Kyowa Kirin Privacy Policy
Last Updated: February 4, 2024
Privacy Statement
How We Collect Personal Information
How We Use Your Information
How We Share Your Information
Your Privacy Choices and Rights
Other Aspects of Our Privacy Practices
Supplemental U.S. State Privacy Notices
Supplemental Privacy Notice for U.S. Healthcare Professionals
Supplemental Privacy Notice for Residents of the European Economic Area, Switzerland and the UK
Privacy Statement
Kyowa Kirin is committed to respecting your privacy, and wants you to know how we collect, use and disclose personal information. We are the North American-based affiliated companies of Kyowa Kirin Co. Ltd., a global specialty pharmaceutical company. This Privacy Policy applies to personal information that we collect through online and digital service activities, including this website (the “Site”), our other U.S. websites, mobile applications (“Apps”), social media forums, and other digital services in which this Privacy Policy is posted or linked (collectively, the “Services”). For certain activity, such as clinical trials, we may process personal information of individuals outside of the U.S.
This Privacy Policy provides you with meaningful insight into our practices with respect to your personal information.
We urge you to read this Privacy Policy and the Terms of Use before using the Services or submitting any information to us. By providing personal information to us or by using the Services, you acknowledge that you understand the terms of this Privacy Policy.
With limited exception for certain research activity, this Privacy Policy is intended for use by residents of the United States only. For residents of certain U.S. states, including California, Colorado, Connecticut, Nevada, Texas, Utah, or Virginia, please scroll down to view our Supplemental U.S. State Privacy Notices. If you are a healthcare professional, scroll down to view the Supplemental Privacy Notice for U.S. HCPs. For residents of the European Economic Area, Switzerland and the UK, scroll down to view the Supplemental Privacy Notice for these jurisdictions.
How We Collect Personal Information
Information We Collect
Information You Provide: We collect personal information that you voluntarily provide when you use the Services, such as when you register for a program, participate in a survey, provide a testimonial, order a product, participate in an interactive feature or forum (such as chat features), or contact us with a question. Depending on the particular Service, we may ask you to provide your name, address, age, birth date, gender, email address, phone number, photo, zip code, education, professional experience, demographic information, or information about your health or medical condition. When we collect information from you, our goal is to let you know how we will use your information, and how you may contact us to tell us that you do not want us to use the information to contact you any longer beyond fulfilling your requests. You will be informed what information is required and what is optional. If you choose not to provide the required information, you may not be able to participate in the activity that requires the information.
Information We Receive From Third Parties: From time to time, in accordance with applicable law, we may supplement the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information, joint marketing partners, social media platforms, people with whom you are connected on social media platforms, and other third parties. Information we collect could include such things as products and services purchased, obtained, or considered; professional or employment-related information; education information; Internet or other electronic network activity information including interactions with a website, app, or ad; or your preferences and behaviors relating to health care. We may obtain this information in order to verify your contact information, identity, professional credentials, specialty, and/or to provide you with more tailored information about our products and services.
Interactive Tools You Use: We may provide interactive tools, including third-party tools, on our websites that allow you to share information with others, such as posts on social media sites or send-to-a-friend emails for the purpose of sending informational and educational materials about Kyowa Kirin or our products or services. To enable information sharing, we may collect personal information. In some instances, you may also be asked to provide information about another person, such as name and email address, in addition to your own personal information so the content may be shared. We will use this information to fulfill your delivery request. We do not view or store this information for any purpose other than to process your request and to comply with regulatory or legal requirements. Be sure to review the legal notice and privacy policy of third parties who provide interactive tools, such as social media sites, because the policies of those sites may be different from those of our website.
If you submit personal information relating to other people to us in connection with the Services, you represent that you have the authority to do so, and to permit us to use the information in accordance with this Privacy Policy.
Information Collected Automatically: We and our service providers may collect basic information about you and your surfing habits automatically through browser navigational tools, cookies, pixel tags and other similar technologies. This includes information about your operating system, your IP address, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the website. Below are descriptions of the online tools we may use to collect this usage information:
Browser Navigational Tools: Certain information is collected by most browsers, such as your computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device. We use this information to ensure that the Service functions properly.
