Daiichi Sankyo Privacy Notice

1. About this notice

The Company processes personal data in compliance with applicable laws and any future laws that may replace them.

The Company provides you with information based on data protection laws. This notice sets out the basis on which any personal data that you provide to the Company, or that the Company obtains about you from other sources, will be processed by the Company. Please take the time to read and fully understand this notice.

2. How the Company collects your personal data

The Company may collect information that you provide to the Company, whether by means of a form on the Company’s website, by email, in a letter, or otherwise, such as your name, address, telephone number, gender, date of birth, e-mail address, and other information necessary to achieve the purposes of use described in Section 3 below.

The Company may also be provided with your name, address, telephone number, gender, date of birth, e-mail address, and other information from contractors and medical professionals.

When you visit the Company’s website, the Company may automatically collect cookies on your terminal device. For more information on the Company’s use of cookies and how to opt out of cookie collection, please see the Company’s Cookie Policy（refer to Cookie Policy）.

For more information on the handling of anonymously processed information under Japanese law, please click here (refer to “Information Items of Anonymously Processed Information, Etc.).

3. Purposes of use of personal data, Etc.

(1) Purposes of use of personal data

The Company uses the personal data that it holds about you for the following purposes, and only to the extent necessary to fulfil such purposes:

(A) Purposes of use of personal information concerning the Company’s shareholders

To exercise rights and perform obligations under the Companies Act;
To provide various facilities to them in their capacity as shareholders;
To implement various measures to facilitate delivery of documents, in light of a relationship between an association and its members;
To manage shareholders, including preparing shareholders’ data based on the standards prescribed by applicable laws and regulations; and
To contact and respond to persons who made inquiries.

※ Please note that the Company makes it a rule to record telephone conversations regarding consultations and inquiries over the phone dedicated to shareholders and investors, in order to accurately understand the details thereof.

(B) Purposes of use of personal information of persons whose personal information was acquired by the Company through IR activities

To provide them with information necessary for investment decisions in a timely, fair and continuous manner; and
To contact and respond to persons who made inquiries.

To provide, collect and consider information regarding the proper use of pharmaceuticals, etc.;
To understand the users and purchasers of pharmaceuticals, etc.;
To request, conduct and support clinical tests, post-marketing research, or clinical research;
To provide, collect and consider information in the medical and pharmaceutical fields;
To conduct survey activities and research in the medical and pharmaceutical fields;
To notify relevant government agencies pursuant to the Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices and other relevant laws and regulations;
To verify medical personnel when they access the Company’s medical personnel-only website;
To confirm how medical personnel are accessing the Company’s medical personnel-only website, and send e-mail newsletters;
To contact persons who made inquires about the Company’s products;
To provide congratulatory and condolence greetings, and season’s greetings; and
To conduct business communication with and respond to medical personnel.

※ Please note that the Company makes it a rule to record telephone conversations regarding consultations and inquiries made to the Product Information Center of the Company, in order to accurately understand the details thereof.

(D) Purposes of use of personal information concerning customers, consumers, and patients

To contact and respond to persons who consulted regarding pharmaceuticals, etc.;
To address and investigate side effects of pharmaceuticals, etc.;
To provide information regarding pharmaceuticals, etc., and after-sales service;
To contact holders of marketing authorization for, manufacturers and sellers of, pharmaceuticals, etc., and medical personnel, etc.;
To confirm how they are accessing the Company’s medical personnel-only website, and send e-mail newsletters;
To notify relevant government agencies pursuant to laws and regulations;
To manage entry to and exit from the Company’s facilities;
To smoothly perform operations in the Company Group’s business; and
To provide congratulatory and condolence greetings, and season’s greeting.

(E) Purposes of use of personal information concerning persons belonging to wholesalers in the Company’s business domains

To conduct business communication with and respond to them;
To understand the users and purchasers of pharmaceuticals, etc.;
To collect and consider information in the medical and pharmaceutical fields;
To request and conduct sales promotion activities, including questionnaires; and
To provide congratulatory and condolence greetings, and season’s greeting.

(F) Purposes of use of personal information concerning persons who applied for internships at and employment with the Company

To conduct internships, screen for employment, contact applicants regarding the screening process for employment, and manage personnel and labor after hiring decisions have been made (for those who have been hired, including personnel and internal training in the Company).

(G) Purposes of use of personal information concerning users of the contact point for inquiries about the Company

To contact and respond to persons who made inquiries about the Company; and
To maintain and manage the Company’s website; perform statistical analysis how the website is used to provide better services.

