About this notice 

This website is operated by Otsuka Pharmaceutical Vietnam JSC (OPV) at address Lot 512, No. 13 Street, Amata Industrial Zone, Long Binh Ward, Bien Hoa City, Dong Nai Province.  For the purposes of this notice, OPV will be the controller, meaning OPV determines how and to what extent your personal information will be processed (the controller is also referred to in this notice as “Otsuka”, “OPV”, “we”, “our” and “us”).

This notice explains how and why we use your personal information, for example: when we provide you with information you have requested from us, where you have provided information to us pursuant to any agreement, or when you simply use our websites and other digital platforms.

In all cases, OPV understands and respects your privacy. In this notice, when we talk about personal information, we mean any information or piece of information which could identify you either directly (e.g., your name) or indirectly (e.g., a government issued identifier)

You should read this notice, so you know what personal information 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 may apply to our use of your personal information in specific circumstances from time to time. If you have any questions about this notice, you can contact us by submitting your query here: support@otsukavn.com.vn

In summary…

• We use your personal information pursuant to any agreement between you and us, when you use our websites and other digital platforms, to provide you with information, where you have requested them, manage our business, recruit new staff, comply with our legal obligations, and improve and monitor the performance of our digital platforms.
• We have measures in place to safeguard your personal information when we transfer it outside of Vietnam.
• We take steps to minimize the amount of personal information we hold about you and to keep it secure
• We delete your personal information when we no longer need it, and we have policies in place to govern when that is
• You have rights in relation to your personal information
• We are happy to answer your questions about any of the above – please submit your query here: support@otsukavn.com.vn

1. Our data protection responsibilities 

OPV is a controller, in relation to its use of your personal information. This is a legal term – it means that we make decisions about how and why we use your personal information, 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. What types of personal information do we collect and where do we get it from?

The personal information we process about you broadly falls into four main categories: (i) Contact Information; (ii) Agreement Information; (iii) Candidate Information and (iv) Browsing Information.

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:

Category	Type of personal information	Collected from
Contact Information	Information such as: Name; address; telephone number, email address; organization details (e.g., your place of work, practice, professional area, job title) etc.	You, Third Parties
Agreement Information	Contact Information (see above) Details relating to the services you provide to us, including service-related communications with you Information about other people (e.g., your customers and/or staff) that you share with us in connection with your services or when you order products from us Information you provide us when you interact with Otsuka (e.g., for a product order, conference, patient cohort) Billing and payment information	You
Browsing Information	Browsing and search history Referring web site addresses Device characteristics Site preferences	You when you visit our website
Candidate Information	Contact Information (see above) Details you include in your application, e.g., CV, references, certificates	You, Third Parties

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. What do we do with your personal information, and why? 

We use your personal information for a number of different purposes: we have a “lawful basis” (i.e., a reason or justification, prescribed by law) for processing your personal information.

The table below sets out the purposes for which we process the different categories of your personal information 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.

Website visitors 

Category of information	Purposes of processing	Lawful basis
Contact Information	Responding to your enquiries	To perform a contract with you or you have provided your consent. Legitimate interests (so that we can respond to your enquiries)
Browsing Information	Monitoring and producing statistical information regarding the use of our platforms, and analysing and improving their functionality	Legitimate interests (We need to perform limited routine monitoring to make sure our platforms work properly)
Agreement Information	Keeping accurate records of Otsuka’s communications with you. In addition, we may need the information you provide to comply with our regulatory monitoring and reporting obligations.   Disclosure of payments according to regulatory requirements   Understanding of how our products impact you, to track and respond to safety concerns and to further develop and improve our products and services.   Compliance with our legal obligations where data related to safety or pharmacovigilance is concerned, including those related to adverse events, product complaints and patient safety.	To perform a contract with you, to comply with a legal obligation, legitimate interests (to ensure transparency) or you have provided your consent.
All information	Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity.   Complying with instructions from law enforcement agencies, any court or otherwise as required by law, resolving any complaints from or disputes with you.	To comply with a legal obligation

Job applicants  

Category of information	Purposes of processing	Lawful basis
Candidate Information	Processing of this personal information is required to enable Otsuka to administer the recruiting process, including the set-up of an electronic job applicant HR file, managing your application, organizing interviews – in short, the processing is necessary for us to enter into a contract with you.	To perform a contract with you
Candidate Information	We may also share your personal information with other Otsuka group companies to consider you for future job openings and will retain your data for a limited period of time beyond an unsuccessful application for this purpose.	Legitimate interests (It is our interest to consider you for other vacancies, now and in the future)

For an understanding of our processing activities related to Healthcare Professionals, please review the Healthcare Professional Privacy OPV_HCPs_Privacy Notice_2023 (attach on website)

4. Who do we share your personal information with, and why? 

Sometimes we share your personal information with third parties, including the following:

• other Otsuka 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 information 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.

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 information and impose appropriate security standards on them.

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

5. Where is your personal information transferred to? Since Otsuka is part of a global company, we will sometimes need to transfer your personal information outside of Vietnam, in particular to the US and our headquarters in Japan. We will only make that transfer if:

• the recipient or recipient country ensures an adequate level of protection for your personal information.
• 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 information.
• we have put in place appropriate safeguards to protect your personal information, such as a contract with the person or entity receiving your personal information which incorporates specific provisions.
• the transfer is permitted by applicable laws; or
• you explicitly consent to the transfer.

6. How do we keep your personal information secure? 

We will put in place appropriate security measures to protect your personal information from unlawful or unauthorized processing and accidental loss, destruction, or damage.

However please note that, in relation to any personal information 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. How long do we keep your personal information for? 

We will only retain your personal information 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:

• 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 information for a valid reason.

8. What are your privacy rights and how can you exercise them? 

Where our processing of your personal information 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 information for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.

Where our processing of your personal information is based on 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.

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

• access your personal information 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.
• require us to correct any inaccuracies in your personal information without undue delay.
• require us to erase your personal information.
• require us to restrict processing of your personal information.
• receive the personal information 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
• object to a decision that we make which is based solely on automated processing of your personal information.

Contact us here: support@otsukavn.com.vn if you would like to exercise any of your privacy rights.

We also encourage you to let us know if you have any concern about how we are processing your personal information 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.

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 taking effect. We encourage you to review the content of this notice regularly.