DATA PRIVACY NOTICE

Conceive IVF Manila Inc. (Kato Fertility Center) (“We”, “CIMI”, or the “Company”) is a fertility center located in Quezon, Philippines. CIMI performs fertility workups in order to help couples choose the best fertility treatment based on their medical history and age. CIMI uses Assisted Reproductive Technology methods that adhere to international and local standards of medical practice.

As the services provided by the Company may from time to time entail the processing of Personal Data, CIMI ensures strict compliance with Republic Act No. 10173, otherwise known as “The Data Privacy Act of 2012” (“DPA”), its Implementing Rules and Regulations (“Rules”), and the various issuances and policies of the National Privacy Commission (“NPC”) (collectively, the “DPA and Rules”).

In this Privacy Notice, you will know how we handle your Personal Data and how we protect them. We want you to know what data we have on you, how you can access your Personal Data, and when necessary, how you can correct or have the said data deleted. In case you have a complaint or concern regarding your privacy, we undertake to settle the same immediately.

Scope and Application

We may collect your Personal Data, which can either be Personal Information and/or Sensitive Personal Information, when you avail of our services, contact us via our email, or through online job search engines, or when you submit to us your curriculum vitae, application letters, and other similar, related, or supporting documents for employment.

By submitting your Personal Data to CIMI through these means, or by availing of CIMI’s services and products, you consent to the processing of your Personal Data as stated in this Privacy Notice. Under the DPA and the Rules, “processing” includes the collection, recording, organization, storage, updating, modification, retrieval, consultation, use, consolidation, blocking, erasure, or destruction of data.

If you do not agree with any provision of this Privacy Notice, please do not provide CIMI with your Personal Data. However, CIMI may not be able to provide you with the services requiring the use of such Personal Data.

Personal Data that CIMI Collects

CIMI collects your Personal Data in order to provide you with medical services and treatment, employment, and/or other related services. This may include the endorsement of your Personal Data to the Company’s third-party service providers for the purposes of providing you with better service or for employment purposes.

The DPA defines Personal Information1 as any information, whether or not recorded in a material form, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual. This includes your name, mobile phone number, landline, residential address, email address and references, among others.

Other Personal Information that you will provide may be considered Sensitive Personal Information2 under the DPA. This includes your age, race, marital status, health, education, employment history, and social security number, among others. CIMI will collect, use, or disclose your Sensitive Personal Information only in accordance with the DPA and the Rules, and only after it has obtained your prior written consent.

Personal Information and Sensitive Personal Information are collectively referred to as Personal Data.

How CIMI Collects Personal Data

CIMI generally collects Personal Data directly from you when you:

1. Avail of our services, including any fertility workups or IVF treatments;
2. Communicate with CIMI officers and Employees in person or online, or by telephone, letter, email, facsimile, or via online job search engines;
3. Submit to us your curriculum vitae, application letters, and other similar, related, or supporting documents, whether for purposes of applying for a job or upon actual employment by the Company; and
4. Submit any other information in connection with any queries sent or addressed to the Company.

CIMI also collects your Personal Data from third parties which we contact for verification purposes in
connection with your medical treatment and/or job application or employment, such as in the following
instances:

1. verification from banking and other medical institutions, if necessary;
2. from the references you have provided;
3. verification from academic institutions, professional associations, and/or licensing bodies of the educational and professional qualifications you have stated in your curriculum vitae;
4. inquiries with former employers and co-workers;
5. performance feedback, including any administrative proceedings you were involved in at the workplace; and/or
6. information on any investigation, professional license disciplinary matter, or criminal, civil or other legal proceedings in which you are or were involved.

How CIMI May Use Your Personal Data

Personal Data collected and received by CIMI shall be used and processed in order to provide you with employment, with customer service or medical treatment, and/or with other related services, which may include:

1. the verification or vetting of your credentials and other Personal Data for responding to your inquiries or concerns;
2. the endorsement of your Personal Data to CIMI’s departments for purposes of providing you with
   employment;
3. for the provision and management of your benefits and compensation as an employee; and
4. for other purposes for which you have availed of CIMI’s services.

CIMI will also use your Personal Information for future marketing, advertising, and promotional activities, provided that it first obtains your prior written consent for such purpose.

