. De-identified and aggregated information is used for a variety offunctions, including the measurement of visitors' interest in and use of various
portions or features of the Sites. De-identified or aggregated information is not
Personal Information, and Otsuka may use such information in a number of ways,
including research, internal analysis, analytics and any other legally permissible
purposes. We may share this information within Otsuka, its Selected Affiliates andMarch 2024

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with external vendors or service providers for our or their purposes in a de-identified
or aggregated form that is designed to prevent anyone from identifying you. We will
maintain, process, and use this data in its deidentified form, and will not attempt toreidentify you from it.

3.0 Choice/Methods to Opt Out
You have the right to opt out of certain uses and disclosures of your Personal
Information, as set out in this Privacy Policy. Where you have consented to Otsuka's
processing of your Personal Information you may withdraw that consent at any timeand opt out by following the included opt out instructions.

3.1 Communications
An "Unsubscribe" option will be provided on certain communications by Otsuka so
you can opt out of future communications. However, we may continue to sendtransaction-related communication regarding products or services you have requested
in response to such request. We may need to send you certain communications
regarding the Otsuka programs and services and you will not be able to opt out of
those communications.

3.2 "Do Not Track"
Do Not Track ("DNT") is a privacy preference that users can set in certain web
browsers. DNT is a way for users to inform websites and services that they do notwant certain information about their webpage visits collected and used over time andacross websites or online services. Otsuka recognizes and responds to browserinitiated DNT signals sent by consumers’ devices and browsers. Additional
information about how Otsuka responds to certain opt-out preference signals is
described in Section 5.1 below. For information about "do-not-track",
visit http://www.allaboutdnt.org.

3.3 Advertising Choices

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If you choose to subscribe to any Program(s) through which you provide to us your
Personal Information, Otsuka does not sell or share that information with third parties,
and such information may not be used by third parties for their own marketing
purposes. Otsuka may, however, disclose that information to its corporate affiliates,
subsidiaries, vendors, and service providers to provide you with the SMS/text
messaging service, to process and respond to your inquiries or requests, to comply
with our legal obligations under applicable law, and for any other purpose to which
you have consented to.
Except as described in the preceding paragraph, Otsuka may use information related
to your online browsing activities for interest-based advertising purposes. The online
advertising industry provides websites from which you may opt out of receiving
targeted ads from participants’ self-regulatory programs. You can access thesewebsites and learn more about targeted advertising and consumer choice and privacy,
at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To
separately make choices for mobile apps on a mobile device, you can download
DAA's AppChoices application from your device's app store. Alternatively, for somedevices you may use your device's platform controls in your settings to exercise
choice.
Please note you must separately opt out in each browser and on eachdevice. Advertisements on external websites that contain the AdChoices link may
have been directed to you based on information collected by advertising partners overtime and across websites. These advertisements provide a mechanism to opt out of
the advertising partners' use of this information for interest-based advertising
purposes.
Even if you opt-out, we may still collect and use information regarding your browsing
activities on our Sites and/or information from the advertisements on external
websites for non-interest-based advertising purposes, such as to determine theeffectiveness of the advertisements.

4.0 Onward Transfer:

4.1 Information We Disclose

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Otsuka does not sell your Personal Information. Except as provided below, Otsuka
does not disclose Personal Information about you absent your consent. Otsuka
endeavors to require external vendors or service providers to which it discloses
Personal Information to protect Personal Information using substantially-similar
standards to those required by Otsuka, and to notify Otsuka if they make adetermination that they can no longer meet this obligation.

4.1.1 Service Providers
Otsuka may share Personal Information with our service providers that we haveretained to perform services on our behalf including: (i) provision of IT and related
services; (ii) provision of information and services you have requested; (iii) payment
processing; and, (iv) customer service activities. Payment information will be usedand shared only to effectuate your order and may be stored by a service provider for
purposes of future orders.
Otsuka executes contracts with service providers prohibiting them from using or
sharing your Personal Information except as necessary to perform the contracted
services on our behalf or to comply with applicable legal requirements.

