Privacy Policy

Kuraray Co., Ltd. and its group companies listed in Exhibit 1 attached hereto(hereinafter collectively, the “Kuraray Group”) are highly conscious of the importance ofpersonal information. The Kuraray Group has established the following policies tosafeguard personal information.

1. Management of personal information
(1) The Kuraray Group has appointed personal information managers in eachorganization that treats personal information. These managers are responsible for thesecurity of personal information collected by their organizations.
(2) The Kuraray Group strives to prevent unauthorized access, leaks, or loss of personalinformation to ensure the security of personal information.

2. Use of personal information.
When the Kuraray Group collects personal information, the Kuraray Group will clearlyspecify the purpose of use, and the personal information will be used only for suchpurpose as specified. A data subject may refuse to provide its personal information at itsdiscretion. The purpose of use of personal information is as follows;
(1) Customers, suppliers or vendors: business communications, providing informationon services and products offered by the Kuraray Group,
(2) Shareholders: to allow execution of shareholders’ rights under the corporation law,to provide information and/or services to shareholders, administration of theshareholder registry,
(3) Job applicants: communication necessary for recruitment,
(4) Response to inquiries from the data subject, or
(5) Other purposes specifically informed to the data subject.

The Kuraray Group may, to the extent necessary for the purpose (1) or (4) mentionedabove, share personal data (address, name, company name, telephone number, e-mailaddress, etc.) within the Kuraray Group.

3. Disclosure to third parties.
Except as stipulated below, the Kuraray Group will not release personal information tothird parties. Providing information to contractors or affiliate companies by legitimatemeans is not considered as disclosure to third parties;

(1) With the explicit permission from the data subject,
(2) As required by law,
(3) When the provision of personal information is necessary for the protection of the life,body, or property of an individual and it is difficult to obtain the consent of the person,
(4) When the personal information is necessary for a state or local government inexecuting the affairs prescribed by laws and regulations and obtaining the consent ofthe person are likely to impede the execution of the affairs,
(5) When personal information is appropriately edited as statistical data by which thedata subject cannot be identified, or(6) When personal information is transferred in consequence of a merger, amalgamationor other corporate reorganization,

4. Changes in personal information.
A data subject has right to request to disclose, correct, add, delete, discontinue using, orerase its personal information the Kuraray Group has. The Kuraray Group will complywith these requests only after verification of the identity of the requestor. Inquiries withregard to personal information will be directed to the department to which the datasubject provided its personal information. In the case that a data subject is not surewhere to contact, inquiries may be accepted at:

E-mail: PersonalDataProtection.JP@kuraray.com
Tel: +81-3-6701-1000
Fax: +81-3-6701-1005

5. Changes in our privacy policy
This privacy policy may be changed in conformity with amendments to statutes orregulations, or for other purposes.

Handling of Personal Information of Residents of the EEA

In addition to the main body of the Privacy Policy, this Section 2 shall apply to thehandling of personal information of residents of the EEA where the General DataProtection Regulations (GDPR) is applicable, In the event of conflict or inconsistencybetween them, this Section 2 shall prevail.

1. Purpose of use and Legal basis under GDPR for processing the personal data whichthe Kuraray Group processes;

(1) Customers, suppliers or vendors: business communications, providinginformation on services and products offered by the Kuraray Group. Legalbasis: Consent of the data subject (GDPR Art.6(1) a) or Legitimate interest(GDPR Art.6(1) f)

(2) Response to inquiries and requests from the data subject. Legal basis: Consentof the data subject (GDPR Art.6(1) a) or Legitimate interest (GDPR Art.6(1) f)

2. When the Kuraray Group transfers personal data to its group companies orcontractors listed in Exhibit 1 attached hereto, the personal data may betransferred to the counties outside the EEA. The Kuraray Group will transferpersonal data only to the extent;

(1) the transfer to a country may take place where the EU Commission hasdecided that the country ensures an adequate level of protection of personalinformation (GDPR Art. 45),

(2) the transfer to a third party with whom the Kuraray Group executed thestandard data protection clauses approved by the EU Commission (GDPR Art.46.2) , or

(3) the transfer takes place on one of the conditions listed in GDPR49.1.

3. The Kuraray Group will store personal data for the appropriate period determinedbased on the criteria of the respective statutory retention period. After expiration ofthe period, the corresponding data no longer necessary will be deleted in accordancewith the respective retention policy.

4. A resident of the EEA has the following rights in connection with his/her own
personal data handled by the Kuraray Group;

(1) access (disclosure),
(2) rectification,
(3) erasure,
(4) restriction of processing,
(5) data portability,
(6) object to processing, and
(7) withdrawal of data processing consent.
The Request Form is attached hereto as Exhibit 2.

5. Lodging a complaint with a competent authority

A resident of the EEA has right to lodge a complaint on the processing of theirpersonal data with a competent supervisory authority. The following URL providesinformation of the authority:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

6. Contact information of the Data Protection Officer of the Kuraray Group in EEA:

Kuraray Europe GmbH
Philipp-Reis-Strasse 4
65795 Hattersheim / Germany
Attn: Data Protection Officer
Email: dataprotection.eu@kuraray.com
Tel: +49-69-305-85358

Attachments

Exhibit 1
Exhibit 2