Last updated: December 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.

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. Takeda does not sell your personal data.

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 employment 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.

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.

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 the right of you, or where permitted by law, your authorized agent to know and inquire about what personal data about you we have collected, used or disclosed. In addition, you or your authorized agent 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. 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 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 may find a list of their local data protection authorities at https://edpb.europa.eu/about-edpb/board/members_en. For further details on other jurisdictions’ data protection authorities, please contact us as described in 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.

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.

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.

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.

How to Contact Us

Takeda welcomes any questions or comments you may have regarding this Notice or its implementation. You may also request this Notice in an alternative format if necessary due to a disability. Any 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:

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

Additionally, In the United States, you may contact Takeda at 1-800-676-8975.

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.