4.1.2 Business Partners
Otsuka may disclose Personal Information to our affiliates (including, without
limitation, the Selected Affiliates) for our and our affiliates’ internal businesspurposes or to provide you with a product, service or educational information that you
have requested. Otsuka may also provide Personal Information to business partners
with whom we may jointly offer products, services, or educational information orwhose products or services we believe may be of interest to you. In such cases, ourbusiness partner’s name will appear, along with Otsuka’s. Otsuka requires ouraffiliates and business partners to agree to maintain the confidentiality and security of
Personal Information they maintain on our behalf and not to use it for any purpose
other than the purpose for which it was provided.

4.1.3 Information Disclosed to Non-affiliated Parties for Our Protection and theProtection of Others
We may disclose information about you to non-affiliated parties: (i) if we are required
to do so by law, court order or legal process; (ii) in response to lawful requests by
public authorities, including to meet national security or law enforcement
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requirements; (iii) under the discovery process in litigation; (iv) to enforce Otsuka
policies or contracts; (v) to collect amounts owed to Otsuka; (vi) when we believe
disclosure is necessary or appropriate to prevent physical harm or financial loss or inconnection with an investigation or prosecution of suspected or actual illegal activity;or, (vii) if we, in good faith, believe that disclosure is otherwise necessary oradvisable. In addition, from time to time, server logs may be reviewed for security
purposes, e.g., to detect unauthorized activity on the Sites. In such cases, server log
data containing IP addresses may be shared where applicable with law enforcement
bodies in order that they may identify users in connection with their investigation of
the unauthorized activities.

4.1.4 Information Disclosed in Connection with Business Transactions
We reserve the right to disclose or transfer any information we have about you in theevent of a proposed or actual purchase, any reorganization, sale, lease, merger, joint
venture, assignment, amalgamation or any other type of acquisition, disposal or
financing of all or any portion of our business or of any of the business assets orshares (including in connection with any bankruptcy or similar proceeding). Shouldsuch an event occur, Otsuka will endeavor to direct the transferee to use Personal
Information in a manner that is consistent with this Privacy Policy.

4.2 Data Transfers
All Personal Information sent or collected via or by Otsuka may be stored anywherein the world, including but not limited to, in the United States, in the cloud, ourservers, the servers of our affiliates or the servers of our service providers. We
will endeavor that any such transfers of Personal Information of an individual residingin the European Union outside of the European Economic Area will only be madewhere appropriate safeguards have been put in place.
Your Personal Information may be accessible to law enforcement or other authorities
pursuant to a lawful request. By providing information to Otsuka, you consent to thestorage of your Personal Information in these locations.

5.0 Your Privacy Rights

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We encourage you to update the information you provide to us, such as providing uswith a new mailing or email address, a name change, or a change in other material
information you have notified us about. This will help us continue to provide
information to you that best meets your needs.
In accordance with applicable law, you may have the right to: (i) request confirmationof whether we are processing Personal Information about you; (ii) obtain access to ora copy of your Personal Information; (iii) receive an electronic copy of Personal
Information that you have provided to us, or ask us to send that information to anothercompany (the "right of data portability"); (iv) restrict our uses of your Personal
Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or
improperly processed Personal Information; (vi) withdraw your consent; and, (vii)
request erasure of Personal Information held about you by us, subject to certain
exceptions prescribed by law.
If you or your authorized representative would like to exercise any of these rights,
please contact us as set forth below. We will process such requests in accordance withapplicable laws. To protect your privacy, we will take steps to verify your identity,
including requiring proof of identity before fulfilling request(s). Although Otsuka
makes good faith efforts to provide Individuals with access to their Personal
Information, there may be circumstances in which Otsuka is unable to provide access,including but not limited to: where the information contains legal privilege, where it
would compromise others' privacy or other legitimate rights, where the burden or
expense of providing access would be disproportionate to the risks to the Individual's
privacy in the case in question, or where it is commercially proprietary. If Otsuka
determines that access should be restricted in any particular instance, we will provide
you with an explanation of why that determination has been made and a contact point
for any further inquiries.
Otsuka does not discriminate or retaliate against anyone for exercising their individual
rights under applicable laws, rules, or regulations.

