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Privacy Policy

Catalys Pacific, LLC (the “Firm”) will comply with the Act on the Protection of Personal Information (“Personal Information Protection Act”), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (“My Number Act”), and other applicable laws and regulations for the purpose of handling Personal Information and Personal Numbers and Specific Personal Information (Personal Numbers and Specific Personal Information is hereinafter referred to as “Specific Personal Information Etc.”) in a proper manner as described below and we will take appropriate measures for the safety management thereof.  The Firm is committed to making every effort to train and educate persons engaged in the Firm’s business to ensure the proper handling of Personal Information and Specific Personal Information Etc.  The Firm will also perform reviews as needed to improve the following statements as required.

Capitalized terms that are not defined in this Privacy Policy have the meanings set forth in the Personal Information Protection Act and the My Number Act.  In this Privacy Policy, the term “Data Subjects” includes (i) directors, officers, employees and other representatives of portfolio companies and potential portfolio companies of the Firm’s fund(s), (ii) directors, officers, employees and other representatives of seller or potential seller, investment bankers, consultants, lawyers, accountants, advisers and other service providers of the Firm’s fund(s) and (iii) investors and potential investors in the Firms’ fund(s).  Personal Information and Personal Data of Data Subjects do not include Specific Personal Information Etc. of such Data Subjects.

1. Acquisition of Personal Information of Data Subjects[1]
The Firm collects Personal Information of its Data Subjects in a lawful and appropriate manner to the extent necessary for carrying out the Firm’s business.

2. Purposes of use of Personal Information of Data Subjects[2]
The Firm uses Personal Information of its Data Subjects obtained in the course of its business to the extent necessary for the business activities and purposes that are listed below (“Purposes of Use”). The Firm will post its Purposes of Use, as they may be updated from time to time, on its website, or otherwise notify concerned Data Subjects as necessary.

Scope of Business Activities
(i) Specially permitted businesses for qualified institutional investors, etc. pursuant to Article 63 of the Financial Instruments and Exchange Act, and ancillary activities thereto; and
(ii) Other businesses that may be operated by the Firm pursuant to laws and regulations, and ancillary activities thereto.

Purposes of Use
(i) Solicitation, proposal, or information about services that the Firm offers;
(ii) Consideration of suitability or appropriateness of the provision of services by the Firm;
(iii) Verification of identity of the Firm’s Data Subjects or their agents;
(iv) Report on results of investment management, asset balance, etc. to its Data Subjects;
(v) Operational and administrative activities with respect to transactions with its Data Subjects;
(vi) Exercising rights and fulfilling obligations under contracts with its Data Subjects and under applicable laws and regulations;
(vii) Research and development of assets, investment products, financial instruments, and services through market research, data analysis, and questionnaires;
(viii) Operational and administrative activities with respect to the management of the Firm, including those for creation of, investment in and growth of the Firm and/or its affiliates;
(ix) Response to inquiries and complaints regarding the handling of Personal Information and Specific Personal Information Etc.;
(x) Operational and administrative activities with respect to funds managed by the Firm, including those for support and facilitation of the creation and growth of a more vibrant life-sciences sector in Japan and globally; and
(xi) Other activities for appropriate and smooth execution of transactions with Data Subjects;

If the Firm handles Personal Information of its Data Subjects beyond the extent necessary to achieve the Purposes of Use, the Firm will obtain advance consent of the Data Subjects concerned, unless advance consent is not required under the Personal Information Protection Act.

3. Provision of Personal Data of Data Subjects to third parties
The Firm will not provide Personal Data of Data Subjects to any third parties without obtaining prior consent of the Data Subjects concerned, except in the cases permitted in the Personal Information Protection Act.

4. Handling of Specific Personal Information Etc.
The use of Specific Personal Information Etc. is restricted by the My Number Act, and the Firm will not collect or use such information beyond the Purposes of Use.  The Firm will not provide Specific Personal Information Etc. to any third parties except as permitted under the My Number Act.

5. Notification, Disclosure/Correction or Suspension of Use of Personal Data and Specific Personal Information Etc. Retained by Firm
Please direct any request for notification, disclosure/correction or suspension of use of Personal Data and Specific Personal Information Etc. retained by the Firm (“Request for Disclosure Etc.”) to the contact office set forth in Clause 7.  The Firm will make its best efforts to confirm that the person making the request is the Data Subject concerned or an agent of such Data Subject and will ask such person to fill out a form designated by the Firm, and will, in principle, respond in writing.  The Firm will charge a fixed fee for any Request for Disclosure Etc.

6. Management of Personal Data and Specific Personal Information Etc.
The Firm has appointed its Chief Compliance Officer as the person in charge of information management and the Firm aims to have sufficient security measures to prevent leaks, loss or damage of Personal Data and Specific Personal Information Etc. and to implement the safety management of such data and information.  The Firm also aims to ensure that Personal Data and Specific Personal Information are sufficiently accurate for the purpose for which they are used by the Firm and to keep such data and information updated to ensure such level of accuracy.

7. Contact
The Firm intends to appropriately respond to any complaints or consultations regarding the handling of Personal Information and Specific Personal Information Etc.  Please direct any inquiry or question concerning the handling of, and the Firm’s safety management measures for, Personal Information and Specific Personal Information Etc., to the Firm’s Chief Compliance Officer at privacy@catalyspacific.com.

[1] Please see Clause 4 below with respect to Specific Personal Information Etc.
[2] Please see Clause 4 below with respect to Specific Personal Information Etc.