PRIVACY POLICY

This privacy notice is only for this website and does not affect other Takeda online properties.

Takeda[1] respects the privacy of individuals and complies with all applicable privacy laws including the Personal Information Protection and Electronic Documents Act (PIPEDA) and similar provincial laws.

This Privacy Policy (“Policy”) applies to all healthcare professionals and healthcare organisations (including employees of such organisations) with which Takeda interacts as well as Takeda’s customers, employees of customers and other individuals, from whom or about whom Takeda collects personal information. This Policy describes:

• The types of personal information Takeda may collect about you
• The purposes for which Takeda collects and uses personal information about you
• How Takeda protects your personal information
• The types of third parties with whom Takeda may share your personal information
• How you can make enquiries, request access, or submit complaints with respect to your personal information
• For the purpose of this Policy, “personal information” means all information collected, stored or otherwise handled by Takeda by which an individual can be identified or is identifiable.

Personal Information Takeda Collects

This section explains the types of personal information about you that may be collected by Takeda, and under what circumstances. This personal information may be collected through a number of different channels, such as information that you provide on Takeda website(s), in surveys that you fill in for Takeda, and personal information provided during marketing events.

• Healthcare Professionals Marketing Events: Takeda may conduct various marketing activities, such as seminars. As part of this process, Takeda may collect and retain healthcare professionals’ personal information (such as first name, last name, age, gender, business address, business phone number, business fax, business e-mail address, home address, home phone number, medical specialization, professional qualifications, license number and scientific society membership number).
• Information in order to comply with our regulatory obligations: Takeda is obliged to collect certain information to comply with its regulatory requirements. For example, we may ask you for information if you experience any adverse effects whilst taking any of our products. This information may also be reported to us by third parties, such as healthcare professionals. Please note that if you are a healthcare professional, it is imperative that you obtain appropriate consent from your patients before you provide us with their personal information or sensitive personal information.
• As part of our business relationship with you: If you are a customer, supplier or business partner of Takeda, we will handle your personal information (for example, contact details and records of our interactions with you) for the purposes of maintaining that relationship.
• Websites: In general, you may browse Takeda websites without providing any personal data. Takeda may provide you with opportunities to sign up to receive specific information or services from Takeda. As part of this process, Takeda might ask you to provide personal information about you (such as name, home address, home phone number or personal e-mail address). For example, you may choose to register to receive e-mail updates about a Takeda website, information about a particular health condition, or materials relating to products or services offered by Takeda, and you may provide Takeda with your e-mail address to receive such communications.
• Research & Development Surveys: Surveys and questionnaires may ask for sensitive personal information including health related information which may be used for benchmarking services and for assessing the quality of care. Unless specifically requested in a survey or questionnaire, Takeda advises you not to disclose your personal information (i.e. information by which you could be identified) when filling in these surveys and questionnaires.

Personal Information Obtained From Third Parties

To better understand and address your interests, and to keep the personal information that Takeda has about you accurate, Takeda may correct or add to the personal information that you provide to Takeda with the personal information that Takeda receives from other sources like third parties providing services on behalf of Takeda. If you have a business or professional relationship with Takeda, Takeda may use your personal information, including the personal information Takeda may collect about you from other sources, in order to develop Takeda’s business relationship with you and/or your organization.

How Takeda Uses the Personal Information

Takeda and its service providers may use the personal information about you for the following purposes:

• Provide information and services that you have requested: Takeda may use the personal information about you to provide you information that you may request, e.g. information about a product that Takeda is offering.
• Market Takeda products and services: Takeda may use the personal information about you to provide you with materials about products and services offered by Takeda including new content or services on its websites. Takeda may provide you with these materials by phone, postal mail, facsimile or e-mail, as permitted by applicable law, including Canada’s anti-spam legislation. Takeda does not share any of your personal information with third parties for their own direct marketing purposes without providing you an opportunity to opt-out of such disclosure.
• Research and Development: Takeda may send health questionnaires to patients and healthcare professionals in order to gather information about patients and their family members. Takeda may aggregate this information with information obtained from other sources in order to obtain a summary, that will be used to improve Takeda products and services.
• Customer Servicing: Takeda may use the personal information about you to invite you to events that Takeda feels are relevant for you as a part of customer service efforts.

How Takeda Protects Your Personal Information

Takeda maintains reasonable physical, administrative and technical safeguards to protect the personal information about you from loss, misuse, unauthorized access, disclosure, alteration or destruction.

