Takeda Privacy Notice

Last updated: February 2021

Takeda recognizes and respects the privacy rights of individuals regarding their personal data. This privacy notice ("Notice") explains the 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 about Takeda's privacy practices or wish to exercise your rights in connection with personal information 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 with operations globally. The Takeda Group ("Takeda", "we", "us", "our") includes the parent company Takeda Pharmaceutical Company Limited and its subsidiaries. For contact information related to your local subsidiary, see Takeda's website at https://www.takeda.com/who-we-are/company-information/worldwide-offices/ .

This notice applies to Takeda websites, as well as other Takeda services and activities that display or reference this notice (collectively, the "Services").

Any person who accesses, browses or otherwise uses the Services, whether manually or through an automated device or program, shall be considered a "User".

Personal data that we collect and use

Takeda collects personal data to operate efficiently and provide you with the best experience from our services.

Takeda may collect information directly from you through your interactions with us when you register for a Service, enter into an agreement 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 websites, view our advertisements, or use our products or services.

We may also collect information about you from third parties, such as our vendors, suppliers, contractors and business partners. For example, we may use such information from third parties 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. The specific type of personal data that we process about you will be described in the specific privacy notice that you receive from us. If you simply browse one of Takeda's websites, we would only process limited types of personal data such as:

Name and contact information: We may collect your name, postal address, email address, telephone number and other similar contact information if you voluntarily provide this to us.
Usage Data: We may collect data about how you and your device interact with our Services, such as the Internet Protocol (IP) address used to connect your computer to the Internet, your login credentials, browser type and version, time zone setting, plug-in types and browser, operating system and platform versions; Information about your visit and online activities (e.g. page response times, download errors, length of visit to certain pages, page interaction information (e.g. scrolling, clicks and mouse pointers) and methods used to scroll away from the page.)
Relationship and interaction data: We may collect data about our interactions and meetings, for example when you contact us for information and support.
Location Data: We may collect imprecise data such as. a location derived from your IP address or your data that indicates your location with less precision, such as at a city or zip code level.
Legally Required Information : We may collect additional data about you that is related to patient safety and side effects, or as may be required by laws applicable to Takeda.

In some cases, and only for certain types of services, we may enhance the information we have about individuals with information we receive from third parties and with information that is publicly or commercially available and/or obtained by any other legal means.

For example, we may collect publicly available information, including online postings, social media platforms, publication databases, journals and communities. Please note that any information you post or provide through these services may become publicly available information to users of the service you provided it to and to the public. We urge you to use extreme caution when deciding to disclose your personal information, or 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 corporate finance (finance and accounting, human resources, prevention and investigative activities), (3) for corporate governance (internal audit, asset management, system and business controls) and (4) as necessary to protect the health, safety and security of Takeda's personnel and to comply legal requirements and obligations. Takeda does not sell your personal data.

We may use personal data:

To communicate with you about any inquiries or requests 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, necessary notices and promotional materials.
To send you administrative information, for example, information about the (changes in) the services we provide.
To personalize your experience when using our Services by presenting products and offers that are tailored to you when relevant and appropriate.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, improving, enhancing or modifying our services, identifying usage trends, determining the effectiveness of our marketing campaigns, conducting surveys and operating and expanding our business.
To better understand how our products and services affect you, to track and respond to security issues, and to further develop and improve our products and services.
As we deem 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; (e) to protect our or any of our affiliates' operations; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; (g) to enable us to take available measures 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 permitted, also known as having a legal basis for processing your personal data . The legal grounds on which takeda would rely include:

when we have a contract or agreement with you – for example, an agreement to provide goods or services (ie when you engage with us to attend an organized Takeda event or order information online) or an employee contract;
when we have to fulfill a legal obligation – for example when processing your data is a legal requirement, for example in some countries there are transparency requirements for interactions with healthcare professionals or to provide information to authorities in the event of adverse events related to the use of our products;
when data processing is in your vital interest – for example when this may protect your life;
when you process your data for our legitimate interests as a pharmaceutical company in accordance with our company policies – for example, to communicate with you about our products and services, about scientific research and educational opportunities, scientific research and market research and 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 the legal basis for processing your personal data.

Please note that if you provide your consent, you may also withdraw your consent at any time 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 "Your rights related to your personal data".

Who we share personal data with

We share data with Takeda controlled subsidiaries; with suppliers working on our behalf; when required by law or to respond to legal process, to protect our customers; to protect life; to maintain the security of our Services; and to protect Takeda's rights or property.

