Privacy Policy

PRIVACY POLICY

Medical Data Vision Co., Ltd. (“we”, “us”, “our”) recognizes the importance of the protection of your personal information and strives to ensure that your rights under applicable personal information protection and privacy laws are respected.

This Privacy Policy is designed to provide you with information about how we will use your personal information when you visit our websites and use our services.

Please note that this Privacy Policy is designed for individuals who reside outside of Japan. If you are a resident of Japan, please click here to view our domestic privacy policy.

Scope of this Privacy Policy

This Privacy Policy applies when you visit our websites and use our services. When you visit our websites and use our services, you will be required to provide us with personal information so that we can provide our websites and services to you. We will collect, use, process and retain your personal information accordingly.

Your Personal Information

We will collect the following personal information from you when you visit our websites and use our services:

• User ID and Password
• Name
• E-mail Address
• Place of Work
• Other Information You Choose to Provide to Us

In addition to the above, we will also collect certain information about you including information about your content preferences and information about your interaction with our websites via the use of Cookies. For more information, please view the “Cookies” section of this Privacy Policy below.

When you visit our websites and use our services, we will only collect your personal information to the minimum extent that it is necessary to achieve one or more of the purposes stated in this Privacy Policy.

Collection of Personal Information

We will collect personal information about you from the following sources:

• Directly from you when you provide information to us.
• Indirectly from your activity when you visit our websites and use our services.

Purpose of Use of Personal Information

We will use personal information we have collected about you for the following purposes:

• To verify your identity at the time of registration for our services.
• To provide you with our websites and our services.
• To initially propose our services to you.
• To communicate with you regarding our services.
• To respond to enquiries we receive from you.
• To send you marketing and promotional materials regarding our services (but only if you have consented to receiving such materials).
• To provide you with a personalized experience of our websites and services.
• To analyze and evaluate our websites and services for the purposes of improving the quality of the content available through them.
• To prevent our competitors from using and accessing our services where this would compromise our business interests.
• Other purposes for which we will notify you and obtain your consent.

We will use your personal information only to the minimum extent necessary to achieve the purposes above.

Legal Basis for the Use of your Personal Data

If you are located in the European Economic Area (EEA) or in the United Kingdom (UK), we are required to indicate the legal basis for our use of your personal information.

The following table sets out the different legal bases that we rely on for each of our respective uses of your personal information:

Use of your Personal Information based on your Consent

When our use of your personal information is based on your explicit consent, we will take steps to ensure that your consent is freely-given, specific, informed and unambiguous.

You have the right to withdraw your consent to our use of your personal information, however the withdrawal of your consent will not affect the legal validity of any use of your personal information prior to your withdrawal of consent.

You can withdraw your consent by following the withdrawal procedures available through our websites or our online services or by contacting us via one of the means listed below in the “Contact Us” section of this Privacy Policy.

Retention of your Personal Information

All personal information we have collected about you will be securely retained in cloud data storage.

We will only retain your personal information for as long as the information is necessary for one or more of the purposes stated in this Privacy Policy and we will promptly delete or de-identify your personal information after it is no longer necessary for any such purpose.

We will implement necessary and appropriate safety measures to ensure that any personal information we have collected about you is protected from unauthorized use or access, leakage, damage or destruction.

When we collect your personal information in the course of providing you with our online services, we will retain such personal information for the duration of your subscription to the service. After your subscription to the service has ended, we will delete or de-identify any remaining personal information we have collected about you as soon as reasonably possible and at the latest within thirty (30) days. However, we may continue to retain your personal information after your subscription to the online service has ended but only to the extent that we have another legal basis for retaining and processing the information.

Disclosure of Personal Information to Third Parties

We will disclose your personal information to credible third-party service providers including cloud service providers and data analytics providers. We will only disclose your personal information to third-parties to the extent necessary to achieve the purposes stated in this Privacy Policy.

When we disclose your personal information to third-party service providers, we will take necessary and appropriate measures to ensure the security and integrity of your personal information, including the following:

• Selection of Appropriate Third-Party Service Providers: We will select credible third-party service providers that we have confirmed are implementing necessary and appropriate safety measures to ensure that your personal information is protected from unauthorized use or access, leakage, damage or destruction.
• Data Processing Agreement: We will enter into legally-binding Data Processing Agreements with our third-party service providers that compel our third-party service providers to handle your personal information according to the same standards as those set out in this Privacy Policy and any applicable laws and regulations.
• Control and Supervision: We will ensure that we have the right to audit our third-party service providers to confirm that your personal data is being handled according to the same standards as those set out in this Privacy Policy and your rights under applicable laws and regulations are respected.