IP Address: Your IP address is a number that is automatically assigned to your computer or device by your Internet Service Provider. An IP address is identified and logged automatically in our server log files whenever a user visits the Service, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many online services. We use IP addresses for purposes such as calculating Service usage levels, diagnosing server problems, and administering the Service in an optimal format. We may also derive your approximate location from your IP address.
Device Information: We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.
Pixel Tags and similar technologies. We may also use pixel tags (also known as web beacons, clear GIFs) or similar technologies (collectively, “Pixel Tags”) in connection with some website pages and HTML-formatted email messages to, among other things: track the online activity of users of the Services and our email recipients (including activity on other websites); determine the success of marketing campaigns; and compile aggregate statistics about site usage of the Services and response rates.
Cookies. Cookies are small bits of information that a website sends to your web browser that helps the site remember information about you and your preferences across multiple visits. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. If you do not disable Cookies and continue to use our Service, we will infer your consent to their use.
We treat information we collect through these technologies as personal information when it enables us to identify you, including when we associate that information with other personal information that you provide to us or that we have otherwise collected about you.
How We Use Your Information
In addition to the uses listed above, we may use your personal information for the following purposes:
- Fulfilling and Responding to Requests. We may communicate with you to process, complete and fulfill your requested transactions, or provide our products and services. We may also personalize and customize this Site and other social media platforms with references to products and/or services that we believe may be of interest to you.
- Responding to your Inquiries. We may provide customer service, respond to your questions about applications, clinical trials and other services, verify information provided to us, and determine eligibility for our products, services and programs.
- Connecting You With Third Parties. We may provide functionality on the Site that will connect you or allow you to forward and share certain content with another person or organization through the Services. In addition, we may offer access to third-party sharing functionality, such as third-party social media widgets/tools/buttons.
- Marketing and Corporate Communications. We may use information that you or third parties provide to inform you of products, programs, services, surveys, promotions, or other interactive features, such as chat features, that we believe may be of interest to you. We may also provide you with newsletters, articles, alerts, announcements, invitations, and other information about products, brands, health topics and disease states. You may opt out of receiving such communications, as described in the “Your Privacy Choices and Rights” section below.
- Administrative Communications. We may send you important information, such as changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt out of receiving such communications.
- Online Services. We collect and use information about how you and other users interact with our online services through our websites, apps, and online tools such as Google Analytics. We use this information in order to compile statistics for analysis of our Services and our business and to make decisions to optimize the experiences we deliver through digital and online channels.
- Research. We may use the information we collect from you to better understand our audiences, evaluate user interest in the Services, improve the Services, and perform other market research activities, as well as conduct surveys, identify and recruit individuals to participate in our research programs, interview individuals relating to our research, conduct clinical trials, create directories and compile databases of contact information. When required by law, we will use anonymized or de-identified information for these purposes.
- Internal Business Purposes. We may use information we collect from you to facilitate our business operations, including engaging in communications, services, advertising, and marketing activities, data analysis; auditing, assessing quality and safety, monitoring and preventing fraud, infringement, and other potential misuse of the Services; determining the effectiveness of our promotional campaigns and improving our products, services, and technology; and operating and expanding our business activities.
- Legal and Regulatory. We may use any information we believe to be necessary or appropriate under applicable law, including laws outside your country of residence, to meet legal and regulatory requirements, and comply with legal process; respond to requests from public and government authorities, including those outside your country of residence; enforce our Terms and Conditions; protect our operations or those of any of our affiliates; protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; allow us to pursue available remedies or limit the damages that we may sustain, and protect against fraud, suspicious or other illegal activities.
- In Aggregated or De-Identified Form. We may use information about you or use suggestions, comments, and ideas that do not personally identify you for any purpose, except where we are required to do otherwise under applicable law. We may combine, aggregate or de-identify any of the information we collect from you with information we may collect from or about you from any other online or offline source and use it for any purpose, including product and service development and improvement activities.
How We Share Your Information
Kyowa Kirin does not sell your personal information to third parties for business or commercial purposes. We may share the personal information that we collect and use it as described in this Privacy Policy and any other applicable privacy notices or opt-ins that you receive.
