Takeda General Privacy Notice

Effective date of this privacy notice: October, 2019

Takeda recognizes and respects the privacy rights of individuals with regard to their personal data. This Privacy Notice (“Notice”) explains what type of personal data we may collect about you and how we use it.

Your privacy is important to us. If you have any questions concerning Takeda’s privacy practices or wish to exercise your rights relating to personal data that Takeda has collected about you, please contact us as described in the “How to Contact Us” section below.

Applicability and Organizations Covered by This Privacy Notice

Takeda is a group of companies with operations globally. The Takeda enterprise (“Takeda”, “we”, “us”, “our”) includes the parent company Takeda Pharmaceutical Company Limited, and its affiliated entities. For contact information related to your local affiliate, please refer to Takeda’s website at https://www.takeda.com/countries.

This Notice applies to Takeda websites, social media pages, (mobile) applications, surveys, patient and healthcare professional support activities, as well as other Takeda services and activities that display or reference this Notice (together “Services”).

Any person accessing, browsing or otherwise using the Services, either manually or via an automated device or program, shall be considered a “User.”

All Users are bound to the terms of this Notice and to any specific terms of use associated with the applicable Service. Your continued use of Takeda Services means you continue to be informed about the collection, use and disclosure of your personal data as described in this Notice.

Personal Data We Collect and Use

Takeda collects personal data to operate effectively and provide you with the best experiences from our Services.

Takeda collects information directly from you through your interactions with us when you sign up for a Service, enter into a contract with us, submit an application to us, and through various other engagements we may have with you. We may use technologies that automatically collect information when you visit our sites, view our advertisements, or use our products or services.

We also may collect information about you from third-parties, such as our vendors, suppliers, contractors, and business partners. For example, we may use such third-party data to confirm contact or financial information, to verify qualifications of healthcare professionals and to check references.

The type of personal data we collect depends on the interactions you have with Takeda and the Takeda Services you use. These may include:

  • Name and contact data: We may collect your name, postal address, email address, telephone number and other similar contact data.
  • Credentials: We may collect passwords, password hints and similar security information used for authentication and Takeda account access.
  • Educational and Professional Details: We may collect when you submit your CV, qualifications and organizational or institutional affiliations, activities performed as part of your professional experience, and your skills;
  • Government-issued Identification: We may collect certain types of government-issued data from you, including Social Security Numbers, national identification numbers, driver’s license data, and passport data.
  • Demographic data: We may collect data about you such as your age, gender, country of origin or residence, and preferred language.
  • Preferences, interests and favorites: We may collect data about your professional or personal interests and favorites, such as the websites you visit, your dietary requirements etc.
  • Financial data: We may collect data necessary to process payments, such as a bank account or credit card number.
  • Usage data: We may collect data about how you and your device interact with our Services, such as Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser-plug-in types and versions, operating system and platform; Information about your visit and online activities (e.g. page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.)
  • Relationship and interaction data: We may collect data about our interactions and meetings, such as when you contact us for information and support.
  • Photographic and video information: We may collect images or videos related to you, including as a result of video surveillance for us to keep our premises secure.
  • Location data: We may collect data about your location, which can be either precise or imprecise. Precise data includes geolocation data. Imprecise location data includes, for example, a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postcode level.
  • Health-related data: We may collect data related to your healthcare, including prior authorization for payment of healthcare services, patient engagement and support services, and prescription information.
  • Clinical data: We may collect data related to our research and development and clinical studies, registries and trials.
  • Biometric Information: We may collect data related to your biometrics, such as fingerprints, voice prints, or other unique physical characteristics.
  • Legally Required Information: We may collect additional data about you that is related to patient safety and adverse events, or that may be required by laws that apply to Takeda.

In some cases, we may enhance the information we hold about you with information we receive from third parties and with information which is publicly or commercially available and/or which is obtained by any other legal means.

For example, we may collect publicly available information about you, including online postings, social media platforms, publication databases, journals, and societies. Please note that any information you post or disclose through these services may become publicly available information to users of the service you provided it to, and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, in these forums, and to carefully review and familiarize yourself with applicable privacy settings and options.