Overseas Transfers of Personal Information

We will transfer your personal information overseas to the extent necessary to achieve the purposes stated in this Privacy Policy. For example, we may transfer your personal information to third-party service providers located in different locations around the world in order to achieve such purposes.

When we transfer your personal information overseas, we will take steps to ensure that your personal data is handled in accordance with applicable data protection laws and regulations and this Privacy Policy by selecting credible third-party service providers who have provided guarantees that the necessary technical and organizational measures have been implemented to protect the security of your personal information irrespective of its location and by ensuring that we have suitable Data Processing Agreements in place with our third-party service providers.

For users located in the EEA or the UK, we will not transfer your personal information outside of the EEA or the UK without your consent unless we can ensure that the security and integrity of your personal data and your rights with respect to your personal data will not be compromised based on either of the following bases:

• Adequacy Decision: We may transfer your personal data outside of the EEA or the UK without your consent to countries for which the European Commission or the UK Government has adopted an “Adequacy Decision”. An “Adequacy Decision” means a decision adopted by the European Commission or the UK Government that a country affords the same degree of protection to personal data as that required of member states of the EEA or the UK under the European General Data Protection Regulation (EUGDPR) or the United Kingdom General Data Protection Regulation (UKGDPR).
• Appropriate Safeguards: We may transfer your personal information outside of the EEA or the UK without your consent where we can confirm that appropriate safeguards are in place to protect the security and integrity of your personal information and to ensure that enforceable rights and effective remedies are available with respect to your personal information. Such appropriate safeguards include the execution of legally-binding Data Processing Agreements with the overseas recipient of your personal information that provides enforceable rights and effective remedies to protect your rights with respect to your personal information, including through the implementation of Standard Contractual Clauses (SCCs) pre-approved by the European Commission or the International Data Transfer Agreement (IDTA) pre-approved by UK Government as providing the necessary safeguards to protect your personal information and ensure your rights under the EUGDPR and the UKGDPR respectively are maintained. When we transfer your personal information outside of the EEA or the UK on the basis of appropriate safeguards, we will ensure that documentation of the appropriate safeguards is available to you on request. You can request a copy of such documentation by contacting us via one of the means listed below in the “Contact Us” section of this Privacy Policy.

Cookies

We use Cookies to provide convenience to you and to improve your experience of our websites and online services.

A Cookie is a mechanism whereby certain data is saved to your device (computer, smartphone, tablet etc.) at the time when you visit a website. The data saved to your device by the Cookie will automatically be transmitted to the website the next time you access the website and can be used to enable certain functions via the website or to analyze your usage of the website.

Cookies can be categorized into different classifications depending on the function that they serve. The following table sets out the types of Cookies that we use and our purposes for using such Cookies.

When we use Cookies other than “Strictly Necessary Cookies”, we will notify you and obtain your explicit consent for the use of Cookies.

Cookies do not collect any information that can be used to directly identify a particular individual such as the individual’s name, address, telephone number etc.

We will not use Cookies for any purposes other than the purposes described above.

You can adjust the settings of your browser to refuse to accept Cookies. However, please note that certain functions of our services and websites (including the Font Size Display Function and the Favorites Function) may be unavailable without the use of Cookies.

Your Rights

You have rights with respect to your personal information, including the rights listed below, under applicable personal information protection and privacy laws.

Please note that the specific rights applicable to you will depend on your location. Therefore, some or all of the rights listed below may not be applicable to you based on your location.