- Affiliated Entities. We may share your personal information with our affiliated companies, including Kyowa Kirin Company, Ltd, which is our parent company in Japan, and other companies within the Kyowa Kirin Group of companies, for the purposes described in this Privacy Policy.
- Service Providers. We may share your personal information with service providers who provide us with services for our websites, as well as other products and services, such as web hosting, data analysis, payment processing, order fulfillment, customer service, infrastructure provision, technology services, email delivery services, credit card processing, legal services, and other similar services. We grant our service providers access to personal information only to the extent needed for them to perform their functions, and require them to protect the confidentiality and security of such information.
- Commercial and Collaboration Partners. We may share your personal information with unaffiliated trusted third parties that partner with us to deliver a Service or to support our commercial or research activities. Depending on the choices you have made and the nature of the joint activity, these third parties may contact you regarding Kyowa Kirin- related products, programs, services and promotions that may be of interest to you. You may always opt-out from receiving marketing communications from our partners by following the instructions in their electronic communications. However, we do not sell, rent or otherwise share your personal information with any unaffiliated third parties for their own use or marketing purposes.
- At your direction. We may share your personal information with other parties with your consent or at your direction.
- Business Transfers or Assignments. If we decide to reorganize or divest part or all of our business or a line of our business, including our information databases and websites, through a merger, sale, joint venture or collaboration, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect from site users or offline to a third party. We will share your personal data with such company (without your consent or any further notice to you). In such circumstances, we will seek written assurances that your personal information submitted through our websites will be protected consistent with this Privacy Policy.
- Other Third Parties. We may share information with third parties, such as information shared when you use interactive features. In addition, cookies, pixels, web server data, and other technologies may involve sharing of information with third parties.
- Legal and Regulatory. We reserve the right to disclose your personal information as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Kyowa Kirin or others. We have no obligation to notify you of such disclosures, except as required by applicable law.
We may disclose information that does not allow any one to identify you directly or indirectly for any purpose, except where we are required to do otherwise under applicable law.
Your Privacy Choices and Rights
You may contact us to update or correct your personal information and your preferences provided to us through the Site, or opt out of receiving mailings or other communications in which you previously chose to participate. Different programs and services may offer different phone numbers, links or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. You may also contact our Privacy Office for assistance at usprivacyoffice@kyowakirin.com if you have difficulty finding these tools or otherwise updating your data or preferences. We may need to retain certain personal information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. We will endeavor to comply with your request as soon as reasonably practicable.
If you no longer wish to receive promotional emails from us on a going-forward basis, you may opt out of receiving such emails by following the “unsubscribe” directions on the emails or by changing your preference settings.
Our websites do not currently respond to web browser "do not track" signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services.
Other Aspects of Our Privacy Practices
Third-Party Sites. This Site may contain links to third-party websites that Kyowa Kirin does not control. We are not responsible for the privacy practices or the contents of any such linked sites, or for the nature, quality, or accuracy of the content or opinions expressed in such websites. We do not investigate, monitor, or check the quality, accuracy, or completeness of these third-party sites. Inclusion of any linked website on this Site does not imply or express an approval or endorsement of the linked website by Kyowa Kirin, or of any of the content, opinions, products, or services provided on such websites. Each of these linked sites maintains its own independent privacy policy. If you visit a website that is linked to this Site, we encourage you to familiarize yourself with the privacy policy of that website, which is not governed by this Privacy Policy.
Information Security. We use reasonable organizational, technical and administrative safeguards to help protect the information collected through the Services. Our security and privacy policies are periodically reviewed and enhanced, and are designed to allow only authorized individuals to have access to the information you provide. However, data transmitted over the Internet cannot be guaranteed to be completely secure from people who might attempt to evade our security measures. Your email is a non-encrypted form of Internet communications which may be accessed and viewed by other Internet users without your knowledge or permission while in transit to us. For that reason, in order to protect your privacy, please do not use email to communicate information to us that you consider confidential. While we strive to protect your personal information, Kyowa Kirin cannot guarantee the security of any information you transmit to us through this Site. Users are responsible for maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting usat usprivacyoffice@kyowakirin.com.
Data Integrity and Retention. We will retain information about you for the period necessary to fulfill the purposes outlined in this Privacy Policy or Kyowa Kirin’s data retention policies unless a longer retention period is required by law.