How We Use Personal Data

Depending on your relationship with Takeda, Takeda uses the personal data we collect for a number of basic purposes, described in more detail below: (1) for business operations (marketing and sales, research and development, patient support, donations and sponsorships, communications), (2) for business administration (finance and accounting, human resources, prevention and investigatory activities), (3) for business management (internal audit, asset management, system and business controls), and (4) as necessary to protect the health, safety, and security of Takeda personnel and to comply with legal requirements and obligations.

We may use personal data:

  • To communicate with you regarding any requests or inquiries you may submit and to provide you with related support or Service.
  • To contact you from time to time to provide you with important information, required notices, and promotional materials.
  • To send administrative information to you, for example, information regarding the (changes to) Services we provide.
  • To personalize your experience when using our Services by presenting products and offers tailored to you.
  • To identify you to anyone to whom you send messages using our Services.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, conducting surveys, and operating and expanding our business activities.
  • To better understand how our products and Services impact you, to track and respond to safety concerns and to further develop and improve our products and Services.
  • To offer special programs, activities, clinical trials, events or promotions via our Services that have specific terms, privacy notices and/or informed consent forms that explain how personal data you provide will be processed in connection with such special program. Some of these special programs may involve sharing information with a third party and Takeda will provide you with notice of this. You may be offered the opportunity to agree to or opt-out of the sharing of your data with such third party. But, in some instances, it may be necessary to agree to share with a third party in order to participate in the special program. The personal data you provide may be used by the third party in accordance with the special program terms and, unless provided otherwise in such special program terms, for their own purposes in accordance with their own policies/terms. We encourage you to review both the special program terms and any applicable third party policies/terms before participating.
  • As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may incur.

Legal Basis for Processing Personal Data

When Takeda engages in the processing of your personal data, we will only do so if this is allowed, also referred to as having a legal basis to process your personal data. The legal bases Takeda would rely on include:

  • when we have a contract or agreement with you – for example, a contract to supply goods or services (i.e. when you engage with us to visit a Takeda organized event, or order information on-line), or an employee contract;
  • when we must comply with a legal obligation – for example, when processing your data is a legal requirement, for example in some countries there are transparency requirements regarding interaction with healthcare professionals, or to provide information to authorities in case of adverse events related to use of our products;
  • when data processing is in your vital interests – for example, when this might protect your life;
  • when processing your data for our legitimate interests as a pharmaceutical company in compliance with our corporate policies – for example, to communicate with you about our products and services, about scientific research and educational opportunities, scientific and market research surveys, as well as for the effective continuation of our business operations.

In all situations where there is no other legal basis, Takeda will ask for your agreement (known as “consent”) as legal basis to process your personal data.

Note that if you provide your consent, you may also at any time withdraw your consent by contacting us as described in the “How to Contact Us” section. It is also important to know that you have other rights regarding the processing of your personal data, see the section on “Your rights related to your personal data”.

Who We Share Personal Data With

We share data with Takeda-controlled affiliates and subsidiaries; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our Services; and to protect the rights or property of Takeda.

In such cases, Takeda will require these third parties to protect the confidentiality and security of the personal data that is shared with them. These third parties will be required to agree that they will not use or disclose personal data about you except as necessary to provide services to us or perform services on our behalf, or as necessary to comply with applicable laws or regulations.

Takeda may share your personal data with affiliates and third parties as follows:

  • Among affiliates for the purposes described in this Notice. Takeda is the party responsible for the management of the jointly-used personal data.
  • To our third-party service providers that provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. Takeda policy requires that our service providers adhere to appropriate restrictions on access and use of your personal data.
  • To third parties to allow them to send you marketing communications.
  • To third-party sponsors of sweepstakes, contests and similar promotions.

We may also disclose your personal data in the following circumstances:

  • In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings. As required by law, including laws outside your country of residence, to comply with a subpoena, required registration, or legal process.

We may also disclose aggregate or de-identified data that is not personally identifiable to third parties. Aggregate data is created by collecting and processing information about individuals and summarizing the data, eliminating the possibility to identify an individual.