(H) Purposes of use of personal information concerning experts and qualified persons in each area

To select persons from whom the Company seeks legal and IP expert services;
To select persons from whom the Company seeks medical, pharmaceutical, chemical, food, and health administration expert services;
To select persons from whom the Company seeks accounting and tax expert services;
To select persons from whom the Company seeks business management expert services; and
To provide congratulatory and condolence greetings, and season’s greeting.

(I) Purposes of use of personal information concerning persons who belong to counterparties or potential counterparties to contracts to be executed by the Company

To smoothly perform operations between them and the Company;
To contact counterparties to contracts; and
To provide congratulatory and condolence greetings, and season’s greeting.

(J) Purposes of use of personal information concerning persons who belong to the Company

To manage them, including their scheduling, remuneration payments, personal identification verification, welfare, and safety and health;
To contact health insurance societies, officers’ shareholding associations, life insurance and non-life insurance companies (those companies for which the Company intermediates only), the Company Group companies, relevant organizations and affiliate companies;
To notify and report to government and municipal offices;
To smoothly perform operations in the Company business; and
To operate intracompany club activities and social gathering bodies.

To manage them, including their attendance, salary and benefit payments, personal identification verification, human resources (including secondment and employment transfers), evaluation, potential development, welfare, and safety management;
To contact workers’ unions, health insurance societies, shareholding associations, life insurance and non-life insurance companies (those companies for which the Company intermediates only), the Company Group companies, relevant organizations and affiliate companies;
To notify and report to government and municipal offices;
To smoothly perform operations in the Company business;
To operate intracompany club activities and social gathering bodies;
To support the provision of information on the proper use of pharmaceuticals, etc.;
To support the development of pharmaceuticals, etc.; and
To support post-marketing research of pharmaceuticals, etc.

To contact them in case of emergency;
To calculate and pay salaries and benefits to employees; and
To manage their welfare and pensions.

To take procedures and contact them after their retirement; and
To operate the retiree association and manage its members.

(K) Purposes of use of personal information to be acquired in connection with the Company’s research activities

To utilize base sequences (which are deemed to be an individual identification code) obtained from commercially available human-derived cultivated cell lines and human-derived cell lines, or human-derived specimens of a subject collected through clinical tests, and information associated with a disease, for drug discovery research or academic research; and
To utilize base sequences (which are deemed to be an individual identification code) obtained from human-derived specimens to be acquired from a joint research institute, and information associated with a disease, for drug discovery research or academic research.

(L) Purposes of use of personal information to be acquired in connection with the Company’s development activities

To utilize base sequences (which are deemed to be an individual identification code) obtained from human-derived specimens of a subject collected through clinical tests, and information associated with a disease, for analysis and evaluation for appropriate drug discovery, proper use, and for academic research.

(2) Purposes of use of specific personal information, etc.

The Company shall use specific personal information, etc. retained by it for the following purposes.

Purposes of use of specific personal information, etc. concerning the Company’s employees and their family members, retirees, and business partners

To do office work to prepare statements prescribed by law;
To do office work related to withholding tax;
To do office work related to special collection of local tax;
To do office work related to applications for health insurance and employees’ pension insurance;
To do office work related to employment insurance; and
To do office work related to pensions.

4. Disclosure and joint use of personal data

4-1. Disclosure of personal data

The Company may disclose your personal data to the following categories of recipients.

(1) Affiliates: The Company may disclose your personal data to companies belonging to the Daiichi Sankyo Group and to organizations related to the Daiichi Sankyo Group.

(2) The Company’s employees: The Company may disclose your personal data to the Company’s employees who are authorized and who have a need to access such data.

(3) Medical institutions and healthcare professionals, pharmaceutical companies, wholesalers, and research, survey, and evaluation organizations: The Company may disclose your personal data to these parties.

(4) Service providers: The Company may disclose your personal data to third-party service providers that perform certain services, such as IT service providers (including data server and cloud service providers) and legal advisors.

4-2. Joint use of personal data

In accordance with Japanese law, the Company may share personal data pursuant to the framework of data sharing under the Act on Protection of Personal Information, the details of which are as follows. The Company will not jointly use specific personal information, etc. except in cases where joint use of specific personal information, etc. is permitted by laws and regulations.

(1) Personal data of persons belonging to the Company

Entity with which personal data is shared	Companies belonging to the Daiichi Sankyo Group Organizations related to the Daiichi Sankyo Group (at present, including the following organizations): Public Interest Incorporated Foundation Daiichi Sankyo Foundation of Life Science; Public Interest Incorporated Foundation Japan Research Foundation for Clinical Pharmacology; and Public Interest Incorporated Foundation Manpei Suzuki International Prize for Diabetes Research.
Purposes of joint use	Communication between persons in charge of the relevant business
Personal data to be jointly used	Name, company and department to which the person belongs, title, email address and telephone number
Party responsible for management of personal data	Daiichi Sankyo Company, Limited For the address, the name of the representative and other information on the Company, see Section 8 below.