Data Transfers. This website is controlled and operated by Kyowa Kirin from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any personal information you provide to us may be stored and processed, transferred between and accessed from the United States (including our group companies and our external technology service providers), Japan, and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your information.
Children’s Privacy. We are committed to protecting the privacy of children. This Site and any accompanying Services offered are not directed at children who are under 13 years of age. It is our policy to require that individuals requesting information on our products be 13 years of age or older. We may collect the personal information of minors in connection with other business activities, such as adverse event reporting. Should we receive personal information from a person whom we know is under 13 years of age, we will endeavor to delete such information from our website database, and the information will not be used for any purpose. If you believe that a person under 13 years of age has provided us with his or her personal information, please notify us so that we can take reasonable steps to remove the information from our database.
Changes to Our Privacy Policy. We may revise or update this Privacy Policy at any time in our sole discretion. We will post any changes on this page and indicate at the top of this page the date this Privacy Policy was last revised. We recommend that you regularly review the Privacy Policy when you visit the Site. Your continued use of our Services constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us from the effective date.
Contacting Us. If you have any questions, comments, requests, or concerns related to this Privacy Policy, Kyowa Kirin’s information practices, or how to access this policy in another format, please contact us at Kyowa Kirin, Inc., 510 Carnegie Center Drive, Suite 600, Princeton, NJ, 08540, attention Privacy Office, or at usprivacyoffice@kyowakirin.com for assistance.
Supplemental U.S. State Privacy Notices
Last Updated: February 4, 2024
The notices below supplement the information contained in the Kyowa Kirin Privacy Policy. Capitalized terms as well as “we” or “us” have the same meaning as in the Privacy Policy.
1.Privacy Notice for Residents of California, Colorado, Connecticut, Utah, and Virginia
If you are a resident of one of the above-mentioned states, you have rights under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”) and its implementing regulations, the Colorado Privacy Act of 2021 (the “CPA”), the Connecticut Data Privacy Act of 2022 (“CDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), or the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”). Pursuant to these laws, this Privacy Notice is intended to provide you with meaningful insight into our practices regarding your Personal Information, the rights that you have, and how you may exercise them.
Please be aware that the scope of your rights as well as our obligations may differ depending on your state of residence. In those instances, we have identified the states that recognize the right or obligation. In many instances, we may not be subject to the privacy laws of your state.
A. Definitions
- “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes “personal data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as defined below, except where otherwise noted.
- “Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA.
- “Third Party” has the meanings afforded to it in the CPRA, CPA, CDPA, UCPA, and VCDPA.
- “Third Party” has the meanings afforded to it in the CPRA, CPA, CDPA, UCPA, and VCDPA.
To the extent that other terms used in this Supplemental Notice are defined terms under the CPRA, CPA, CDPA, UCPA, or VCDPA, they shall have the meanings afforded to them in those statutes. The definition that is applicable to you is provided in the law of the state in which you reside.
B. Collection & Processing of Personal Information
We and our Vendors may have collected the following categories of Personal Information about you in the last 12 months:
- Identifiers, such as name and government-issued identifier (e.g., Social Security number);
- Personal information, as defined in the California safeguards law, such as contact and financial information;
- Characteristics of protected classifications under California or federal law, such as age, gender, race, medical conditions, and marital status;
- Commercial information, such as transaction information and purchase history;
- Biometric Information;
- Internet or other electronic network activity information, such as browsing history and interactions with our websites;
- Geolocation data, such as device location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
- Sensitive Personal Information, including:
A. Personal information that reveals:
i. Social security, driver’s license, state identification card, or passport number;
ii. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
iii. Precise geolocation;
iv. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
v. Contents of a consumer’s email and text messages, unless the business is the intended recipient thereof; or
vi. Genetic data.
B. Biometric data processed for the purpose of uniquely identifying a consumer;
C. Personal Information collected and analyzed concerning a consumer’s health; and
D. Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Retention of Personal Information. We will retain your Personal Information only for a period that is reasonably necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required by law.
C. Sources from Which We Collect Personal Information
We collect your Personal Information directly from California, Colorado, Connecticut, Utah, and Virginia residents, as well as from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, caregivers, companies that help us screen and onboard individuals for hiring purposes, and other entities when they share the information with us.