5.1 Supplemental Notice for Residents of Certain U.S. States
This Supplemental Notice only applies to our processing of Personal Information ofresidents of California, Colorado, Virginia, Utah, Connecticut, Montana, Tennessee,
and Texas. It provides information required under the privacy laws of those ten states–the California Consumer Privacy Act of 2018 ("CCPA"), the Colorado Privacy Act(“CPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Utah
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Montana Consumer Data Privacy Act (“MCDPA”), the Tennessee Information
Protection Act (“TIPA”) and the Texas Data Privacy and Security Act (“TDPSA”)(collectively, the “U.S. Privacy Laws”). Some portions of this Supplemental Notice
apply only to residents of particular states. In those instances, we have indicated thatsuch language applies only to those residents.
These state laws provide their residents with the right to receive a notice before or at
the time we collect Personal Information from them of the Personal Information(including Sensitive Personal Information) to be collected, the purpose for which weuse it, whether or not that Personal Information is sold or shared, and the length oftime we intend to retain each category of Personal Information. This Supplemental
Notice is intended to satisfy this requirement.
These state laws also provide their residents with the right to know the categories of
Personal Information we have collected about them, the categories of sources of that
information, the external vendors or service providers to whom we have disclosed
their Personal Information, and the business or commercial purpose for collecting or
disclosing the Personal Information. The information provided below is intended toserve this purpose.
Under these state laws, residents of California, Colorado, Virginia, Utah,
Connecticut, Montana, Tennessee, and Texas also have the following rights:• The right to request a copy of the Personal Information we have collected(including to request a copy in a portable format).
• The right to correct inaccurate Personal Information that we maintain aboutthem.
• The right to delete Personal Information that we have collected from them,subject to certain exceptions.
• The right to opt-out of the sale of their Personal Information.
• The right to opt-out of the use and sharing of their Personal Information fortargeted advertising across non-affiliated websites or applications.
• The right to opt-out of the use of their Personal Information for purposes of
profiling in furtherance of decisions that produce legal or similarly significant
effects.
• The right to restrict the processing of their Sensitive Personal Information.
An explanation of how to exercise the above rights is provided below.

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Personal Information Details for Website Visitors

Category of Personal Information
Collected by Otsuka
Identifiers.
A real name, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name,Social Security number, or other similar identifiers.
Personal information categories listed in state laws governing thesecurity of customer records
A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver's
license or state identification card number, insurance policy number,
education, employment, employment history, bank account number,credit card number, debit card number, or any other financial
information, medical information, or health insurance information.
Protected classification characteristics under state or federal law
Age (40 years or older), race, color, ancestry, national origin,citizenship, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information).
Commercial information
Records of products or services purchased, obtained, or considered, orother purchasing or consuming histories or tendencies.
Biometric information
Physiological, biological, or behavioral, characteristics, including
information pertaining to an individual’s deoxyribonucleic acid (DNA),
that is used or intended to be used singly or in combination with eachother or with other identifying data, including diagnostic or lab results,
imagery of the face or hand from which an identifier template can beextracted and sleep, health or exercise data that contain identifying
information.
Internet or other electronic network activity
Browsing history, search history, information on a consumer's
interaction with an internet website, application, or advertisement.
Geolocation data
Physical location or movements.

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose
•
•
•

•
•
•

•
•
•

•
•
•

Government entities
Service providers
Business partners

Government entities
Service providers
Business partners

Government entities
Service providers
Business partners
Government entities
Service providers
Business partners•

Service providers
Business partners•

Service providers•

Service providers
Business partners••

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Category of Personal Information
Collected by Otsuka
Electronic and Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information(e.g., a recording of a customer service call or profile photograph).
Professional or employment-related information
Current or past job history or performance evaluations.
Education information
An individual’s education information, including academic
information and records.
Inferences
Inferences drawn from any of the information identified in thissubdivision to create a profile about a consumer reflecting theconsumer’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, andaptitudes.
Sensitive Personal Information
Personal information that reveals your social security, driver’s license,
state identification card, or passport number, precise geolocation,
racial or ethnic origin, genetic information (including familial genetic
information), medical condition, physical or mental disability, sex life
(including pregnancy or childbirth and related medical conditions),
and sexual orientation.