(2) Personal data of the Company employees and their family members

Entity with which personal data is shared	Companies belonging to the Daiichi Sankyo Group
Purposes of joint use	To plan and manage the human resources of the Daiichi Sankyo Group; To formulate and implement personnel systems for the Daiichi Sankyo Group; To formulate and implement human resource development measures for the Daiichi Sankyo Group; To manage the disciplinary rules of the Daiichi Sankyo Group; To research the Daiichi Sankyo Group’s working conditions and consider their revisions; and To implement the industrial safety and health management of the Daiichi Sankyo Group.
Personal data to be jointly used	Name, date of joining the Company, gender, date of birth, department, title, place of residence, commuting route, personal history, qualifications and licenses, employee evaluation, commendations, salaries and bonuses, skills development, health check results, insurance status, information on family members (name, gender, date of birth, relationship, and whether cohabiting or working), and other data required to attain any of the above purposes of use.
Party responsible for management of personal data	Daiichi Sankyo Company, Limited For the address, the name of the representative and other information on the Company, see Section 8 below.

(3) Personal data of the Company employees and their family members

Entity with which personal data is shared	Daiichi-Sankyo Workers’ Union Federation of Daiichi-Sankyo Workers’ Union
Purposes of joint use	For the Company to provide a series of internal communications, notices, notifications to the principal, notify the principal of the joint users’ policies, report on workers’ union consultations (negotiations), inform the principal of events, among other purposes; To create basic data for workers’ union consultations (negotiations) with joint users regarding the principal’s wages and working conditions; To respond smoothly and appropriately to disasters and emergencies involving the Company or the principal (including mental or physical health issues) in cooperation with joint users; and To implement the practical welfare operations supervised by joint users.
Personal data to be jointly used	Information on the principal Name, gender, date of birth, date of joining the Company, years of service, academic background, employee number, department and place of work, employee category, grade/position level, job group, email address, work cellular phone number, address/residence category, phone number, emergency contact, secondment destination, commendations/disciplinary action, salary information (such as items and amount), attendance, form of job transfer, and retirement allowances Information on the principal’s family members (family members mean the principal’s spouse, children, parents, siblings, and other persons analogous to the foregoing) Name, gender, date of birth, and relationship with the principal
Party responsible for management of personal data	Daiichi Sankyo Company, Limited For the address, the name of the representative and other information on the Company, see Section 8 below.

(4) Personal data of persons belonging to the Company (including retirees from the Company) and their family members

Entity with which personal data is shared	Daiichi-Sankyo Group Health Insurance Society, Daiichi-Sankyo Group Corporate Pension Fund, Daiichi-Sankyo Group Employee Shareholding Association, Daiichi-Sankyo Group Mutual Aid Association, Daiichi-Sankyo Retiree Association, and other organizations related to the Daiichi Sankyo Group
Purposes of joint use	To attain the joint users’ business purposes
Personal data to be jointly used	Name, company and department to which the person belongs, title, email address, data required to attain the joint users’ business purposes, and data required to send materials to the principal
Party responsible for management of personal data	Daiichi Sankyo Company, Limited For the address, the name of the representative and other information on the Company, see Section 8 below.

(5) Personal data of doctors, dentists, pharmacists, and other medical personnel

The details are shown in the website below:
https://www.ultmarc.co.jp/privacy/shared_use/index.html.