How Do We Protect Your Personal Data

We have implemented a variety of security technologies and organizational procedures to protect your personal data from unauthorized access, use and disclosure. For example, we store your personal data on computer systems that have various types of technical and physical access controls, such as encryption. Takeda has implemented data security controls consistent with industry standards; however, Takeda cannot guarantee the security of your information. It is also important for you to protect against unauthorized access to your password(s) and your computer, mobile devices, etc. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately as described in the “How to Contact Us” section below.

Where We Store and Process Personal Data

As Takeda is a multi-national organization with locations in many countries around the world, your personal data may be stored and processed in any country in which we operate, including where we have facilities, or in which we engage service providers. Takeda takes steps to process personal data according to the provisions of this Notice and the requirements of applicable law.

Takeda may transfer personal data to countries outside of your country of residence. The laws of the receiving countries may not provide as stringent protections for personal data as your country of residence. In instances where a lesser level of protection is provided by a receiving country, Takeda undertakes that adequate safeguards are in place and that applicable laws and regulations are complied with in connection with such transfers.

In certain cases, Takeda undertakes to enter into contractual agreements (e.g., European Union Standard Contractual Clauses), or relies on other available data transfer mechanisms that aim to provide adequate protections. A copy of the EU Standard Contractual Clauses boilerplate contracts may be found at: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/.

To obtain additional information regarding the safeguards that Takeda has put in place to govern cross-border transfers of personal data, please contact us using the information provided in the “How to Contact Us” section.

Retention Period

Takeda will retain your personal data for the period necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or permitted by law.

Your Rights Related to Your Personal Data

You have choices about the data we collect. When you are asked to share your personal data with Takeda, you may decline; however, your choice not to share your personal data with Takeda may mean you will not be able to use or (fully) benefit from our Services, features or offerings.

Takeda respects your right to know and inquire about what personal data we have collected about you. In addition, you have the right to request correction or deletion of such personal data, as well as to request removal of your personal data held by third parties with whom we conduct business.

For more information about your privacy rights, or if you are not able to resolve a problem directly with us and wish to make a complaint, please contact the relevant data protection authority that is responsible for making sure that privacy laws are followed in your country of residence. Individuals residing in the EEA and Switzerland may find a list of their local data protection authorities at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. For further details on other jurisdictions’ data protection authorities, please contact us as described in the “How to Contact Us” section below.

If you would like to make a request for Takeda to correct or delete personal data that you have provided to Takeda, please contact us as described in the “How to Contact Us” section below, and we will respond in a reasonable time. We will make a good faith effort to provide you with access to your personal data and to correct any inaccuracies or delete such information at your request if it is not otherwise required to be retained by law or for Takeda’s legitimate business purposes. If for any reason your request is declined, we will notify you. Before fulfilling your requests we may need to verify your identity.

Takeda will inform you if it intends to use your data for marketing purposes and to send marketing communications to you or if it intends to disclose your information to any third party for such purposes. You have the right to opt out from marketing communications that are being sent to you by Takeda. You can exercise your right to prevent such processing by informing Takeda at any time that you do not wish to receive such marketing. Where you wish to exercise this right, please use the “unsubscribe” functionality in the relevant communications or refer to the “How to Contact Us” section below.

Children

Takeda treats children’s information with extra care to ensure that they receive additional protection and safety. We may in some instances collect personal data about children with the consent of a parent or guardian for the provision of our Services such as clinical activities or for patient support programs. However, we do not otherwise knowingly solicit data from, or market to, children.

As a parent or guardian, if you wish to remove personal data related to your child, please contact us as described in the “How to Contact Us” section below.

Web, Cookies and Tracking Technologies

Takeda uses cookies (small text files placed on your device) and similar technologies, directly or through third parties, to provide our Services and help collect data. This data allows Takeda to, among other things, store your preferences and settings; enable you to sign-in to websites or applications; provide interest-based advertising; combat fraud; and analyze how our Services are performing.

