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Personal Information Handling Policy (Basic Policy on the Protection of Personal Information)

METRIA Inc.

Through businesses such as the non-contact measurement of vital signs, AI-based analysis of images and data and image-reading support, and the research, development, and provision of a healthcare data platform, METRIA Inc. (“the Company”) handles sensitive personal information relating to health and medicine (including special care-required personal information as defined in the Act on the Protection of Personal Information (“the APPI”)).

The Company recognizes that appropriately protecting this information is both the foundation of its business and a serious responsibility to society, and handles personal information appropriately in compliance with the APPI and other applicable laws, national guidelines, and this Policy. Based on the following basic policy, the Company implements its efforts regarding personal information protection systematically and continuously.

1. Compliance with Laws and Guidelines

  • The Company complies with the APPI and other applicable laws, the guidelines established by the Personal Information Protection Commission, and this Policy.
  • The Company also refers to, and endeavors to appropriately address, the guidelines applicable to the medical and health fields (such as the Guidelines for the Safety Management of Information Systems Handling Medical Information), according to its business content.

2. Proper Acquisition

  • The Company acquires personal information by proper methods, without deception or other wrongful means.
  • When acquiring special care-required personal information, the Company obtains the individual’s prior consent, except for the exceptions provided by law.

3. Specification of the Purpose of Use and Restriction of Use

  • The Company specifies the purpose of use of personal information as specifically as possible, and announces it in advance or notifies the individual.
  • The Company does not handle personal information beyond the scope necessary to achieve the specified purpose of use. Where it handles information beyond the purpose of use, it obtains the individual’s prior consent.
  • The Company does not use personal information by methods that may encourage or induce illegal or unjust acts.

4. Strict Handling of Special Care-Required Personal Information

  • The Company strictly manages, separately from other personal information, the biometric and health-related information estimated through non-contact vital measurement and other special care-required personal information.
  • The Company does not perform opt-out (third-party provision without the individual’s consent) under the APPI for special care-required personal information. When providing it to third parties, the Company obtains the individual’s prior consent, except for the exceptions provided by law.

5. Security Management Measures

To prevent the leakage, loss, or damage of the personal data it handles and to otherwise ensure secure management, the Company takes necessary and appropriate measures, including the following.

  • Organizational measures: appointment of a personal information protection manager, development of rules, and establishment of systems for inspecting and auditing the handling status.
  • Human measures: periodic training of employees and agreements on confidentiality.
  • Physical measures: area management, prevention of theft of equipment and media, and measures when taking them out.
  • Technical measures: access control, identification and authentication of accessing persons, measures against unauthorized access, encryption, and other protection of information systems.
  • Handling region: The Company handles personal data within Japan.

6. Supervision of Contractors

  • When entrusting all or part of the handling of personal data, the Company appropriately selects the contractor, obligates safety-management measures by contract, and exercises necessary and appropriate supervision over the contractor.

7. Restriction on Third-Party Provision

  • Except where provided by law, the Company does not provide personal data to third parties without the individual’s prior consent.
  • At present, the Company does not perform third-party provision or joint use of personal data based on the individual’s consent. If it does so, it will amend the Privacy Policy in advance and implement the necessary procedures.

8. Proper Handling of Anonymously and Pseudonymously Processed Information

  • Where the Company creates or handles anonymously or pseudonymously processed information for utilization in R&D in the health and medical fields, it processes the information appropriately in accordance with the standards set by the APPI and complies with the prohibition on identification acts and other obligations.
  • When the Company creates anonymously processed information, it announces the items of information contained therein in accordance with law.

9. Respect for the Rights of Individuals

  • The Company responds appropriately and promptly, in accordance with law, to requests from individuals regarding retained personal data — including disclosure, correction/addition/deletion of content, suspension of use/erasure, and suspension of third-party provision.

10. Employee Training

  • The Company periodically conducts the necessary education and training for its officers and employees to ensure the proper handling of personal information.

11. Continuous Improvement

  • The Company periodically inspects and reviews the handling of personal information and its security-management measures, and continuously improves this Policy and related rules (Plan-Do-Check-Act).

12. Handling of Complaints and Consultations

  • The Company establishes a contact point to respond appropriately and promptly to complaints and consultations regarding the handling of personal information, and responds in good faith.

13. Personal Information Protection Manager and Contact

For matters concerning this Policy and inquiries regarding the handling of personal information, please contact the following.

  • Personal Information Protection Manager: Teppei Todo, Executive Officer
  • Contact: METRIA Inc. Personal Information Inquiry Desk
  • Email: contact@metria-vitals.com
  • Address: 1-9-11 Higashi-Azabu, Minato-ku, Tokyo, Japan

Enacted: July 25, 2026 METRIA Inc., Yusuke Fukushima, Representative Director