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose•

Service providers••

Service providers
Business partners•

Service providers•

Service providers
Business partners

•

•
•
•

Government entities
Service providers
Business partners

Personal Information Details for Patients or Clinical Trial Subjects

Category of Personal Information
Collected by Otsuka
Identifiers.
A real name, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name,Social Security number, or other similar identifiers.
Personal information categories listed in state laws governing thesecurity of customer records

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose•

Government entities
Service providers
Business partners•

Government entities••

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Category of Personal Information
Collected by Otsuka
A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver's
license or state identification card number, insurance policy number,
education, employment, employment history, bank account number,credit card number, debit card number, or any other financial
information, medical information, or health insurance information.
Protected classification characteristics under state or federal law
Age (40 years or older), race, color, ancestry, national origin,citizenship, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information).
Commercial information
Records of products or services purchased, obtained, or considered, orother purchasing or consuming histories or tendencies.
Biometric information
Physiological, biological, or behavioral, characteristics, including
information pertaining to an individual’s deoxyribonucleic acid (DNA),
that is used or intended to be used singly or in combination with eachother or with other identifying data, including diagnostic or lab results,
imagery of the face or hand from which an identifier template can beextracted and sleep, health or exercise data that contain identifying
information.
Internet or other electronic network activity
Browsing history, search history, information on a consumer's
interaction with an internet website, application, or advertisement.
Geolocation data
Physical location or movements.
Electronic and Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information(e.g., a recording of a customer service call or profile photograph).
Professional or employment-related information
Current or past job history or performance evaluations.
Education information
An individual’s education information, including academic
information and records.

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose
•
•

•
•
•

•
•
•

Service providers
Business partners

Government entities
Service providers
Business partners
Government entities
Service providers
Business partners•

Service providers
Business partners•

Service providers•

Service providers
Business partners

•

•
•

•

Service providers
Business partners•

Service providers•

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Category of Personal Information
Collected by Otsuka
Inferences
Inferences drawn from any of the information identified in thissubdivision to create a profile about a consumer reflecting theconsumer’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, andaptitudes.
Sensitive Personal Information
Personal information that reveals your social security, driver’s license,
state identification card, or passport number, precise geolocation,
racial or ethnic origin, genetic information (including familial genetic
information), medical condition, physical or mental disability, sex life
(including pregnancy or childbirth and related medical conditions),
and sexual orientation.

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose
•
•

•
•
•

Service providers
Business partners

Government entities
Service providers
Business partners

Personal Information Details for Healthcare Professionals

Category of Personal Information
Collected by Otsuka
Identifiers.
A real name, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name,Social Security number, or other similar identifiers.
Personal information categories listed in state laws governing thesecurity of customer records
A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver's
license or state identification card number, insurance policy number,
education, employment, employment history, bank account number,credit card number, debit card number, or any other financial
information, medical information, or health insurance information.
Protected classification characteristics under state or federal law
Age (40 years or older), race, color, ancestry, national origin,citizenship, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression,

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose
•
•
•

•
•
•

•
•

Government entities
Service providers
Business partners

Government entities
Service providers
Business partners

Government entities
Service providers

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Category of Personal Information
Collected by Otsuka
pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information).
Commercial information
Records of products or services purchased, obtained, or considered, orother purchasing or consuming histories or tendencies.
Biometric information
Physiological, biological, or behavioral, characteristics, including
information pertaining to an individual’s deoxyribonucleic acid (DNA),
that is used or intended to be used singly or in combination with eachother or with other identifying data, including diagnostic or lab results,
imagery of the face or hand from which an identifier template can beextracted and sleep, health or exercise data that contain identifying
information.
Internet or other electronic network activity
Browsing history, search history, information on a consumer's
interaction with an internet website, application, or advertisement.
Geolocation data
Physical location or movements.
Electronic and Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information(e.g., a recording of a customer service call or profile photograph).
Professional or employment-related information
Current or past job history or performance evaluations.
Education information
An individual’s education information, including academic
information and records.
Inferences
Inferences drawn from any of the information identified in thissubdivision to create a profile about a consumer reflecting theconsumer’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, andaptitudes.
Sensitive Personal Information
Personal information that reveals your social security, driver’s license,
state identification card, or passport number, precise geolocation,
racial or ethnic origin, genetic information (including familial genetic
information), medical condition, physical or mental disability, sex life

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose•

Business partners•

Government entities
Service providers
Business partners•••

Service providers
Business partners•

Service providers••

Service providers
Business partners•

Service Providers••

Service providers
Business partners•

Service providers•

Service providers
Business partners

•

•

•
•
•

Government entities
Service providers
Business partners

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Category of Personal Information
Collected by Otsuka

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose(including pregnancy or childbirth and related medical conditions),
and sexual orientation.