You have a variety of tools to control cookies and similar technologies, including browser controls to block and delete cookies. Please look at your particular browser for instructions on these functions. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.

Your browser settings and other tools to control cookies and similar technologies may impact your experience with our Services.

We use various types of cookies, as well as similar technologies such as Local Shared Objects (or “Flash Cookies”) and web beacons (also called single-pixel tags) to identify your IP address, browser type, device characteristics, domain name, referring URLs and specific links and web pages through which you click. This data is collected automatically and is used for purposes as mentioned above. This technology also allows us to recognize you when you return to this Site and to provide you with a customized experience that we feel will be of value to you.

In addition, Takeda uses web analytics services (e.g. Google Analytics) to collect website analytics. The information generated about website usage (including your shortened IP address) is transmitted to these web analytics services. This information is used to evaluate visitors’ use of the domain, compile statistical reports on website activity, and provide other services related to the site and internet use activity.

In addition, Takeda uses web analytics services (e.g. Google Analytics) to collect website analytics. The information generated about website usage (including your shortened IP address) is transmitted to these web analytics services. This information is used to evaluate visitors’ use of the domain, compile statistical reports on website activity, and provide other services related to the site and internet use activity.

For example, Google Analytics is a web analytics service provided by Google Inc. ("Google").  Google Analytics uses cookies and similar technologies to analyze how Users use the Domains, and provide other services related to the site and internet use. Google may also collect information about domain visitors’ use of other websites. For more information about Google Analytics, or to opt out of Google Analytics, please go to https://tools.google.com/dlpage/gaoptout.

Furthermore, we may partner with third-party service providers to serve ads regarding goods or services that may be of interest to you when you access and use our Services and third party-sites. Some of the ads on our Services or on third party sites may be personalized, meaning that they are intended to be relevant to you based on what we, or the online advertising network serving the ad, know about you or your computer's browsing activity on both the Service and third-party sites.

To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags).

The Network Advertising Initiative (NAI) offers useful information about internet advertising companies, including information about how to opt-out of interest-based advertising by their members. See http://www.networkadvertising.org for general information about the NAI and http://www.networkadvertising.org/managing/opt_out.asp for the opt-out page. You may also visit http://www.aboutads.info/consumers to learn about interest-based advertising and how to opt-out from ads served by some or all participating companies.

These opt-out mechanisms rely on cookies to remember your choices. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests.

Third Party Services

This Notice does not address, and Takeda is not responsible for, the terms of use, information or privacy practices of any third parties, including any third party operating any site or service to which our Takeda Service links. The inclusion of a link on the Takeda Service does not imply our or our affiliates’ endorsement of the linked site or service.

Social Networks

Generally, social networks are interactive tools that enable you to collaborate and share information. Takeda may collect certain personal data from you to enable you to use online social network features. Takeda may also use these tools to post or share personal data with others. When using social networks, you should be very vigilant about what personal data you choose to share with others. Takeda provides notices and choices about how personal data is collected, used and disclosed on its website, social networks and other services. When engaging in social network activities, you should not post information about third parties without their consent.

Please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other, non-Takeda organizations, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer.  If you choose to share or disclose your personal data to other organizations through, or in connection with our social media pages, you should refer to the privacy notices and terms of use provided by those organizations. Takeda encourages you to review and familiarize yourself with applicable privacy settings and functions of these third-party platforms and applications.

How to Contact Us

Takeda welcomes any questions or comments you may have regarding this Notice or its implementation. Any such questions or comments should be submitted using the contact information below. Please note that email communications are not always secure, so we encourage you not to include sensitive information in your emails to us.

Contact Details:

Mailing Address: Attn: Data Protection Officer, Legal Department, Takeda Pharmaceuticals International AG, Thurgauerstrasse 130, CH-8152 Glattpark-Opfikon (Zürich), Switzerland.

Email Address: privacyoffice@takeda.com

Updates to Our Privacy Notice

Takeda may update this Notice from time to time. Please check this Notice periodically for changes. If we make any changes, the updated Notice will be posted with a revised effective date. We encourage you to periodically review this page for the latest information on our privacy practices.