• Right to Access: the right to confirm whether or not we are processing your personal information and, if we are processing your personal information, the right to be provided with access to the personal information and certain information about our processing of the personal information.
• Right to Rectification: the right to have any inaccurate or out-of-date personal information about you corrected or updated.
• Right to Withdraw Consent: the right to withdraw your consent to our processing of your personal information where such processing was based on your explicit consent. Please refer above to the section entitled “Use of your Personal Information based on your Consent” for further information.
• Right to Erasure: the right to have any personal information we have collected about you erased after it is no longer required for the purpose for which it was collected.
• Right to Restrict Processing: the right to restrict our processing of your personal information in certain circumstances.
• Right to Data Portability: the right to be provided with a copy of any personal information we have collected about you in a commonly-used, machine-readable format that you can freely transmit to others.
• Right to Object to Processing: the right to object to our processing of your personal information in certain circumstances.
• Right to Object to Automated Decision Making: the right to object to the processing of your personal information for the purposes of automated decision making. However, we do not process your personal information for the purposes of automated decision making.
• Right to Lodge a Complaint: the right to lodge an official complaint to your local data protection authority if you believe that our processing of your personal information violates applicable personal information protection and privacy laws. Please note that the relevant data protection authority with whom you should lodge a complaint will depend on your location.

To contact us regarding any of your rights, please contact us via any of the means listed below in the “Contact Us” section of this Privacy Policy.

Please note that in order to respond to requests, we need to verify that the person making the request matches the person about whom we have personal information. Therefore, when you make a request, we may require you to provide additional information in order to verify your identity. We will only use the information you provide to us for this verification purpose.

We will respond to your request within one (1) month from the date we receive your request.

Your Choices

It is ultimately your choice whether or not to provide us with any of your personal information. However, please note that certain features of our websites and services may require the use of your personal information and may be unavailable if you refuse to provide us with the necessary information.

Minors

Our services are not intended for minors below the age of sixteen (16) years of age. We do not knowingly collect personal information from minors and we implement measures to prevent the collection of such information through our services. If we become aware that we have inadvertently collected the personal information of a minor, we will take steps to ensure that the information is immediately deleted or deidentified.

Personal Information Breaches

In the event that personal information we retain is accessed without authorization, leaked, damaged or destroyed, we will report the personal information breach to the relevant data protection authorities in the territories of all of the affected individuals as required by applicable personal information protection and privacy laws. We will report any personal information breaches to the relevant data protection authorities within the timeframes required by the applicable personal information protection and privacy laws but in principle within seventy-two (72) hours of the occurrence of the personal information breach.

In addition to the above, in the event that a personal information breach is likely to result in a high risk to the rights of the affected individuals under applicable personal information protection and privacy laws, we will report the personal information breach to the affected individuals without undue delay.

Data Protection Officer

As we do not engage in large-scale systematic monitoring of individuals or process sensitive personal data on a large-scale, our activities do not meet the criteria requiring the appointment of a Data Protection Officer under Article 37 of the EUGDPR or the UKGDPR. Accordingly, having regard to the scale of our activities, we have elected not to appoint a Data Protection Officer. Nevertheless, to ensure suitable governance, we have established a point of contact for inquiries related to our processing of personal data. Please see the “Contact Us” section of this Privacy Policy below.

Changes to this Privacy Policy

This Privacy Policy will be updated from time to time. Any changes to this Privacy Policy will be displayed on this page.

We encourage you to review this page from time to time to make sure you have read the most up-to-date version of this Privacy Policy.

Contact Us

If you have any questions about the content of this Privacy Policy or would like to contact us regarding your rights as described in this Privacy Policy, please contact us via e-mail to privacy@mdv.co.jp or via our online inquiry portal (please select “Privacy” as the reason for your inquiry).

Our Information

Medical Data Vision Co., Ltd.
10F Sumitomo Fudosan Kanda Building, 7 Kanda Mitoshirocho, Chiyoda-ku, Tokyo 101-0053

Last Updated: October 1st, 2025

CALIFORNIA CONSUMER PRIVACY NOTICE

Pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (the “CCPA”), Medical Data Vision Co. Ltd. (“we”, “us”, “our”) provides this California Consumer Privacy Notice (this “Notice”) to our customers who reside in the State of California. This Notice contains information about the categories of Personal Information we collect about you, the purposes for which we use your Personal Information and your rights under the CCPA with respect to your Personal Information. This Notice supplements the information contained in our Privacy Policy. Any terms defined in the CCPA are used with the same meaning in this Notice. If there is any conflict between the content of this Notice and the content of our Privacy Policy, the content of this Notice will prevail.

Personal Information we Collect

The following table details the categories of Personal Information we will collect about you when you use visit our websites and use our services, as well as the categories of Personal Information we have collected about California residents in the past twelve (12) months.