Personal Information Details for Employees, Workers, and Job ApplicantsCategory of Personal Information
Collected by Otsuka
Identifiers.
A real name, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name,Social Security number, or other similar identifiers.
Personal information categories listed in state laws governing thesecurity of customer records
A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver's
license or state identification card number, insurance policy number,
education, employment, employment history, bank account number,credit card number, debit card number, or any other financial
information, medical information, or health insurance information.
Protected classification characteristics under state or federal law
Age (40 years or older), race, color, ancestry, national origin,citizenship, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information).
Internet or other electronic network activity
Browsing history, search history, information on a consumer's
interaction with an internet website, application, or advertisement.
Geolocation data
Physical location or movements.

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose
•
•
•

•
•
•

Government entities
Service providers
Business partners

Government entities
Service providers
Business partners•

Government entities
Service providers
Business partners•

Service providers•

Service providers
Business partners•••

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Category of Personal Information
Collected by Otsuka
Electronic and Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information(e.g., a recording of a customer service call or profile photograph).
Professional or employment-related information
Current or past job history or performance evaluations.
Education information
An individual’s education information, including academic
information and records.
Inferences
Inferences drawn from any of the information identified in thissubdivision to create a profile about a consumer reflecting theconsumer’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, andaptitudes.
Sensitive Personal Information
Personal information that reveals your social security, driver’s license,
state identification card, or passport number, precise geolocation,
racial or ethnic origin, genetic information (including familial genetic
information), medical condition, physical or mental disability, sex life
(including pregnancy or childbirth and related medical conditions),
and sexual orientation.

Category of NonAffiliated Parties toWhom Otsuka Discloses
Information for a
Business Purpose•

Service providers••

Service providers
Business partners•

Service providers•

Service providers
Business partners

•

•
•
•

Government entities
Service providers
Business partners

The categories of sources from which we collect Personal Information are set forth
above in the sections concerning How Otsuka Collects Personal Information andInformation from External Sources. Our business and commercial purposes forcollecting and disclosing Personal Information are set forth above in the sections
concerning How Otsuka Uses Your Personal Information and Onward Transfer. The
retention period that applies to each category of Personal Information described above
is set forth below in the section concerning Retention.
"Sales" of Personal Information
Otsuka does not "sell" Personal Information, nor do we have actual knowledge of any"sale" of Personal Information of minors under 16 years of age. For purposes of thisparagraph, a “sale” is the disclosure of Personal Information to a third party formonetary or other valuable consideration.

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Use of Personal Information for “Profiling”
Otsuka does not use Personal Information for purposes of profiling in furtherance ofdecisions that produce legal or similarly significant effects concerning an individual.
Use and Sharing of Personal Information for Targeted Advertising Across NonAffiliated Websites and Applications
As described in section 2.9.4 above concerning Interest-Based Advertising, Otsuka“shares” your Personal Information as defined under the CCPA and uses your
Personal Information for “targeted advertising” as defined under the CPA, VCDPA,
UCPA, and CDPA. For purposes of this paragraph, “sharing” is the disclosure of
Personal Information to a third party for cross-context behavioral advertising, whether
or not for monetary or other valuable consideration. “Targeted advertising” means
displaying advertisements to a consumer where the advertisement is selected based on
personal data obtained from that consumer's activities over time and acrossnonaffiliated websites or online applications to predict such consumer's preferences orinterests. In the past twelve months, Otsuka has shared the following categories of
Personal Information: Internet or Other Electronic Network Activity, cookie-related
trackers. Otsuka also used these categories of Personal Information for Targeted
Advertising. You have the right to opt-out of the use and sharing of your Personal
Information or Targeted Advertising. To submit an opt-out request, please contact ourPrivacy Office (at privacyofficer@otsuka-oph.com or by calling 1-833-468-7852).
We will process your request(s) in accordance with applicable law.
Your Privacy Choices

