メドピア株式会社

Protection of Personal Information (Privacy Policy)

When handling the personal information of members (hereinafter "Members") or clients/third parties (hereinafter collectively "Client"), MedPeer, Inc. (hereinafter the "Company") in the course of operating the services it provides (hereinafter "Services") it provides, the Company will respect individual dignity and carefully consider the need to use this information. Furthermore, all usage of personal information will comply with the law and social order, and the Company will strive to protect it through appropriate management per its internal regulations.

1. Compliance with laws and regulations and continuous improvement of management frameworks

The Company complies with all relevant laws and regulations regarding personal information (information that can be used to identify specific individuals by name, date of birth, or other descriptions contained in the information, including information that can be easily cross-referenced with other information and used to identify specific individuals), as well as establishing its internal frameworks and regulations for the protection of personal information. The Company strives to operate these protective frameworks and regulations effectively and continuously improve them.

2. Acquiring personal information

When acquiring personal information, the Company will clearly define the purposes for acquiring it within the scope of the Company's legitimate business. Information will be acquired lawfully and fairly to the minimum extent necessary to achieve these purposes.

The Company will also obtain the following information regarding the use of its Services, regardless of whether or not it constitutes personal information

(1) Information related to the Services used by Clients, such as the content of the Services, the date, time, and the number of times Clients used the Services, and how Clients used and viewed the Company's Services (including cookie information, access logs, and other information related to usage, device information, OS information, location information, and transmission information including IP address, browser information, browser language, etc.)
(2) Posts, photos, videos, comments, ratings, and other information posted or transmitted by Clients using the Service

3. The Company will use the personal information obtained for the following purposes

- Personal information of Members who use the Company's Services

(1) To contact them to authenticate and confirm their membership to the Services
(2) To respond to inquiries and complaints
(3) To provide information on medical care, pharmaceuticals, and related matters
(4) To analyze information on usage of the Services, such as browsing history and activity history, and to provide information on the Company's Services or services provided by third parties that are suitable for Members
(5) To contact Members or Clients
(6) To send campaigns, prize plans, questionnaire surveys, ranking plans, products, etc.
(7) To research and analyze marketing data and develop new services (in this situation, information will be used in a way that prevents specific individuals from being identified)
(8) To commission work or request monitoring, etc., for the planning, development, production, promotion, sales, and provision of Services
(9) To analyze information on the usage of Services, such as browsing and activity history, to improve the Services, enhance their quality, and develop new services
(10) To analyze information such as browsing history and activity history to provide services and display content (including advertisements) customized for individual Clients, etc.
(11) To analyze and score information on a Member's activity history within the Services (including the types of content viewed and the content posted by the Member) and public information, as well as information on the Member's medical specializations, paper co-authors, number of co-authored publications, etc. obtained from third parties such as database providers, and provide said scores to third parties.
(12) For system maintenance, responding to malfunctions, and achieving other aims required for technical or operational purposes
(13) To provide third parties, such as clients who use the Services, with information obtained publicly and from third parties, such as database providers, regarding the Member's medical specializations, paper co-authors, number of co-authored publications, etc., as reference information, by adding this information to personal information for which consent has been obtained in advance to provide to third parties
(14) For other purposes as individually determined by the Company’s Services
(15) For provision to third parties to the extent necessary to carry out the above purposes

- Personal information concerning the Company's clients

(1) For making contact as required for business, executing contracts, conducting business negotiations, etc.
(2) To manage client information

- Personal information about individuals making inquiries

(1) To respond to inquiries

- Personal information of applicants for employment selection processes

(1) To provide employment information to the applicant or contact/notify them
(2) To determine whether to accept or reject applicants for employment

4. Provision of personal information to third parties

1）The Company will not provide personal information of Clients to any third party without their prior consent, unless permitted by law, such as when required by law, when stipulated in 2) and 3) below, or when personal information has been entrusted within the scope necessary to achieve the intended use.