No Collection of Sensitive Personal Information

In the past twelve (12) months, we have not collected any Personal Information from California residents that is considered to be “Sensitive Personal Information” and we will not collect any Sensitive Personal Information about you when you visit our websites or use our services. Under the CCPA, “Sensitive Personal Information” includes information such as an individual’s Social Security number, financial information, racial or ethnic origin, geolocation data, genetic data etc.

Purposes of Use of Personal Information we Collect

We will use and disclose Personal Information we collect about you for the business and operational purposes specified below:

• Service Provision: to provide you with our websites and services.
• Auditing: for auditing related to our provision of our websites and services.
• Security: to detect, prevent and investigate malicious, deceptive and fraudulent activity through our websites and services.
• Debugging: to identify and repair defects that impair the existing intended functionality of our websites and services.
• Short-term, Transient Use: for certain short-term uses provided that your Personal Information is not further provided to third-parties and is not used to build a profile about you.
• Quality Assurance and Improvement: to maintain and improve the quality of our websites and services.
• Other Operational Purposes: other operational purposes which are compatible with the context in which we collected your Personal Information or which we have notified to you.

Disclosure of Personal Information

We are entitled to disclose your Personal Information to third-parties for our business and operational purposes. When we disclose your Personal Information to a third-party, we will ensure that we have entered into an appropriate contract with the third-party that requires the third-party to implement measures to maintain the security and integrity of your Personal Information and to use your Personal Information only for specified purposes.

The following table details the categories of recipients to whom we have disclosed Personal Information we have collected about California Residents in the past twelve (12) months, as well as the categories of Personal Information disclosed and the business purposes of such disclosures.

Your California Privacy Rights

As a resident of the State of California, you have the right to exercise the following rights with respect to Personal Information we have collected about you.

Right to Correction: You have the right to request us to correct Personal Information we have collected from you that is outdated or inaccurate.

Right to Deletion: You have the right to request us to delete Personal Information that we have collected from you and to direct our third-party service providers to do the same.

Right to Limit: You have the right to direct us to limit the use and disclosure of your Personal Information that is considered to be Sensitive Personal Information to specific purposes such as providing you with the Service. However, we do not and will not collect any Sensitive Personal Information about you.

Right to Opt-Out: You have the right to request that we stop selling your Personal Information or sharing your Personal Information for cross-context behavioral advertising purposes.

Right to Non-Discrimination: You have the right not to be discriminated against on the basis that you exercised any of your California Privacy Rights.

To contact us regarding any of your California Privacy Rights, please contact us via any of the means listed below in the “Contact Us” section of this Notice.

Please note that in order to respond to requests, we need to verify that the person making the request matches the person about whom we have Personal Information. Therefore, when you make a request, we may require you to provide additional information in order to verify your identity. We will only use the information you provide us for this verification purpose.

We will respond to your request within forty-five (45) days from the date we receive your request.

Authorized Agents

You are entitled to have an authorized agent submit a request for the exercise of your California Privacy Rights on your behalf. However, please note that, we may require additional information from either you or from your agent in order to verify that you are the person directing the agent and that the agent has been properly authorized to submit the request on your behalf. We may require you or your agent to submit evidence that you have provided signed permission or a power of attorney that authorizes the agent to submit the request on your behalf, or to directly confirm that you have granted permission to the agent to submit the request on your behalf.

We may refuse a request for the exercise of your California Privacy Rights made by an agent if we are unable to receive evidence or confirmation from you or the agent that the agent has been granted permission to submit the request on your behalf.

Minors

We do not knowingly sell or share for cross-context behavioral advertising purposes any Personal Information of minors below sixteen (16) years of age.

Changes to this Notice

This Notice will be updated from time to time. Any changes to this Notice will be displayed on this page.

We encourage you to review this page from time to time to make sure you have read the most up-to-date version of this Notice.

Contact Us

If you have any questions about the content of this Notice or would like to contact us regarding your California Privacy Rights, please contact us via e-mail to privacy@mdv.co.jp or via our online inquiry portal (please select “Privacy” as the reason for your inquiry).

Our Information

Medical Data Vision Co., Ltd.
10F Sumitomo Fudosan Kanda Building, 7 Kanda Mitoshirocho, Chiyoda-ku, Tokyo 101-0053

Last Updated: October 1st, 2025