D. Categories of Personal Information We Disclose to Vendors & Third Parties
We may disclose the following categories of Personal Information to Vendors and Third Parties:
- Identifiers, such as name and government-issued identifier (e.g., Social Security number);
- Personal information, as defined in the California safeguards law, such as contact and financial information;
- Characteristics of protected classifications under California or federal law, such as age, gender, race, medical conditions, and marital status;
- Commercial information, such as transaction information and purchase history;
- Biometric Information;
- Internet or other electronic network activity information, such as browsing history and interactions with our websites;
- Geolocation data, such as device location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
- Sensitive Personal Information, including:
A. Personal information that reveals:
i. Social security, driver’s license, state identification card, or passport number;
ii. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
iii. Precise geolocation;
iv. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
v. Contents of a consumer’s email and text messages, unless the business is the intended recipient thereof; or
vi. Genetic data.
B. Biometric data processed for the purpose of uniquely identifying a consumer;
C. Personal Information collected and analyzed concerning a consumer’s health; and
D. Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.
California Residents: We have not sold or shared your Personal Information in the last twelve months. For purposes of the CPRA, “sold” or “sale” means the disclosure of Personal Information to a Third Party for monetary or other valuable consideration. “Share” or “sharing” means the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Residents of Colorado, Connecticut, Utah, or Virginia: We do not sell or share Personal Information to Third Parties or process Personal Information for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, CDPA, UCPA, and VCDPA.
E. Categories of Entities to Whom We Disclose Personal Information
We will only disclose your Personal Information for purposes that are described in Section F of this Privacy Notice. We may have disclosed your Personal Information to:
- Affiliated Entities. We may share your Personal Information with our affiliated companies, including Kyowa Kirin Company, Ltd, which is our parent company in Japan, and other companies within the Kyowa Kirin Group of companies, for the purposes described in this Privacy Policy.
- Service Providers. We may share your Personal Information with service providers who perform services in our behalf. When we do so, we limit the service provider’s access to your Personal Information only to the extent that is needed for them to perform the service.
- Commercial and Collaboration Partners We may share your Personal Information with commercial and collaboration partners who we may work with to deliver a particular Service or support our commercial or research activities.
- Third Parties We may disclose your Personal Information to:
- Any Third Party, provided that you have directed us or have provided your consent to do so.
- Other entities as reasonably necessary to facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
- Government authorities, regulatory bodies, or courts when the disclosure is reasonably necessary for our business operational purposes, to assert and defend legal claims, or otherwise as permitted or required by law.
F. Purposes for Processing Personal Information
We and our Vendors may use your Personal Information to:
- Operate, manage, and maintain our business;
- Provide our products and services;
- Develop, improve, repair, and maintain our products and services;
- Personalize, advertise, and market our products and services;
- Conduct research, analytics, and data analysis;
- Maintain our facilities and infrastructure;
- Undertake quality and safety assurance measures;
- Conduct risk and security controls and monitoring;
- Detect and prevent fraud;
- Perform identity verification;
- Perform accounting, audit, and other internal functions, such as internal investigations;
- Comply with law, legal process, and internal policies;
- Maintain records;
- Exercising and defend legal claims.
- For employment purposes, including hiring and managing employees; or
- Otherwise accomplish our business purposes and objectives.
We and our Vendors will only use your Sensitive Personal Information for the following purposes:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
- To ensure security and integrity to the extent the use of the consumer's Personal Information is reasonably necessary and proportionate for these purposes;
- For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us; provided that we will not disclose your Personal Information to a Third Party and or build a profile about you;
- To perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
- To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
G. Your Rights Under U.S. State Privacy Law
As a resident of California, Colorado, Connecticut, Utah, or Virginia, you are entitled to certain rights with respect to your Personal Information. These include the following:
- The Right to Non-discrimination. We will not discriminate against you for exercising any data subject rights that you have under U.S. state privacy law. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
- The Right to Access Certain Personal Information. You may request that we provide you with access to certain Personal Information that we have collected about you, subject to exceptions provided by law.
- The Right to Opt-out of Processing for Targeted Advertising and Sales. You have the right to opt-out of the processing of your Personal Information for targeted advertising and sales, as defined by state law. However, as we explain in Section D, above, we do not process your Personal Information for these purposes.
