Privacy Policy

The categories of data subject

• Healthcare Professionals (HCP): Doctors, nurses, other health care professionals, etc.
• Business Partners: Vendors, Contractors, suppliers, other business partners along with their representatives or staff members, etc.
• Patients: Patients (former or current), potential patients, parents or guardians and caregivers, etc. and members and staff of patient advocacy groups
• Members of the Public: users of public-facing websites, mobile apps, other online platforms, etc or who attend our business or premises

The categories of personal data

• Personal details: name, address, phone number, e-mail address, gender, country of birth/residence, nationality, citizenship, employment status, and family status, etc.
• Financial details: bank account information, payment card details, payment details, income tax details, transaction data, billing information, tax numbers, tax administrative data, etc.
• Voice or Image Data: authorized photographs, videos, recordings, etc.
• Technical and Usage Data: including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform, your preferences in receiving marketing information from us, your communication preferences and information about how you use our websites(s) and services, including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs). More details on our use of cookies can be found in our [Privacy Preference Centre].
• Professional Data including occupation, place of work, professional registration number, professional background and interests, medical specialization, professional memberships and affiliations.
• Employment and business information: your position and employer, your work contact details and your interaction with us in your role, including information provided in the course of the contractual or client relationship between you or your organisation and Kyowa Kirin, or otherwise voluntarily provided by you or your organisation.
• Communications content: any other information you may provide in your communications with us.

The categories of sensitive data

• Health and medical records: family medical history, sexual history, sexual orientation, ethnicity, diseases and illnesses, disability, health statistics such as blood pressure, smoking status, alcohol intake, type of dialysis treatment, current therapies, prescriptions and medications, patient type, consumption and usage of equipment and medications, record of hospitalization, laboratory results and adverse reactions to treatment
• Medical Photographs and images: medical images including radiology scans and other such visual representations.
• Physiological and Physical Data: activity data gathered through self-report in dedicated apps, wearables, or other technology.

• Your engagements with other Kyowa Kirin entities, or Kyowa Kirin websites or services. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
• Healthcare professionals or pharmacies, particularly in relation to safety/adverse event reports or engagements through clinical trials or early access programs or where there has been a complaint;
• Third parties we work with (including, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics, providers, search information providers, credit reference agencies, etc.) If you are a health care professional, we receive information about your professional life (such as medical specialisation and professional background) from third party sources, including Clinical Research Organisations.
• Other organizations you have provided permission to share with us.
• Publicly available sources (where possible) to keep your information up to date (Post Office’s National Change of Address Database or any professional registration database)
• Occasionally purchasing the contact information of people who might be interested in hearing from us. We only contact people who have actively expressed an interest in receiving information from third parties.
• We may receive information about you if you apply for a vacancy at Kyowa Kirin, particularly from any third party recruitment agency or website you have engaged with for this purpose.

Legal bases relied on by Kyowa Kirin for processing described in this privacy notice

• Consent – sometimes we ask for your consent to use your data.
• Contract – if we have an agreement in place with you, we may process your data where it is necessary for us to meet our obligations or enforce our rights under the contract.
• Legitimate interest – we can process your data when this is necessary for us to achieve a legitimate business purpose, or where this is necessary for someone else to achieve their legitimate purpose. We explain below what interests we, or others, are trying to achieve when we process your data. Where we process personal data on the basis of a legitimate interest, then we consider what the impact of the processing will be on affected individuals to determine whether those individuals’ interests outweigh our interests in the processing taking place.
• Legal obligation – we have obligations to comply with legal and regulatory requirements under various applicable laws. In certain cases, we have to use your data to meet these obligations.
• Publicly-available data – where permitted by applicable laws, we may use your data already publicly disclosed either by you or otherwise legally publicized in a reasonable manner as prescribed by the applicable law.

Purposes

• A member of our group where we have a legal basis for doing so.
  Global Network
• Companies who provide services to us or on our behalf, answering questions about products or services, sending mail and emails, patient analysis, assessment and profiling and when using auditors or other professional advisors.
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Analytics and search engine providers that assist us in the improvement and optimization of our site.
• IT service providers.
• Clinical Research Organizations.
• Healthcare Professionals.
• Other organizations, including universities, when we run an event in partnership with such other organizations. In such case, your personal data may need to be shared. We will be very clear about what will happen to your personal data when you register for such events.
• A new entity or purchaser, in the case we merge with another organization or form a new entity. In such case, your personal data may be transferred to that new entity and/or purchaser, including their professional advisors.
• Appropriate third parties where this is necessary to:
  • Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies or is required by any stock exchange rules where a member of the Kyowa Kirin Group is listed.
  • Enforce or apply our terms of use and any other agreements.
  • Protect the rights, property, or safety of us, our employees or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

• The right to access – You have the right to request that we provide copies of your personal data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete any information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Right to lodge a complaint with a supervisory authority – You might have the right to lodge a complaint with a supervisory authority against the processing of your personal data if you believe that the processing of your personal data violates data protection regulations.
• Other rights under applicable data and privacy laws and regulations.

• if we process your personal data for direct marketing purposes; or
• insofar as we process your personal data for the pursuit of our legitimate interests and there are grounds based on your particular situation.