Entity with which personal data is shared	Holders of marketing authorization for pharmaceuticals (manufacturers of pharmaceuticals); Holders of marketing authorization for quasi-pharmaceutical products and cosmetics; Pharmaceuticals and cosmetics wholesalers (wholesalers of pharmaceuticals); Holders of marketing authorization for medical appliances and instruments, and medical supplies (manufacturers of medical devices); Medical appliance and instrument wholesalers (wholesalers of medical devices); Medical inspection agencies (inspection centers); Publishers and newspaper publishers (healthcare-related media); Investigation service providers (healthcare-related investigation companies); Information service providers (health counseling companies); Medical food service providers; Contract sales organizations (CSOs); Contract research organizations (CROs); Site management organizations (SMOs); Insurance companies (non-life and life insurance companies); Leasing companies (medical leasing companies); Software companies (medical system development companies); Internet service providers (healthcare-related Internet website operators); and Administration bodies and healthcare-related organizations.
Purposes of joint use	To provide emergency safety information, and information such as revised package inserts; To provide, collect and review information regarding the proper use of pharmaceutical products, medical devices and other items; To understand the users of pharmaceutical products, medical devices and other items, and establish a contact network with the users; To provide, collect and review medical/academic information in the medical and pharmaceutical areas; To provide, collect and review information to assist with the commencement of practice and business management; To provide, collect and review information to assist with the introduction of information technology to handle medical information; To survey the actual use of pharmaceutical products, medical devices and other items, users’ needs, and other matters; To assist in epidemiological investigations and research in medical and pharmaceutical areas; To certify and manage facilities, doctors, dentists and pharmacists for health consultation; and To certify and manage Internet website members for doctors, dentists and pharmacists.
Personal data to be jointly used	The details are shown in the website below: https://www.ultmarc.co.jp/privacy/shared_use/index.html. Name, gender, and the name, address and phone number of the facility the principal serves, clinical department, department/section to which the principal belongs, title, position, graduation year, name of the school last graduated from, date of birth, prefectural origin, the year when the principal passed the national examination for medical practitioners, distinction between a private-practice doctor and a hospital doctor, year when the principal commenced practice/joined a medical association, membership in medical/dental association.
Party responsible for management of personal data	Nihon Ultmarc Inc. For the address and the name of the representative of Nihon Ultmarc Inc., see the website below: https://www.ultmarc.co.jp/privacy/shared_use/index.html.

5. Storage period of personal data

The Company will retain the personal data that it collects for the period necessary for the processing of such personal data, not exceeding seven (7) years after termination of the business relationship, except to the extent that the Company is required by law to retain it for a longer period of time, in which case, the Company will retain it for the period required by law.

6. Your rights

You have a number of legal rights in relation to the personal data that the Company holds about you. These rights may vary depending on where you are located and which data protection laws apply to the relationship between you and the Company, but will typically include the following:

(1) the right to obtain information regarding the processing of the relevant personal data and to access the relevant personal data that the Company holds;
(2) the right to request rectification of the relevant personal data if it is inaccurate or incomplete;
(3) the right to request erasure of the relevant personal data in certain circumstances;
(4) the right to request that the Company restrict its processing of the relevant personal data in certain circumstances;
(5) the right to object to the Company’s processing of the relevant personal data;
(6) the right to receive the relevant personal data in a structured, commonly used, and machine-readable format and/or to request that the Company transmits such personal data to a recipient where this is technically feasible (the so-called “right to data portability”); and
(7) the right to withdraw your consent to the Company’s processing of the relevant personal data at any time.

You may exercise any of your rights by contacting the Company using the information about the Company indicated in Section 8 below. You may also lodge a complaint with the competent data protection authority if you believe that any of your rights have been infringed by the Company.

For other methods of exercising rights recognized in relation to Japanese law, please click here (refer to Procedure for Responding to a Demand, etc. for Disclosure, etc.). For information on how to exercise rights recognized in relation to the laws and regulations of countries other than Japan, please contact the Company using the information about the Company indicated in Section 8 below.

7. Security control measures

The Company shall make efforts to keep the content of personal data and specific personal information, etc. accurate and up to date, and take organizational, personal, physical, and technical safety control measures to prevent the leakage, loss, or damage of personal information and for security control, such as establishing rules for the processing of personal information, regular self-inspection of the processing of personal information, regular training of employees in the processing of personal information, prevention of theft or loss of equipment processing personal information, restricting the means by which personal information can be removed from Company premises, appropriately destroying devices on which personal information is recorded, implementing access controls, preventing unauthorized access from outside the Company, and protection from malware. Furthermore, when handling personal information in a foreign country, the Company shall take the appropriate security control measures by understanding the system of protecting personal information in such foreign country.

8. Information about the Company

If you have any questions about this notice, your rights, or any other matter relating to the protection of your personal data, please contact the Company using the contact information below.

(1) Main office address: 3-5-1 Nihonbashi Honcho, Chuo-ku, Tokyo, Japan
(2) Name of representative: Sunao Manabe
(3) E-mail address: privacy-t@daiichisankyo.co.jp
(4) Phone number: 03-6225-1428 Japan

(Reception hours: 9 am to 5 pm, excluding Saturdays, Sundays, public holidays, and other designated holidays)

For contact information for the accredited personal information protection organization to which the Company belongs under Japanese law, please click here (refer to Accredited Personal Information Protection Organization to which the Company Belongs).

9. Revision of this notice

Any changes to this notice will be promptly announced on the Company’s website.

For residents in the EEA and the UK