Otsuka uses the OneTrust consent management platform to recognize and honor
certain opt-out preference signals that ask websites to opt out the device or browser
from any “sale” or “sharing” of personal information. If you have preset your device
or browser to send such signals, our website will automatically treat that signal as
your request to opt out of any “sale” or “sharing” of personal information obtained
from “targeting cookies” that our advertising partners use to understand your interestsand market to you through that device or browser. Recognition of this signal will only
take place with respect to the device and/or browser that communicates the signal. In
the event that a website does not track or does not have cookies, we will not be storing
any information regarding you.
Children’s Personal Information
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Otsuka processes Personal Information about children less than 13 years of age inaccordance with the federal Children’s Online Privacy Protection Act and, wherelegally required, obtains parental consent before processing Personal Information
about a known child. Otsuka does not have actual knowledge that we have Personal
Information of California residents under 16 years of age.
Sensitive Personal Information
Otsuka uses Sensitive Personal Information for the purposes listed in this Privacy
Notice, which include purposes other than those authorized by these state laws or
purposes that require consent from you. Where we are required by law to obtainconsent from you, we will do so before collecting your Sensitive Personal Informationand inform you of any additional purposes we may process that Sensitive Personal
Information. Depending on your state of residence, you also may have certain rights
to limit the use of your Sensitive Personal Information. To submit a request to limit
our processing of your Sensitive Personal Information, please contact our Privacy
Office (at privacyofficer@otsuka-oph.com or by calling 1-833-468-7852). We willprocess your request(s) in accordance with applicable law.
Additional Privacy Rights for Virginia, Colorado, and Connecticut Residents
Virginia, Colorado, and Connecticut consumers have the right to appeal our decisions
on their data subject requests. To appeal our decision on your data subject requests,
you may contact our Privacy Office at privacyofficer@otsuka-oph.com or by calling
1-833-468-7852. Please enclose a copy of or otherwise specifically reference ourdecision on your data subject request so that we may adequately address your appeal.
We will respond to your appeal in accordance with applicable law.
Non-Discrimination. We will not discriminate against you for exercising your rights
conferred by these state laws.
Authorized Agent. Only you, or someone legally authorized to act on your behalf,
may make a verifiable consumer request related to your Personal Information. You
must provide the authorized agent with written permission to do so, and we may denya request submitted by a person that does not submit proof that they have beenauthorized to act on your behalf. In certain circumstances, we may ask you to verify
your own identity directly with us and to confirm that you provided the person
permission to submit the request. You may also make a verifiable consumer request
on behalf of your minor child.
Verification. To protect your privacy, we will take the following steps to verify youridentity before fulfilling your request. When you make a request, we will ask you toprovide sufficient information that allows us to reasonably verify you are the person
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about whom we collected Personal Information or an authorized agent, which may
include your name, email address, phone number, or birth date. If you are an
authorized agent, we will ask you for a copy of the written permission from therequestor authorizing you to submit the request on his or her behalf.
If you are a resident of the U.S. states listed in this section 5.1 and would like toexercise any of your rights described above, please contact our Privacy Office (atprivacyofficer@otsuka-oph.com or by calling 1-833-468-7852). We will process such
requests in accordance with applicable laws.

5.2 Supplemental Notice for Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain
Personal Information to third parties. You can exercise this right by contacting us
at privacyofficer@otsuka-oph.com with the subject line "Nevada Do Not Sell
Request" and providing us with your name and the email address associated with youraccount. Please note that we do not currently sell your Personal Information as sales
are defined in Nevada Revised Statutes Chapter 603A.

5.3 Washington & Nevada My Health My Data Act Disclosures.
This section only applies to website visitors, patients, and clinical trial subjects of the
U.S. states of Washington and Nevada to the extent the Washington My Health My
Data Act or the Nevada My Health My Data Act apply to Otsuka’s processing ofhealth data. We collect the below categories of health data from those state residents,
and we process such categories of consumer health data for the purposes and in themanners listed in section 5.1:
Individual health conditions, treatment, diseases, or diagnosis;
Social, psychological, behavioral, and medical interventions;
Health-related surgeries or procedures;
Use or purchase of prescribed medication;
Bodily functions, vital signs, symptoms, or measurements of healthinformation;o Diagnoses or diagnostic testing, treatment, or medication;o Genetic data;o Precise location information that could reasonably indicate a resident’s
attempt to acquire or receive health services or supplies;
o
o
o
o
o

