Website, Contact Us and Services Privacy Notice
Website and Digital Platform Visitors, Users of Otsuka Products and Services and Contacting Us
This website is operated by Otsuka Pharmaceutical Europe Ltd. (“Otsuka”), 2 Windsor Dials, Arthur Road, Windsor, SL4 1RS. In this notice, we may also refer to Otsuka as ‘we’, ‘our’ and ‘us’.
This notice explains how and why we use your personal data, e.g. when we provide you with information you have requested from us, within the framework of any agreement pursuant to which you provide products or services to, or receive products or services from, Otsuka or when you simply use our websites and other digital platforms. In all cases, Otsuka understands and respects your privacy and acknowledges that in particular the information about an individual’s health and healthcare is confidential and sensitive.
In this notice, when we talk about personal data, we mean any information that relates to an identifiable natural person—in this case, you.
You should read this notice, so you know what personal data we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other privacy notices that we give you that might apply to our use of your personal data in specific circumstances from time to time.
If you have any questions about this notice, you can contact Otsuka’s Data Protection Office at Otsuka Pharmaceutical Europe Ltd., 2 Windsor Dials, Arthur Road, Windsor, SL4 1RS or by
We process personal data for different purposes, depending on who you are and our relationship with you. To find out for what specific purposes we process your personal data, please navigate to the relevant privacy notice to you via the Otsuka Privacy Hub where you will find a more comprehensive overview of processing.
This notice is applicable to:
- Website visitors, just browsing the Otsuka websites;
- Individuals using Otsuka digital platforms;
- Individuals providing services to Otsuka or ordering products or services from Otsuka;
- Individuals who contact or would like to be contacted by Otsuka; and
- Individuals to whom other privacy notices are not applicable.
Otsuka is a controller in relation to its use of your personal data. This is a legal term—it means that we make decisions about how and why we use your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws. We are required by law to give you the information in this notice.
4.1. The personal data we process about you broadly falls into three main categories: (i) contact information; (ii) agreement information; and (iv) browsing information.
4.2. We collect your personal information from limited sources. The table below sets out the different types of personal information that we collect and the sources we collect it from:
|
Category |
Type of personal data |
Collected from |
|
Contact information |
|
|
|
Agreement information |
|
|
4.3. Please note that if you do not provide us with your contact information, we will not be able to provide you with any information you request, and if you do not provide us with your contact information or agreement information, we will not be able to interact or contract with you.
5.1. We use your personal data for a number of different purposes. We must always have a lawful basis (i.e. a reason or justification, prescribed by law) for processing your personal data. The table below sets out the purposes for which we process the different categories of your personal data and the corresponding lawful basis for that processing. For some processing activities, we consider that more than one lawful basis may be relevant, depending on the circumstances.
|
Category |
Purposes of processing |
Lawful basis |
|
Contact information |
Responding to your enquiries; and Responding to your orders for products or services. |
To perform a contract with you Legitimate interests (it’s important that we can respond to your enquiries) |
|
Browsing information |
Monitoring and producing statistical information regarding the use of our platforms and analysing and improving their functionality. |
Legitimate interests (we need to perform this limited routine monitoring to make sure our platforms work properly) |
|
Agreement information |
To be able to keep accurate records of Otsuka’s communications with you. In addition, we may need the information you provide to comply with our regulatory monitoring and reporting obligations. |
To perform a contract with you To comply with a legal obligation |
|
Agreement information |
Disclosure of payments according to regulatory requirements. |
Consent To comply with a legal obligation Legitimate interests (to ensure transparency) |
|
Agreement information |
To understand how our products impact your patients, to track and respond to safety concerns and to further develop and improve our products and services. For example, we may create a record about you to decide whether to invite you to participate in various programmes, panels of experts or surveys about our products or services. |
Legitimate interests (we need to use certain personal data for our business development strategies; we have a legitimate interest in making sure that we are continuously improving our product offering) |
|
Agreement information |
Compliance with our legal obligations where data related to safety or pharmacovigilance is concerned, including those related to adverse events, product complaints and patient safety. |
To comply with a legal obligation |
|
All information |
Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity; complying with instructions from law enforcement agencies, any court or otherwise as required by law; and resolving any complaints from or disputes with you. |
To comply with a legal obligation |
5.2. Cookies and similar technologies
For more information regarding how we use cookies and similar technologies in connection with your use of our website, please read our
6.1. Sometimes we share your personal data with third parties, including the following:
6.1.1. other Otsuka companies where necessary for the purposes described above;
6.1.2. alliance partners who co-commercialise our products in certain territories for the purposes described above;
6.1.3. courts, where we are asked to respond to a court order or other binding requests;
6.1.4. regulatory authorities and law enforcement agencies, where necessary for any investigations or to respond to enquiries in relation to our compliance with applicable law or regulations; and
6.1.5. professional advisors (such as lawyers and accountants).
These organisations will also use your personal data as a controller—they will have their own privacy notices, which you should read, and they have their own responsibilities to comply with applicable data protection laws.
6.2. We also ask third party service providers to carry out certain business functions for us.
These include:
6.2.1. IT support, cloud platform and data hosting providers who help us with the operation of our websites, mobile applications, document and workflow management systems and other systems and applications;
6.2.2. service providers assisting us in the organisation of events, arranging travel logistics and bookings;
6.2.3. service providers who assist with supply chain logistics, delivery of and payment for products and related queries or complaints;
6.2.4. third parties assisting on the collection and disclosure of transfer of value information to the public;
6.2.5. communication service providers, including companies who send out surveys and communications on our behalf;
6.2.6. survey providers who help collate feedback for us; and
6.2.7. other Otsuka companies where necessary for the purposes described above.
We will have in place an agreement with our service providers, which will restrict how they are able to process your personal data and impose appropriate security standards on them.
7.1 Since Otsuka is part of a global company, we will sometimes need to transfer your personal data outside the European Union, in particular to the US and our headquarters in Japan. We will only make that transfer if:
7.1.1. that country ensures an adequate level of protection for your personal data;
7.1.2. the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments that amount to appropriate safeguards for your personal data;
7.1.3. we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data, which incorporates specific provisions as directed by the European Commission;
7.1.4. the transfer is permitted by applicable laws; and
7.1.5. you explicitly consent to the transfer.
7.2. If you would like to see a copy of any relevant provisions, please contact us at the address above or
8.1. We will put in place appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
8.2. However please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk.
9.1 We will only retain your personal data for a limited period of time, and for no longer than is necessary for the purposes for which we are processing it for. This will depend on a number of factors, including:
9.1.1. any laws or regulations that we are required to follow;
9.1.2. whether we are in a legal or other type of dispute with each other or any third party;
9.1.3. the type of information that we hold about you; and
9.1.4. whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
10.1. You have a number of rights which apply to the use of your personal data. The availability of these rights depends upon the lawful basis for processing your personal data and your rights may also be subject to certain conditions and restrictions. These rights are:
- Right to withdraw consent
- Right to information
- Right of access
- Right to rectification
- Right to erasure (also ‘right to be forgotten’)
- Right to restriction of data processing
- Right to data portability
- Right to object
10.2. For more information on the rights that you have, please click here or go to https://otsukaprivacy.eu/data-subject-rights.
10.3. You also have the right to complain to a data protection authority about our collection and use of personal data. For more information, please contact your local data protection authority. A list of data protection authorities in the European Economic Area is available
10.4. We may decide to change this notice. If the change is fundamental or may significantly affect you, we will provide you with the updated notice in advance of the change actually taking effect. We encourage you to review the content of this notice regularly.
Date of preparation: October 2024 | OPE-NPR-2400070 (v1.0)