2）The Company will provide the Member's area of medical specialization, names of co-authors of papers, and the number of papers co-authored, obtained from information available on the internet and from database providers (however, this excludes information obtained in violation of the provisions of Article 20, Item 1 of the Act on the Protection of Personal Information, or information obtained from third parties via an opt-out method from other business operators handling personal information) as reference information to domestic and foreign pharmaceutical manufacturers and distributors and physicians who use the Services, along with personal information for which the Company has obtained prior consent to provide to a third party. This information will be categorized by place of employment, co-authorship of papers, academic society memberships, medical specialization, and university attended. The information will be provided by displaying it on a web page accessible by entering an ID and password, by being sent as a password-protected Excel or PDF file as an attachment to an e-mail, by sending a CD-ROM containing the file, or by sending the file through a server with restricted access. Databases created using the acquired information will be updated by checking for consistency with existing information each time new information is acquired. In addition, when receiving personal data from a third party, the Company will confirm the circumstances under which the third party acquired the data, ensuring that it acquires the data in an appropriate manner.

3）The Company will provide the names of non-Member physicians, their facilities, and prefectures where they work, which are included in the answers to Member questionnaires, as reference information to domestic and foreign medical-related businesses that use its Services, along with personal information for which the Company has obtained prior consent to provide to third parties. The information will be provided by displaying it on a web page accessible by entering an ID and password, by being sent as a password-protected file as an attachment to an e-mail, by sending media on which the information is recorded, or by sending the file through a server with restricted access. Information on the Company's Members and databases created using the acquired information will be updated by checking for consistency with existing information. In addition, when receiving personal data from a third party, the Company will confirm the circumstances under which the third party acquired the data, ensuring that it acquires the data in an appropriate manner.

4）Regarding the provision of personal data to third parties as in (2) and (3) above, the Company will cease providing this data to third parties upon the request of the individual in question. To discontinue having your personal information provided to third parties, please contact the Company's inquiries team as listed in "12. Procedures for disclosure of personal information" by mail, e-mail, or using the inquiry form found at: https://medpeer.co.jp/contact/

5. Managing subcontractors

The Company may outsource the handling of personal information to outside parties to the extent necessary for implementing the intended use. If outsourcing is required, it will select a subcontractor that it believes will handle personal information appropriately. The Company provides or discloses Clients' personal information to subcontractors only to the extent necessary for implementing the intended use. The Company requires subcontractors to handle personal information appropriately through contracts or other means and periodically checks how they handle it.

6. Shared use

The Company may share the personal information it has acquired with business partners, business associates, and other third parties as deemed necessary. When sharing information in this manner, the Company shall stipulate the scope of who may use the data and other necessary matters and publish this on the Company's website so that Clients can easily see it.

（1）Items of personal data to be shared

The following items of personal information on physician members, as obtained by the Company, may be shared:
[Applies to shared users in (2) a and b below]
- Name
- Gender
- Date of birth
- Name and address of facility of employment
- Year of medical certification
- Type of work
- Fields of medical treatment
- Graduating university
- E-mail address

[Applies to shared users in (2) c. below]
Each of the above items plus each of the following:
- Job type
- Qualifications
- Access information to contents provided through the service

（2）Scope of shared users, intended use, and name of party responsible for the management of the personal data being shared

a）Shared use with member companies^* of Nihon Ultmarc, Inc. and the database containing basic information on physicians working in medical facilities throughout Japan (hereinafter the "Medical Database (MDB)"), which is managed and operated by Nihon Ultmarc, Inc.
Note: For more information on Nihon Ultmarc, Inc's member companies, please visit its website.
[Nihon Ultmarc, Inc: https://www.ultmarc.co.jp/privacy/shared_use/index.html]

- Intended use by member company:: The MDB's intended use is "protecting human life and body or improving public health." Accordingly, it is used by member companies to provide, collect, and review information required for fulfilling their duties as medical providers, as well as for research and projects aimed at contributing to society in the fields of medicine, welfare, and healthcare, and for operations associated with these activities. Please refer to each member company's website for details on other intended uses.
- Name of company responsible for managing the personal data for shared use: Morinaga Plaza Building, Honkan 15F, 5-33-1 Shiba, Minato-ku, Tokyo 108-0014, Japan
Nihon Ultmarc, Inc.
President: Tomohiko Umeda

b）Shared use with Medical Tribune, Inc.

- Intended use by member company:: The information will be used to collect and review necessary information and provide information regarding the company's services within the scope of the purposes specified in the company's privacy policy. Please visit the company's website for more information on its intended use.
[Medical Tribune, Inc.: https://medical-tribune.co.jp/corporate/about/other/privacy/]
- Name of company responsible for managing the personal data for shared use: Ginza Shochiku Square 9F, 1-13-1 Tsukiji, Chuo-ku, Tokyo 104-0045, Japan
MedPeer, Inc.
President: Yo Iwami

c）Shared use with Sugi Holdings Co., Ltd.

