PRIVACY POLICY FOR TOPPAN PHOTOMASKS, INC.

  1. Toppan Photomasks, Inc. and its consolidated subsidiaries (collectively, "Toppan Photomasks," "we" or "our") have established this policy (this "Policy") regarding the privacy of "Personal Information." Personal Information means all data about an identified or identifiable individual that is recorded or maintained by Toppan Photomasks in any form. Personal Information includes all data that is within the scope of the European UnionŐs Directive on Data Protection (the "Directive"), as well as all data that is within the scope of any similar laws or regulations of any other jurisdiction in which Toppan Photomasks does business. Toppan Photomasks will respect all applicable laws and regulations regarding the privacy of Personal Information, including without limitation the U.S. Health Insurance Portability and Accountability Act. As part of our compliance program with respect to the Directive, we adhere to the Safe Harbor Privacy Principles issued by the United States Department of Commerce.
  2. Toppan Photomasks may, from time to time, review and/or modify this Policy and/or our Personal Information collection, use, transmission, storage, maintenance and disclosure practices. Any modifications to this Policy will be posted on our Intranet. To the extent permitted by applicable laws and regulations, modifications may be made retroactively when appropriate.
  3. Toppan Photomasks hereby gives all employees and contractors notice that we collect, create, transmit, store, maintain and use employee and contractor data worldwide for purposes of establishing and administering our relationships with those persons, including without limitation: evaluation of qualifications for employment, background screening, reference checks and employment decisions; employee evaluations (including, without limitation, productivity and performance data); provision, evaluation and administration of wages, salary, benefits, variable compensation, stock option and other compensation and benefits matters; expatriate programs and benefits; work authorizations and permits; performance and workforce tracking, management and training; budget preparation and analysis; business contact directories; security and computer network access, authentication and customization; and reporting to Toppan Photomasks management and auditing regarding all of the above. We do not use such data for purposes of marketing any products or services to such persons. Subject to the terms of the Directive, we do not collect "sensitive data" (as defined in the Directive) from individuals in the European Union without the explicit consent of the applicable individual, and we will protect any "sensitive data" that we do collect in accordance with all applicable laws and regulations, including the Directive.
  4. From time to time we contract with certain agents that assist with the processing of certain Personal Information. Those agents have assured us that they provide equivalent levels of privacy protection as required by this Policy. You may obtain further information regarding those assurances from the Vice President of Global Human Resources. In addition, we may from time to time remove identifiable features from Personal Information and the resulting information may then be used for statistical, historic, scientific or other purposes, consistent with applicable laws and regulations.
  5. Please contact your local Human Resources representative if you have any complaints, concerns or questions regarding use of your Personal Information, or if you wish to access, delete or correct your Personal Information. We will investigate and resolve all such complaints, concerns, questions and requests, in accordance with this Policy and applicable laws and regulations. Upon request, we will provide information regarding the processes we use to handle such complaints, concerns, questions and requests. The Vice President of Global Human Resources is primarily responsible for administering this Policy.
  6. Toppan Photomasks will provide to the applicable individual a statement of the consequences of any decision by such individual not to provide Personal Information that we have requested. Certain types of Personal Information are required in order to establish and maintain an employment relationship.
  7. We will, and we expect and require each employee and contractor to, use reasonable commercial efforts to: maintain the security, integrity and accuracy of Personal Information; protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction; and ensure that Personal Information is reliable for its intended use, accurate, complete and current.
  8. Toppan Photomasks will, to the extent required by law or court order, collect, use, and/or disclose Personal Information (for example, in connection with law enforcement investigations).
  9. Personal Information should neither be forwarded to personal email accounts nor stored on personal computers or storage devices other than those provided by and under the control of Toppan Photomasks. Personal Information should not be removed from the premises of Toppan Photomasks other than in accordance with established procedures of Toppan Photomasks.