- The Right to Correction (Residents of California, Colorado, Connecticut, and Virginia only). You may request that we correct any inaccurate Personal Information that we maintain about you.
Additionally, you may have the following rights, depending on your state of residence:
California Residents. As a California resident, you have the following rights, subject to certain exceptions:
- Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:
- The categories of Personal Information to be collected;
- The purposes for which the categories of Personal Information are collected or used;
- Whether or not that Personal Information is sold or shared;
- If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
- The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
We have provided such information in this Privacy Notice, and you may request further information about our privacy practices by contacting us as at the contact information provided above.
- Right to Deletion. You may request that we delete any Personal Information about you we that we collected from you.
- Right to Correction. You may request that we correct any inaccurate Personal Information we maintain about you.
- Right to Know. You may request that we provide you with the following information about how we have handled your Personal Information in the 12 months preceding your request:
- The categories of Personal Information we collected about you;
- The categories of sources from which we collected such Personal Information;
- The business or commercial purpose for collecting Personal Information about you;
- The categories of Personal Information about you that we shared or disclosed and the categories of Third Parties with whom we shared or disclosed such Personal Information; and
- The specific pieces of Personal Information we have collected about you.
- Right to Receive Information About Onward Disclosures. You may request that we disclose to you:
- The categories of Personal Information we collected about you;
- The categories of Personal Information that we have sold or shared about you and the categories of Third Parties to whom the Personal Information was sold or shared; and
- The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
- California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of the Services, you may ask us to remove content or data that you have posted to the Services by writing to usprivacyoffice@kyowakirin.com. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
Residents of Colorado, Connecticut, and Virginia. As a resident of these states, you have the following rights:
- The Right to Opt-out of Profiling in Furtherance of Decisions that Produce Legal or Similarly Significant Effects. Please review the law of your state for the applicable definition of this right. You may exercise this right by following the process outlined in Section H, below.
- The Right to Appeal Adverse Decisions. If you have exercised one or more of your rights and we have declined to recognize it, you have the right to appeal this decision. You may exercise your right to appeal by contacting us at: usprivacyoffice@kyowakirin.com or by calling 908-375-2300. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.
H. Submitting Data Privacy Requests
You may submit a request to exercise one or more of the rights outlined in Section G, above, by contacting our Privacy Office at
usprivacyoffice@kyowakirin.com.com or by calling 877-320-1641.
usprivacyoffice@kyowakirin.com.com or by calling 877-320-1641.
We may ask you to provide information that will enable us to verify your identity. In some instances, we may decline to honor your request if an exception applies, such as when the discflosure of Personal Information would adversely affect the rights and freedoms of another person. We will respond to your request consistent with applicable law.
As explained in Section G, we will not discriminate against you for exercising your rights under state law. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your rights.
2.Other Disclosures Under U.S. State Law
Privacy Notice for Nevada Residents. We do not sell Covered Information as defined under Nevada law, and we generally do not disclose or share personal information for commercial purposes. Under Nevada law, you have the right to direct us to not sell or license your personal information to third parties. To exercise this right, if applicable, you or your authorized representative may contact our Privacy Office at usprivacyoffice@kyowakirin.com to make an online request
Privacy Notice for Texas Residents. Pursuant to the Texas Health and Safety Code, Sec. 181.154, please be advised that if we receive any data that identifies you and relates to your past, present or future physical or mental health, healthcare or payment for your healthcare, such data may be subject to electronic disclosure by such means as file transfers or email.
Supplemental Privacy Notice for U.S. Healthcare Professionals
This Privacy Notice is intended for healthcare professionals and institutional healthcare providers who are considering working with or who already work with Kyowa Kirin. This Privacy Notice supplements Kyowa Kirin’s Privacy Policy, provided above.
We may collect personal information regarding your professional credentials, educational and professional history, institutional and government affiliations, and information included on a resume or curriculum vitae about your education and work history. We may also collect information about Kyowa Kirin and third-party programs, products and activities with which you have engaged, including but not limited to: details about our interactions with you, your prescribing of our products, the agreements you have executed with us, and any payments made to you for services provided; and publicly available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence-related information.