- Intended use by member company:: The information will be used to collect and review necessary information and provide information regarding the company's services within the scope of the purposes specified in the company's privacy policy. Please visit the company's website for more information on its intended use.
[Sugi Holdings Co., Ltd.: https://www.sugi-hd.co.jp/privacypolicy/]
- Name of company responsible for the management of the personal data for shared use: Ginza Shochiku Square 9F, 1-13-1 Tsukiji, Chuo-ku, Tokyo 104-0045, Japan
MedPeer, Inc.
President: Yo Iwami

7. Notifications of revisions

The Company may revise its Privacy Policy to protect its Clients' personal information and respond to changes in laws and other regulations. Any revisions will be posted on this website.

8. Development of internal systems

To prevent personal information from being lost, leaked externally, or tampered with, the Company has established internal management regulations and has implemented reasonable security measures. The Company's thoughts on information security are described in its Security Policy.

9. About encrypted communications

The Company uses SSL (Secure Socket Layer), the most reliable internet encryption technology in use today, for all communications. Personal information transmitted is encrypted to make it unviewable by third parties, allowing Members to use the service securely.

10. Addressing requests from Clients

The Company will promptly investigate and appropriately respond when it receives a request from a Client for information on the intended use of information, its disclosure, correction, addition, deletion, suspension of use, elimination, or suspension of the provision of their personal information to a third party (hereinafter "Disclosure").

11. Cookies

(1) What are cookies?

This website uses cookies to provide better services to customers.
Cookies store information about your visit to this website on your computer (or other Internet-capable devices such as a smartphone or tablet). For example, cookies can be used to obtain information such as the number of times a website has been visited and the pages visited.
You can configure your browser to block cookies. However, please be aware that blocking cookies may interfere with normal access to all or parts of the Company's services and with the proper use of all or part of the functions provided by the Company's services.

(2) Intended use of cookies

The Company uses cookies and similar web tracking technologies (web beacons, pixels, etc.) for the following purposes:

1 Remembering login status and using it to authenticate Members and maintain sessions
2 To refer to the Member's stored registration information upon login to the Company’s Services and provide them with customized Services for each Member.
3 To improve the Company's Services by assessing the use of Services by Members (number of visits, date and time of visits, etc.)
4 To use behaviorally targeted advertising¹ provided by third-party companies

(3) Behaviorally targeted advertising

The Company uses behaviorally targeted advertising provided by the following third-party companies. The Company also uses the following services provided by third parties to display message information sent by Clients on some of its services to other Clients using the same services. The Company may provide the third party companies with personal information in a form that cannot be used to identify individual Clients. This information will be handled per the privacy policy and other rules set forth by the third-party companies. Those who do not wish to have behaviorally targeted ads displayed can disable this functionality by following the respective opt-out procedures². In addition, those who do not wish to use third-party services can also disable this functionality by following the opt-out procedures³. Please refer to each company's website, including those listed below, for explanations and opt-out procedures for each form of behaviorally targeted advertising and explanations and opt-out procedures for other services provided by third parties.

(1) Facebook Advertising: Custom Audiences: - Provider: Facebook, Inc.
- About Custom Audiences: https://www.facebook.com/business/help/744354708981227
- Cookie collection and use: See "Cookies and Other Storage Technologies" (https://www.facebook.com/policies/cookies/).
- Opt-out procedures: See "About Facebook Ads" (https://www.facebook.com/about/ads).
(2) Google Analytics (including functionality for display advertisers), Google Ads: - Provider: Google, LLC
- Cookie collection and use: See "Google Analytics Terms of Use" (https://www.google.com/analytics/terms/jp.html) and Google's Privacy Policy (https://policies.google.com/privacy)
- Opt-out procedures: See "Google Analytics Opt-out Add-on" (https://tools.google.com/dlpage/gaoptout) and Google Ads Settings (https://adssettings.google.com/).
(3) Twitter Ads: Tailored Audiences: - Provider: Twitter, Inc.
- About Tailored Audiences Based on Lists: https://business.twitter.com/ja/help/campaign-setup/campaign-targeting/tailored-audiences/TA-from-lists.html
- Cookie collection and use: See "Twitter's Use of Cookies and Similar Technologies" (https://help.twitter.com/ja/rules-and-policies/twitter-cookies).
- Opt-out procedures: See "Customized Ad Display Settings" (https://help.twitter.com/ja/safety-and-security/privacy-controls-for-tailored-ads).
(4) YDN (Yahoo! Display Ad Network): - Provider: Yahoo Japan Corporation
- Handling user information: https://marketing.yahoo.co.jp/service/ad_privacy.html
- Opt-out procedures: See the above page.
(5) Twilio: - Provider: Twilio Japan LLC
- The Company uses Twilio to display message information sent by Clients through the MedPeer Talk service to other Clients who use this service.
- Twilio Terms of Service: https://jp.twilio.com/ja/legal/tos-japan
- Twilio Privacy Policy: https://www.twilio.com/ja/legal/privacy
- Opt-out procedures: Please contact the inquiries team using the information in "12. Procedures for disclosure of personal information" or use the inquiry form (https://medpeer.co.jp/contact/).