With Whom Takeda Shares Your Personal Information

Takeda may share the personal information about you with service providers that Takeda has retained to perform services on its behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; and (iii) customer service activities such as inviting you for certain events. Takeda has executed appropriate contracts with the service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on Takeda’s behalf or to comply with applicable legal requirements. Takeda may also send certain types of personal information about you (e.g. demographic information such as name and contact information, products and services provided and health information) to Takeda affiliates, for the purposes described in this Policy. Takeda may also share the personal information about you with other Takeda affiliates, partners, government agencies and regulatory bodies where necessary to fulfil a legitimate business purpose or to comply with applicable legal requirements. Generally, Takeda may disclose the personal data about you (i) if you request or authorize such a request; (ii) to protect your or Takeda’s legal interest; (iii) to defend against potential or actual litigation; (iv) to abide by law, regulation or contract; (v) to respond to a court order, administrative process or judicial process, including, but not limited to, a subpoena or a search warrant; (vi) to respond to an emergency that is believed to threaten risk of harm to the individual or property; (vii) when disclosure is otherwise a necessary and legitimate consequence of your relationship with Takeda; (viii) for national security matters; (ix) for the performance of a task in the public interest; and (x) when disclosure is in accordance with applicable laws and regulations. Takeda’s affiliates and service providers may be located in jurisdictions outside of Canada, in which case your personal information may be accessible to law enforcement or other authorities in those foreign jurisdictions.

Takeda reserves the right to share the personal information that it has collected in the event it sells, licenses or transfers all or a portion of its business or assets. Should such a sale, lease (licensing) or transfer occur, Takeda will make reasonable efforts to direct the transferee to use personal information about you in a manner that is consistent with this Policy.

Automatically Collected Information – Cookies & Other Website Information

As with other commercial websites, Takeda’s website(s) uses standard "cookie" and "web beacon" technology and web server logs to collect information about how the website is being used. Takeda websites uses Google Analytics to help analyze how visitors use our sites. Google Analytics uses "cookies", which are small text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form. The anonymous information generated by Google Analytics cookies about your use of the websites (including your IP address) is transmitted to Google and processed to compile aggregated statistical reports that are used by Takeda to optimize website content.

Web beacons are transparent pixel images that are used in collecting information about website visitor activities and e-mail response and tracking. For example, if Takeda sends you an e-mail message, Takeda (or third parties providing services on its behalf) may collect information through web beacons to determine whether you have opened the e-mail message or clicked on links located within the e-mail message.

Information gathered through cookies and from web server logs may include your IP address, your Internet web browser name, your operating system name, the domain name of your internet service provider, the date and time of your visits, the pages viewed, the time spent at Takeda website(s), and the websites visited just before and just after Takeda website(s). This information may be associated with the personal information about you, if you choose to provide personal information to us.

Consent to the use of cookies

By using Takeda website(s), you consent to Takeda storing information on your hard drive through Cookies or similar technologies.

Opting Out of Cookies

You may refuse to accept cookies by altering the settings on your internet browser to refuse all cookies (and delete all existing cookies) or to indicate when a cookie is being sent. For further information about how to do so, please refer to your browser ‘help’ section or see www.allaboutcookies.org. Please note that some portions of Takeda website(s) may not work properly, if you refuse cookies.

Your Consent

Takeda will always seek to obtain your consent where required by the applicable law. For example, Takeda will seek to obtain your explicit consent for (i) processing sensitive personal information in any form (ii) for using your personal data for any purposes other than those explained in this Policy, where required by law. In all other circumstances, by providing your personal information to Takeda, you consent to the use and disclosure of your personal information for the purposes described in this Policy.

You have the ability to withdraw your consent for Takeda to collect and process your personal information at any time by contacting Takeda as outlined in the Enquiries and Complaints section below.

Enquiries and Complaints

You may request access to the personal information that Takeda has about you. Takeda also offers you the opportunity to edit and update certain personal information which you have provided. If you require a copy of your personal information, or if you would like to update or correct it, or if you have any inquiries or would like to submit written complaints about Takeda privacy practices, please send a written request including your name, and contact information (e.g. telephone, email address, mailing address) to us at.

Takeda Canada Inc.

Attn: Compliance and Privacy Officer

Mailing Address: Bay Adelaide Centre, 22 Adelaide Street West, Suite 3800,

Toronto, ON M5H 4E3

Email Address: cco.smbx.ca-CanadaCompliance@takeda.com

Complaints about Takeda’s handling of your personal information may also be made to the appropriate Privacy Commissioner:

• Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca/index_e.asp
• Office of the Information and Privacy Commissioner (Alberta): https://www.oipc.ab.ca/
• Office of the Information and Privacy Commissioner (British Columbia): https://www.oipc.bc.ca/
• Commission d’accès à l’information du Québec: http://www.cai.gouv.qc.ca/english/

Effective Date

This Privacy Policy is effective from December 1, 2014.

[1] “Takeda means the Takeda affiliate identified at the end of this Policy or other Takeda entity that controls, is controlled by or is under common control with the Takeda affiliate identified below.”