In such cases, Takeda will require third parties to protect the confidentiality and security of the personal data shared with them. These third parties will be required to agree that they will not use or disclose personal information 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 information with subsidiaries and third parties as follows:

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

We may also disclose your personal data under 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 part of our business, including in connection with any bankruptcy or similar proceeding. As required by law, including laws outside your country of residence, to comply with a subpoena, mandatory registration or legal process.

We may also disclose aggregated or de-identified information that is not personally identifiable to third parties. Aggregated data is created by collecting and processing information about individuals and summarizing the data, which eliminates the possibility of identifying an individual.

How do we protect your personal data?

We have implemented a variety of security technologies and organizational procedures to protect your personal information 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 that conform to industry standards. However, Takeda cannot guarantee the security of your information. It is also important for you to protect yourself against unauthorized access to your passwords 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 may 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 multinational organization with locations in many countries around the world, your personal data may be stored and processed in all countries where we operate, including where we have facilities or where we engage service providers. Takeda takes measures to process personal data in accordance with the provisions of this notice and the requirements of applicable law.

Takeda may transfer personal data to countries outside your country of residence. The laws of the recipient countries may not provide the same strict protection for personal data as your country of residence. In cases where a lower level of protection is offered by a receiving country, Takeda undertakes to ensure that appropriate safeguards are in place and that applicable laws and regulations are followed in connection with such transfers.

In some cases, Takeda undertakes to enter into agreements (eg European Union Standard Contractual Clauses) or rely on other available data transfer mechanisms that aim to provide adequate protection. A copy of the EU Standard Contractual Clauses can be found at the following http://ec.europa.eu/justice/data-protection/international-transfers/transfer/ .

To obtain additional information about the safeguards that Takeda applies to regulate cross-border transfers of personal data, please contact us using the information in the "How to Contact Us" section.

Storage period

Takeda will only retain your personal data for the minimum period necessary to fulfill the purposes set out 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 information we collect. When you are asked to share your personal data with Takeda, you can decline; However, your choice not to share your personal data with Takeda may mean that you will not be able to use or (fully) benefit from our services, features or offers.

Takeda respects your right, or if permitted by law, your authorized agent, to know and inquire about what personal information we have collected, used or disclosed. In addition, you or your authorized representative have the right to request the correction or deletion of such personal data, as well as to request that your personal data held by third parties with whom we conduct business be deleted. Takeda will not discriminate against you based on your exercise of any of these rights.

For more information about your privacy rights, or if you are unable to resolve a problem directly with us and wish to make a complaint, please contact the relevant data protection authority responsible for ensuring compliance with privacy laws in your country of residence. Persons residing within the EEA can find a list of their local data protection authorities at https://edpb.europa.eu/about-edpb/board/members_en. For more information about other jurisdictions' data protection authorities, please contact us as described in the "How to Contact Us" section below.

If you would like to request Takeda to access, 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 within a reasonable time. We will make a good faith effort to provide you with access to your personal information and to correct any inaccuracies or delete such information at your request unless otherwise required to be retained by law or pursuant to other legally permitted exceptions. If your request is rejected for any reason, we will notify you. Before fulfilling your requests, we may need additional information from you to verify your identity.

Takeda will inform you if it intends to use your information for marketing purposes and to send you marketing communications or if it intends to disclose your information to any third party for such purposes. You have the right to opt out of marketing communications 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. If you wish to exercise this right, please use the 'unsubscribe' function in the relevant communication or see the 'How to contact us' section below.

Children

Takeda treats children's information with extra care to ensure they receive additional protection and security. We may in some cases collect personal information about children with the consent of a parent or guardian for the provision of our services such as clinical operations 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 delete personal data related to your child, please contact us as described in the "How to Contact Us" section below.

Social networks

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

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 party, including third parties that operate any website or service to which our Takeda Service links. The inclusion of a link on the Takeda Service does not imply endorsement by us or our affiliates of the linked site or service.

Please note that we are not responsible for the collection, use and disclosure policies and practices (including data security practices) of organizations other than Takeda, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media provider, operating system provider, wireless service provider or device manufacturer. If you choose to share or disclose your personal information 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 the applicable privacy settings and features 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. You can also request this notice in an alternative format if needed due to a disability. Such questions, comments or requests 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:

If you wish to exercise your individual rights, please contact us by going to our individual rights web form. If you have any questions about this privacy notice, please contact us by email.

Email address: privacyoffice@takeda.com

Additionally, in the US you can contact Takeda at 1-800-676-8975.

Updates to our privacy notice

Takeda may update this notice from time to time. If we make any changes, the updated notice will be published with a revised effective date.