How CIMI May Disclose or Share Personal Data with Third Parties

CIMI will only share your Personal Data to third parties who have proper interest thereto and only with your consent, unless permitted or required by law. CIMI shall take reasonable steps to ensure that third parties are bound by written agreements to use your Personal Data solely for the stated purpose and in accordance with CIMI’s instructions, and to comply with the DPA and the Rules. CIMI may share your Personal Data with third parties, such as:

1. service providers or contractors engaged to perform services on CIMI’s behalf, including IT consultants conducting testing and development work on CIMI’s IT systems or data encoders who encode your Personal Data in CIMI’s standard format; and
2. in the event CIMI enters into a joint venture with, or is sold to or merged with another business entity, the new owner who would have access to the information held by CIMI, which could include your Personal Data.

If You Choose Not to Provide Your Personal Data

When you refuse to provide or decide to withdraw your Personal Data, CIMI will be unable to provide you with medical treatment, employment, customer service, and other related services.

Personal Data Security and Retention

1. Security
   CIMI adopts appropriate organizational, physical, and technical measures to protect your Personal Data against any accidental or unlawful/unauthorized destruction, alteration and disclosure, fraudulent misuse, as well as against any other unlawful/unauthorized processing. CIMI stores Personal Data in secure digital data storage and those contained in paper-based files are kept inside secure premises or locked filing areas. Among the other measures taken by CIMI to ensure the protection of your Personal Data, are the following:
   1. trainings and seminars for CIMI’s officers and employees are conducted to ensure that they
      know how to keep your Personal Information safe and secure at all times;
   2. locks are installed, secure filing cabinets are provided for use, and security systems are in place in CIMI’s office premises;
   3. computer passwords are in use to limit access to shared network drives;
   4. passwords and other encryption methods are in use to protect files and electronic documents from unauthorized sharing/disclosure;
   5. access to hard copies of documents containing Personal Data is limited to only specifically authorized staff;
   6. data integrity audits are conducted;
   7. firewalls and virus scanning tools are in use to prevent unauthorized access into the system; and
   8. proper tracking of movement and transfer of custody of files containing Personal Data is being observed.
2. Retention
   CIMI will retain your Personal Data only for as long as is necessary for the stated purpose or for so long as may be permitted by the DPA and Rules. When no longer required or if you ask to be removed from CIMI’s systems, CIMI will dispose or delete your Personal Data in a secure manner that would prevent further processing, unauthorized access, and/or disclosure to any other party or to the public.

Access, Updating, Correction, or Deletion of Your Personal Data

You can view the information we have about you by contacting us through our website or by calling or emailing us. Please see our contact information below. CIMI may, however, deny your request for access on legal grounds which will be promptly communicated to you.

Generally, you can view your information without a fee, but if you will request for your information to be stored in a material form such as a CD or in a printed form, we may ask for a reasonable fee to cover the time we spent recording or printing your information and any photocopying or printing expense incurred by the Company. We will inform you of such a fee before proceeding to process your request.

In case you find that your Personal Data with CIMI is incorrect or inaccurate, you may inform us of the same, and after we verify your identity and determine that your request is reasonable, we will correct the information immediately and take the necessary steps to ensure that all records pertaining to your Personal Information are corrected and updated.

CIMI will likewise undertake to suspend, withdraw, block, remove or destroy your Personal Data from CIMI’s personal information filing system upon your request, after we have sufficiently verified your identity and have determined the reasonableness of such request.

Transfer of Your Personal Data Outside the Philippines

In the event that your Personal Data is transferred outside the Philippines, we will take steps to ensure that the concerned Personal Data continues to receive a standard of protection that is at least comparable to that provided under the DPA.

Changes to this Privacy Notice

CIMI may revise or update this Privacy Notice at any time upon posting a notice of such change or update in its website.

How to Contact Us

With regard to your privacy concerns, you may contact us through:

Postal Address: Unit 02 8th Floor Hexagon Corporate Center 1471 Quezon Ave. Brgy. West Triangle, Quezon
City 1104 Metro Manila, Philippines
Landline: 02-8298-4734
Email: dataprivacy@conceive.ph

¹ Data Privacy Act of 2012, Section 3 (g). Personal information refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

² Data Privacy Act of 2012, Section 3 (l). Sensitive Personal Information refers to personal information:

1. 1. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political
      affiliations;
   2. About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense
      committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;
   3. Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
   4. Specifically established by an executive order or an act of Congress to be kept classified.