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o Data that identifies a resident seeking health care services; ando Any inferences of the above categories of health data derived or
extrapolated from nonhealthy information.
We collect these categories of health data from the sources listed in sections
concerning How Otsuka Collects Personal Information and Information from External
Sources, and we share these categories of consumer health data with the categories ofentities listed in Section 4.1.
These state residents may exercise their data subject rights, including obtaining accessto and requesting changes to their health data under the Washington My Health My
Data Act and the Nevada My Health My Data Act by contacting us via the methods
listed in Section 5.1.
We limit third-party collection of health data over time and across different websites
or online services when these state residents use our websites or online services. We
do this by ensuring strict contractual restrictions with entities whose cookies, pixels,
and other online trackers we use on our websites and online services in accordancewith applicable U.S. privacy laws including the Washington and Nevada My Health
My Data Acts. Nonetheless, please note that non-affiliated parties may still be able tocollect health data from you over time and across different websites depending on
your browser, browser add-ons, and associated permissions you set on your device,
which is unrelated to Otsuka’s collection of health data from you, and we encourage
you to view those non-affiliated parties’ privacy notices for more information about
their processing of health data and the methods they provide to allow you to opt out ofsuch processing.

6.0 Retention
Otsuka retains the Personal Information we receive as described in this Privacy Policy
for as long as you use our Sites or as necessary to fulfill the purpose(s) for which it
was collected, provide our products and services, resolve disputes, establish legal
defenses, conduct audits, pursue legitimate business purposes, enforce ouragreements, and comply with applicable laws.

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7.0 Security
The security of all Personal Information provided to Otsuka is important to us, andOtsuka takes reasonable steps designed to protect your Personal Information.
Unfortunately, no data transmission over the Internet or storage of information can be
guaranteed to be 100% secure. As a result, while Otsuka strives to protect your
Personal Information, we cannot ensure or warrant the security of any information
you transmit to Otsuka, and you do so at your own risk. You are responsible formaintaining the secrecy of your own passwords and security of your computer system.
If you have reason to believe that your passwords or Personal Information connectedwith your use of our Sites is no longer secure, please promptly notify us
at privacyofficer@otsuka-oph.com.

8.0 Redress/Compliance and Accountability
If after reviewing this Privacy Policy, you would like to submit a request, ask anyquestions, or express any concerns, please contact our Privacy Office (atprivacyofficer@otsuka-oph.com or by calling 1-833-468-7852). You may also
alternatively contact:
Otsuka Precision Health, Inc.
Privacy Officer
508 Carnegie Center
Princeton, New Jersey 08540
Otsuka will address your concerns and attempt to resolve any privacy issues in atimely manner.

9.0 Other Rights and Important Information

9.1 Information Regarding Children
Due to the nature of Otsuka's business, services and benefits are not marketed tominors. Otsuka does not knowingly solicit or collect Personal Information fromchildren under the age of 13 (and in certain jurisdictions under the age of 16). If welearn that we have collected Personal Information from a child under the age of 13

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(and in certain jurisdictions under the age of 16), we will promptly delete that
information.

9.2 Links to External Websites
Please note that our Sites may contain links to other websites for your convenienceand information. Otsuka does not control external websites or their privacy practices,which may differ from those set out in this Privacy Policy. Otsuka does not endorse or
make any representations about external websites. Any Personal Information you
choose to give to non-affiliated persons are not covered by this Privacy Policy. Otsuka
encourages you to review the privacy policy of any company or website before
submitting your Personal Information. Some external parties may choose to disclose
their users' Personal Information with Otsuka; that disclosure is governed by thatcompany's privacy policy, not this Privacy Policy.

9.3 ComplianceThis Privacy Policy shall be implemented by Otsuka. Otsuka has put in placemechanisms to verify ongoing compliance with this Privacy Policy. Any Employeethat violates these privacy principles will be subject to disciplinary procedures.

9.4 Changes to the Privacy Policy
Otsuka may update this Privacy Policy from time to time as it deems necessary in its
sole discretion. Otsuka encourages you to review this Privacy Policy periodically to
be informed regarding how Otsuka is using and protecting your information and to beaware of any policy changes. Your continued relationship with Otsuka after the
posting or notice of any amended Privacy Policy shall constitute your agreement to bebound by any such changes. Any changes to this Privacy Policy take effectimmediately after being posted or otherwise provided by Otsuka.

This Privacy Policy was last updated March 18, 2024.

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