As a healthcare professional or an institutional healthcare provider, you are responsible for obtaining any legally required authorization, consent or other permission from your patients prior to providing their personal information to Kyowa Kirin through the Services. By submitting any personal information about a patient, you represent and warrant to us that you have obtained all required permissions to do so.
Supplemental Privacy Notice for Residents of the European Economic Area, Switzerland and the UK
If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), personal information about you may be protected by data protection laws in the EEA, Switzerland, or UK, such as the European Union General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection, the UK GDPR and the UK Data Protection Act 2018 as amended and in force. Kyowa Kirin will comply with these data protection laws when it processes personal information about you as described in this Notice.
When processing personal information as described in this Notice, Kyowa Kirin relies on one of the following legal bases, as appropriate:
- Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);
- Where it is necessary to comply with contractual obligations with you;
- Where the processing is necessary for our compliance with a legal obligation;
- Where the processing is necessary to protect the vital interests of an individual; or
- Where the processing is in Kyowa Kirin’s legitimate interest, for example, Kyowa Kirin processes data for scientific and statistical research purposes, for scientific development, for the improvement of our products and services, to provide security measures to protect its employees, contractors, patients, information, and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations) or in other ways strictly necessary to carry out our business.
In addition to the above, where Kyowa Kirin processes special categories of data about individuals (information about individuals’ health, ethnicity, religion, trade union membership, genetic and biometric data etc.), it shall only do so in accordance with applicable laws and regulations. For such processing Kyowa Kirin relies on the following conditions:
- Where individuals provide explicit consent;
- Where required for rights and obligations related to employment;
- Where required for vital interests of any individual;
- Where processing is necessary for the purposes of provision of healthcare or occupational medicine, pursuant to a contract with a health care professional; and
- Where processing is necessary for scientific research.
Kyowa Kirin is headquartered in the U.S. and as a result, personal information about you will be processed by Kyowa Kirin in the U.S. Kyowa Kirin may contract with service providers to process personal information on Kyowa Kirin’s behalf; these service providers may be located outside of the EEA, Switzerland, and UK. Data protection laws in the U.S. or other countries may not offer you the same protections as the laws of the country in which you are residing when personal information about you is collected.
Where Kyowa Kirin processes personal information in countries that may not provide the same level of data protection as in the country in which you are residing, Kyowa Kirin will implement reasonable and appropriate legal, technical, and organizational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorized access, use or disclosure. In the absence of an adequacy decision adopted by the European Commission or the Swiss/UK Data Protection Authorities, Kyowa Kirin will implement appropriate data transfer mechanisms (such as the Standard Contractual Clauses (SCCs)) for any cross-border data transfers from your country to a third party (controller or processor) located in a third country with the aim to secure such transfers and achieve an adequate level of data protection.
Data protection laws in the EEA, Switzerland, and the UK may provide you the following rights with respect to personal information processed by Kyowa Kirin:
- To withdraw consent at any time, if we are processing personal information about you on the basis of consent;
- To access the personal information that Kyowa Kirin has about you;
- To request that Kyowa Kirin rectify or erase personal information about you;
- To request that Kyowa Kirin restrict the way it processes personal information about you;
- To object to the way Kyowa Kirin processes personal information about you;
- To ask Kyowa Kirin to transfer personal information about you to you or someone else; and
- To lodge a complaint with a data protection authority in the EEA, Switzerland, or UK; You can find the competent EEA supervisory authority here. The UK Authority can be reached out here and the Swiss one here.
Kyowa Kirin’s ability or obligation to comply with your requests may be limited by applicable laws. Kyowa Kirin will require appropriate evidence of your identity or to be provided with additional relevant information based on your relationship with us before we are able to act on your request when the information we have is insufficient to accommodate your request. To request to exercise one of these rights if you are located in the EEA, Switzerland, or UK, please contact our Data Privacy Office by email at kkidpooffice@kyowakirin.com.
As Kyowa Kirin is located outside the EU, it has appointed ALG Manousakis Law Firm, a corporation duly organized under the laws of Greece, having its principal place of business at Str. 16, Laodikias, Athens, P.O. 11528, Greece as its Representative in the European Union for data protection purposes which can be contacted at: dataprivacy@alg.gr.
