Where you provide us with the Personal Data of other individuals in connection with your services or when you order products from us, you are responsible for ensuring that you have duly informed them of the relevant purposes and Otsuka’s processing of their Personal Data in accordance with this Policy, and obtaining their consent before making such disclosure to us.

Some of the Agreement Information, such as billing and payment information is sensitive Personal Data. We collect this information provided that your consent is obtained and processing of this information strictly in compliance with applicable laws. 

Note that:

• Your Personal Data is required to make the website accessible to you and to be able to follow up on your inquiry.
• If you do not provide your Personal Data, the website will not work, and we may not be able to respond to or properly process your request.
• 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 Browsing Information, we will not be able to interact or contract with you.

Website visitors

• Other Otsuka Group companies where necessary for the purposes described above.
• Alliance partners who co-commercialize our products for the purposes described above.
• Courts, where we are asked to respond to a court order or other binding requests.
• 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
• Professional advisors (such as lawyers and accountants). These organizations may also use your Personal Data as a “controller” – they will have their own privacy policies which you should read, and they have their own responsibilities to comply with applicable data protection laws.

We also ask third party service providers to carry out certain business functions for us. These include:

• 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.
• Service providers assisting us in the organisation of events, arranging travel logistics and bookings.
• Service providers who assist with supply chain logistics, delivery of and payment for products and related queries or complaints.
• Third parties assisting on the collection and disclosure of transfer of value information to the public.
• Communication service providers, including companies who send out surveys and communications on our behalf; and
• 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.
• We may also share your Personal Data with a successor-in-interest (actual or proposed), to continue to perform the functions and activities described above. In the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding)

We do not sell your Personal Data, nor do we share your Personal Data with third parties for their own marketing purposes.

• The recipient or recipient country ensures an adequate level of protection for your Personal Data.
• 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.
• 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.
• The transfer is permitted by applicable laws; or
• You explicitly consent to the transfer.

• Any laws or regulations that we are required to follow;
• Whether we are in a legal or other type of dispute with each other or any third party;
• The type of information that we hold about you; and
• Whether we are asked by you or a regulatory authority to keep your Personal Data for a valid reason.

Where our processing of your Personal Data is based on legitimate interests (see table at section 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.

You have the right to (subject to certain limitations):

• The right to be informed: You have the right to be provided with clear, transparent and easily understandable data about how your data is processed and your rights. This is provided in this Policy.
• The right of consent: You have the right to agree or not allow Otsuka to collect or process your Personal Data.
•  The right of access: You have the right to obtain access to your data, request Otsuka to perform the update, amendment, revision, correction, or cancellation of your data that Otsuka has collected or stored.
• The right to withdraw consent: You have the right to withdraw your consent unless otherwise provided for by law.
• The right to erasure: This right enables you to request the deletion or removal of your information where there is no compelling reason for an organisation to keep using it.

This is not a general right to erasure; there are exceptions. For example, where you have provided consent to processing, this applies only where you have withdrawn your consent, if we are processing in connection with performance of a contract or for compliance with law, this applies only where such data are no longer necessary. 

• The right to restrict processing: You have the right to request to restrict the processing of your Personal Data unless otherwise provided for by law.
• The right to data provision: You have the right to request Otsuka to provide copies of your Personal Data.
• The right to object to data processing: You have the right to object to the processing your Personal Data in order to prevent or restrict the disclosure of Personal Data or the use of it for advertising or marketing purposes unless otherwise provided for by law.
• The right to complain, denounce, initiate lawsuits: You have the right to lodge complaints, denunciations or initiate lawsuits in accordance with law.
• The right to claim damages: You have the right to claim damages in accordance with the law when a violation of the provisions on the protection of Personal Data occurs, unless otherwise agreed by the parties or otherwise provided for by law.
• The right to self-protection: You have the right to self-protection in accordance with the provisions of the Civil Code, other relevant laws, or request competent agencies and organizations to take measures to protect civil rights under the law.

For your protection and to protect the Privacy of others, we may ask you to verify your identity before we execute any requests in relation to the rights detailed above.

Where your Personal Data is processed on the basis of your consent, you have the right to withdraw your consent at any time. If exercised, this will not affect the lawfulness of processing prior to withdrawal.

• Provide full and accurate Personal Data as requested by Otsuka when agreeing to allow Otsuka to process Personal Data;
• Take necessary measures to self-protect your Personal Data. If your Personal Data is revealed because of negligence or any other security fault on the part of yourself, you must take the incurred risks and damages; and
• Comply with regulations on the protection of Personal Data and participate in preventing and combating violations of regulations on the protection of Personal Data.