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Otsuka Novel Products GmbH
Privacy Notice 25. May 2018
About this notice
This website is operated by Otsuka Novel Products GmbH, Erika-Mann-Str. 21, 80636 Munich, Germany (hereinafter referred to as “ONPG”).
For the purposes of this notice, ONPG will be the controller, meaning ONPG determines how and to what extent your personal data will be processed (the controller is also referred to in this notice as “ONPG”, “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 services to ONPG, or when you simply use our websites and other digital platforms. In all cases, ONPG 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 ONPG’s Data Protection Officer, by writing to the “Legal & Compliance Department” at the address for ONPG provided above, or by emailing firstname.lastname@example.org.
Who are you?
We process personal data for different purposes, depending on who you are. To find out for what specific purposes we process your personal data, you may choose from the below.
Quickly find what you’re looking for by clicking the links below:
1. Our data protection responsibilities
2. What types of personal data do we collect and where do we get it from?
3. What do we do with your personal data, and why?
4. Who do we share your personal data with, and why?
5. Where is your personal data transferred to?
6. How do we keep your personal data secure?
7. How long do we keep your personal data for?
8. What are your privacy rights and how can you exercise them?
ONPG 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.
2.1 The personal information we process about you broadly falls into four main categories: (i) Contact Information; (ii) Agreement Information; (iii) Candidate Information and (iii) Browsing Information.
2.2 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.
2.3 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, Agreement Information or Candidate Information, we will not be able to interact or contract with you.
3.1 We use your personal data for a number of different purposes. We must always have a “lawful basis” (ie a reason, 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.
3.2 Website visitors
3.3 Healthcare professional
3.4 Job applicants
3.5 Website visitors, healthcare professionals and job applicants
3.6 Cookies and similar technologies
In order to improve the appearance of our Website and to allow the use of certain functions, we use “cookies”. Cookies are small text files that are stored on your computer. This data is not used to identify the personally identify the visitors of the Website.
We only use session cookies, which are automatically deleted when closing the browser. This cookie is a security plugin that checks if a visitor is a person and not, a bot or any security threat.
You may of course decline the installation of cookies at any time by selecting the respective settings in your browser, provided your browser allows this; however, please note that in this case you may not be able to use all of the functions of this Website to their full extent.
3.7 Google Maps
Our Website uses Google Maps in order to show the location of ONPG’s registered office as well as how to reach us.
3.8 Google Analytics
We use Google Analytics on the Websites with the extension “anonymizeIP()”, IP addresses being truncated before further processing in order to rule out direct associations to persons.
4.1 Sometimes we share your personal data with third parties, including the following:
4.1.1 other ONPG companies where necessary for the purposes described above.
4.1.2 courts, where we are asked to respond to a court order or other binding requests;
4.1.3 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
4.1.4 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.
4.2 We also ask third party service providers to carry out certain business functions for us. These include:
4.2.1 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;
4.2.2 Service providers assisting us in the organisation of events, arranging travel logistics and bookings;
4.2.3 Third parties assisting on the collection and disclosure of transfer of value information to the public;
4.2.4 Communication service providers, including companies who send out surveys and communications on our behalf; and
4.2.5 survey providers who help collate feedback for us.
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.
5.1 Since ONPG 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:
5.1.1 that country ensures an adequate level of protection for your personal data;
5.1.2 the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data – this includes for example, the EU-US Privacy Shield which enables the secure transfer of personal data to the United States;
5.1.3 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.
5.1.4 the transfer is permitted by applicable laws; or
5.1.5 you explicitly consent to the transfer.
5.2 If you would like to see a copy of any relevant provisions, please contact email@example.com.
6.1 We will put in place appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
6.2 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.
7.1 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:
7.1.1 any laws or regulations that we are required to follow;
7.1.2 whether we are in a legal or other type of dispute with each other or any third party;
7.1.3 the type of information that we hold about you; and
7.1.4 whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
8.1 Where our processing of your personal data is based on your consent (see table at paragraph 3 above), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.
8.2 Where our processing of your personal data is based on the legitimate interests (see table at paragraph 3 above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
8.3 You have the right to (subject to certain limitations):
8.3.1 access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;
8.3.2 require us to correct any inaccuracies in your personal data without undue delay;
8.3.3 require us to erase your personal data;
8.3.4 require us to restrict processing of your personal data;
8.3.5 receive the personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us (see table at paragraph 3 above) and where the processing is automated; and
8.3.6 object to a decision that we make which is based solely on automated processing of your personal data.
8.4 Please contact us at firstname.lastname@example.org if you would like to exercise any of your privacy rights.
8.5 We also encourage you to let us know if you have any concern about how we are processing your personal data so we can try to resolve your concerns. However, if you consider that we are in breach of our obligations under data protection laws, you are always entitled to submit a complaint with the competent supervisory authority.
8.6 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.
Information current as of 26-07-2018