GDPR Privacy Policy
Nippon Shinyaku Co., Ltd. (“Nippon Shinyaku”, “we” or “us”) has established this GDPR privacy policy (the “GDPR Privacy Policy”), and will handle personal data as follows, in recognition of the importance of personal information (“Personal Data”) acquired, retained, and used by Nippon Shinyaku and its affiliates within the EEA (EU Member States, Iceland, Liechtenstein, Norway, and the United Kingdom), and in order to ensure lawful and adequate protection of Personal Data in compliance with the EU General Data Protection Regulations (the “GDPR”) and other applicable laws and regulations.
Please also see the Cookie Policy regarding the use of cookies.
Nippon Shinyaku may update this GDPR Privacy Policy from time to time if there are changes to the handling of Personal Data.
1. Processing of Personal Data
We may acquire and process Personal Data for the purpose of use based on the following legal grounds under the GDPR.
- (1)Personal information of physicians, dentists, pharmacists, and other healthcare professionals (Article 6.1(f) of the GDPR : processing is necessary for the pursuit of our legitimate interests)
- (2)Personal information of users of the Corporate Communications Department, Medical Information Center and other points of contact (Article 6.1(f) of the GDPR : processing is necessary for the pursuit of our legitimate interests)
- (3)Personal information of business partners (individuals and corporate officers/employees) of Nippon Shinyaku (Article 6.1(f) of the GDPR : processing is necessary for the pursuit of our legitimate interests)
- (4)Personal information of users of the mail order service (Article 6.1(b) of the GDPR : processing is necessary for the performance of the contractual obligations and Article (f) of the GDPR : processing is necessary for the pursuit of our legitimate interests)
- (5)Personal information of shareholders (Article 6.1(f) of the GDPR : processing is necessary for the pursuit of our legitimate interests)
- (6)Personal information of applicants for employment (Article 6.1(f) of the GDPR : processing is necessary for the pursuit of our legitimate interests)
- (7)Personal information of officers, employees and former employees (Including Family Members) (Article 6.1(f) of the GDPR : processing is necessary for the pursuit of our legitimate interests)
For details regarding the balancing test for legitimate interests, please inquire using the contact details at the end of this privacy policy.
Please also see the Cookie Policy regarding the legal grounds for use of cookies.
We will acquire sensitive data, such as your religious beliefs and health conditions, with your express consent under Article 9.2(a) of the GDPR, and handle that data in accordance with the special standards stipulated in Article 9 of the GDPR.
Even if you have given consent to the processing of Personal Data to Nippon Shinyaku, you have the right to withdraw that consent at any time. Nippon Shinyaku will notify you of how to withdraw your consent separately when obtaining that consent. However, your withdrawal of consent does not affect the legality of the processing of Personal Data by Nippon Shinyaku prior to that withdrawal.
2. Sources of Personal Data
We will acquire your name, address, phone number, personal e-mail address, information regarding your use of our communications systems, and other Personal Data directly from you.
3. Retention Period of Personal Data
We will retain Personal Data only for the period necessary to achieve the purpose of acquisition and processing. The specific retention period shall be determined in consideration of the purpose of acquiring and processing Personal Data, the nature of the Personal Data, and the necessity of retaining the personal data for legal or business reasons.
4. Sharing and cross-border transfers of Personal Data
We may, in accordance with GDPR, share Personal Data acquired and processed for the purpose of use set forth in this GDPR Privacy Policy with our affiliate (NS Pharma, Inc.) and contractors and other third parties (including, without limitation, CROs, research organizations, IT systems providers, IT contractors, and data analysis providers).
As part of the above sharing, Personal Data may be transferred to third parties outside the EEA.
In this event, the transfer of Personal Data to Japan is subject to the adequacy decision or the standard data protection clauses (Article 46.2(c) and 46.5 of the GDPR) that we have already entered into. For the transfer of Personal Data to a third country other than Japan (excluding countries or regions that have obtained sufficiency certification), appropriate protective measures will be taken by concluding the standard data protection clauses. If you wish to have a copy of the protection documentation, please contact us (contact details are provided below).
5. Rights of the Individual
In accordance with the provisions of the GDPR, a person who is the subject of Personal Data has the following rights with respect to Personal Data that we acquire and process.
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Acquisition of information concerning the processing of Personal Data
The right to obtain from Nippon Shinyaku all required information relating to our Personal Data processing activities relating to the data subject (Article 13 and 14 of the GDPR).
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Access to Personal Data
The right to confirm with Nippon Shinyaku whether Personal Data relating to the data subject has been processed or not, and the right to access such Personal Data and certain information relating thereto (Article 15 of the GDPR).
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Rectification or erasure of Personal Data
The right to request that inaccurate Personal Data relating to the data subject be corrected without delay and the right to make the inaccurate Personal Data complete (Article 16 of the GDPR). The right to request the erasure of Personal Data related to the data subject without delay if certain requirements are met (Article 17 of the GDPR).
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Restrictions on the processing of Personal Data
The right to request restrictions on the processing of Personal Data (Article 18 of the GDPR).
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Objection to the processing of Personal Data
The right to object to the processing of Personal Data relating to the data subject (Article 21 of the GDPR).
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Lodge a complaint with the supervisory authority
The right to lodge a complaint with the supervisory authority of the place of residence or workplace of the data subject, or the place of the alleged infringement, with regard to the processing of the Personal Data of the data subject.
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Data portability of Personal Data
The right to receive Personal Data relating to the data subject in a structured, commonly used and machine-readable format and the right to transfer such data to another administrator without prejudice to Nippon Shinyaku (Article 20 of the GDPR).
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Rights not subject to automated decision-making
Rights not subject to decisions (including profiling) based solely on automated data processing that will have a legal or significant impact on the data subject if certain requirements are met (Article 22 of the GDPR)
If you wish to exercise these rights, please contact us (contact details are provided below).
6. Contact
Please direct any questions or inquiries about this GDPR Privacy Policy to:
Personal Information Helpdesk, Nippon Shinyaku Co., Ltd.
14, Nishinosho-monguchi-cho, Kisshoin, Minami-ku, Kyoto 601-8550, Japan
Tel: +81–75–321–9055
Operating hours: 9:00 a.m. – 12:00 p.m., 1:00 p.m. – 5:00 p.m. (JST)
(Excluding Saturdays, Sundays, Japanese national holidays, New Year holidays, and other holidays designated by Nippon Shinyaku)
Questions and inquiries about this GDPR Privacy Policy can also be made through our contact form.
Please select "Inquiries about Personal Information" as the category of inquiry and enter the details.