Note:

1. Behaviorally targeted advertising uses cookies to deliver advertisements tailored to your interests based on information such as your accumulated activity history.

2. If you follow the opt-out procedures, certain Service functions may become unavailable. Please agree to this in advance before performing these procedures. Please note that if you change your browser or device or delete cookies after completing the opt-out procedures, you will need to complete the opt-out procedures again.

3. If you follow the opt-out procedures, certain Service functions may become unavailable. Please agree to this in advance before performing these procedures.

12. Procedures for disclosure of personal information

- Inquiries:

MedPeer, Inc. Corporate Headquarters
Address Ginza Shochiku Square 9F, 1-13-1 Tsukiji, Chuo-ku, Tokyo, Japan
E-mail：info@medpeer.co.jp

- Requesting Disclosure

Please send requests for Disclosure to the e-mail address above.
Please note that requests cannot be accepted by telephone or fax.

- How to request Disclosure

1）After receiving your request for Disclosure, the Company will send you a form by mail.
2）Please complete all necessary information and return the form to the inquiries team. When returning the form, please write "Request for Disclosure of Personal Information Enclosed" on the envelope.

a. When the request for Disclosure is made by the individual in question

Please enclose a copy of one of the following to confirm your identity:

- Driver's license
- Health insurance card
- Pension book
- Certificate of residence
- Passport
- Foreign resident registration card

b. When a representative requests Disclosure

Alongside the document in a. above for the individual in question, please enclose documents to verify the proxy's identity and a letter of attorney.
Please note that the Company will not be able to respond to your request if the requested documents are incomplete or it cannot contact you.

- Responding to requests for Disclosure

The Company will confirm the content of any request for Disclosure received and endeavor to send the results to you within one month of receipt of the request form. Please note, however, that there may be delays due to unforeseen circumstances. In principle, the Company will reply to you using the method you specified when applying. However, if it is difficult to do so, the Company will respond to you by the method specified by the Company after notifying you to that effect. If the Company cannot accept your application for reasons such as the following, it will notify you to that effect and provide the reason.

a. If your identity cannot be verified
b. If the request is made by a proxy and their power of representation cannot be confirmed
c. If the submitted documents are incomplete
d. When the request for Disclosure is not related to personal information eligible for disclosure
e. If there is a risk of harm to the life, body, fortune, or other rights and interests of the person concerned or a third party
f. If there is a risk of significant hindrance to the Company's business operations
g. In case of other violations of laws and regulations

- Costs for Disclosure

The Company will bear the actual costs required for the procedure and the cost of correspondence that it sends. However, in some cases, it may ask the applicant to bear costs within a reasonable scope. Please note that the applicant must bear all costs for sending documents to the Company.

13. Inquiries

If you have any comments or questions regarding the content of this privacy policy or the Company's handling of personal information, please contact the inquiry team using the e-mail listed in this document. Please note that requests cannot be accepted by telephone or fax. If the Company receives a complaint from Clients about the Company's handling of personal information, the Company shall respond promptly and appropriately.

MedPeer, Inc.
President: Yo Iwami

Established: August 31, 2007
Revised: February 23, 2016
Revised: December 12, 2018
Revised: March 01, 2019
Revised: April 22, 2019
Revised: July 09, 2019
Revised: December 10, 2019
Revised: December 16, 2019
Revised: January 01, 2020
Revised: March 18, 2020
Revised: November 13, 2020
Revised: June 14, 2021
Revised: November 30, 2021
Revised: February 28, 2022
Revised: April 01, 2022