Last Revised May 12, 2023

This website is operated by Otsuka Medical Devices Co., Ltd. at 2-9, Kanda-Tsukasamachi, Chiyoda-ku, Tokyo 101-0048, Japan (“Otsuka Medical Devices,” “we,” “our,” or “us”). We understand that privacy is important to our customers, business partners, and other individuals with whom we interact. This Privacy Policy explains how and why we collect and use your Personal Data, e.g. when we provide you with information you have requested from us or when you simply use our corporate websites. This Policy also explains your rights with respect to our processing of your Personal Data and other options we may provide to you. This Policy may be supplemented by additional privacy notices that are provided when Personal Data is collected from you. In this Policy, when we talk about “Personal Data,” we mean any information that relates to an identifiable person (alone or in combination with other Information), such as name, address, age, birth date, phone number, email address, user name, government identification, and payment information.

For the purposes of this Policy, Otsuka Medical Devices will be the personal information handler. This is a legal term – it means that we have collected and maintain your Personal Data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws. We are required by the laws to give you the information in this Policy.

This Privacy Policy applies to Personal Data that is processed by Otsuka Medical Devices in your use of our global website(s) (the “Site(s)”). All individuals whose responsibilities include the processing of Personal Data on behalf of Otsuka Medical Devices are expected to adhere to this Privacy Policy.

If you visit our Sites from outside Japan, please note that Japan has data protection laws, including the Act on the Protection of Personal Information in Japan (“APPI”) that may not be consistent with those of other countries and that information collected about you in connection with your visit to our Sites will be processed in accordance with Japanese laws. However, if applicable, Otsuka Medical Devices shall comply with the laws, regulations, and guidelines in any other jurisdictions, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation; “EU GDPR”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 (General Data Protection Regulation) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”).

Your use of each Site is subject to our Terms of Use and Cookie Notice.

We may update this Privacy Policy from time to time as we deem necessary. We encourage you to review this Privacy Policy periodically to be aware of any changes. We will post the date of the last revisions at the top of this Policy. Except as may otherwise be noted, any changes to this Privacy Policy will take effect immediately after being posted.

Our Sites may link to third-party websites and services that we do not operate and are outside of our control. We are not responsible for the security or privacy of any information collected by other websites or other services. Please exercise caution and review the privacy statements applicable to the third-party websites and services you use.

1.0 What Personal Data Do We Collect?

Otsuka Medical Devices collects Personal Data regarding our Site visitors. The types of Personal Data we may collect depend on the nature of our relationship with you and the requirements of applicable laws. We endeavor to collect only information that is relevant for the purposes of processing. The table below sets out the different categories of Personal Data that we may collect.

Category of Personal Data Representative Data Elements Category of Individuals About Whom Processed
Contact Information
  • Name
  • Telephone number
  • Email and mailing addresses
  • Name of company and section you belong to
  • Your job title
  • Site visitors who has made and/or are making information requests
Unique IDs
  • Device identifier
  • Cookie ID
  • Site visitors
Interaction Information
  • Your enquiries
  • Prior communications with you
  • Site visitors who has made and/or are making information requests
Demographic Information and interests
  • Age
  • Gender
  • Site preferences
  • Site visitors
Site Activity Information
  • Browsing and search history
  • Referring web site addresses
  • Device characteristics
  • Site visitors

2.0 From What Sources Do We Collect Personal Data?

Otsuka Medical Devices collects Personal Data directly from you and your devices. The table below sets out the most common sources of Personal Data.

Sources of Personal Data Representative Collection Methods and Circumstances
Directly from you
  • Information request forms
  • When you contact us
From your devices
  • Automatically collected as you navigate our Sites
  • Our website may also download "cookies" to your devices - this is described in our separate cookie notice. As described further in the cookie notice, you can change the way in which we use cookies by changing your cookie preferences.

If you provide us with Personal Data concerning another individual, you represent that you have the authority to provide us with such information for our processing in accordance with this Privacy Policy.

3.0 For What Purposes Do We Collect Personal Data?

We collect Personal Data about you for a variety of purposes, as set forth below.

Purpose for Collection Lawful Basis under EU GDPR and UK GDPR
Delivering information or content that you request and keeping record of the relevant communication

Our legitimate interests

Understanding how you use our products, services, and our Sites in order to improve and further develop our products and services and the content, features, performance, and support available through our Sites

Your consent

Complying with laws and regulations, judicial and administrative orders, or lawful requests from governmental authorities

To comply with our legal obligation

We may combine or aggregate any Personal Data we collect for any of the above purposes. We may also anonymize your Personal Data in such a way that you may not reasonably be re-identified by us or any other organization and may use such anonymized information for any purpose.

4.0 With Whom Do We Share Personal Data?

We share your Personal Data with third parties for the purposes listed below. Within the joint use framework in accordance with APPI, personal information may be disclosed or provided to the other joint users and may be used by such joint users to the extent of the purposes of use as stated below.

Category of Third Party Representative Purposes for Disclosure Safeguards
Other Otsuka Companies* (Joint users)
  • For the functions and activities described above concerning the purposes for which we collect your Personal Data

All Otsuka Companies are required to comply with this Privacy Policy.

Service providers
  • To assist us in the functions and activities described above concerning the purposes for which we collect your Personal Data, including:
    • IT support, cloud platform and data or email hosting services to support the operation of our websites, mobile applications, document and workflow management systems and other systems and applications.

Otsuka Medical Devices executes contracts with service providers prohibiting them from using or sharing your Personal Data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Successor-in-interest (actual or proposed)
  • To continue to perform the functions and activities described above concerning the purposes for which we collect your Personal Data 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)

Otsuka Medical Devices will endeavor to direct the transferee to use Personal Data in a manner that is consistent with this Privacy Policy.

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

We endeavor to limit such disclosures to the minimum necessary and to obtain assurances that your Personal Data will be protected.

Judicial authorities and parties to judicial proceedings
  • To respond to a court order or other binding request

We endeavor to limit such disclosures to the minimum necessary and to obtain assurances that your Personal Data will be protected.

Otsuka Companies* mean that Otsuka Holdings Co., Ltd., and its subsidiaries and affiliates.
We do not sell your Personal Data. Nor do we share your Personal Data with third parties for their own marketing purposes.

5.0 Where Do We Process Personal Data?

Otsuka Medical Devices is located in Japan and your Personal Data will be processed in Japan. Nevertheless, Otsuka Medical Devices is part of a global company, and we will sometimes need to transfer your Personal Data to other jurisdictions as well. We may transfer your data to a recipient in another jurisdiction if one of the following protections applies:

  • The recipient is located in a jurisdiction whose laws ensure an adequate level of data protection that is equivalent to those in Japan.
  • We have put in place appropriate safeguards such as contractual commitments to protect your Personal Data, including, if applicable, standard contractual clauses approved by European Commission when providing personal information to a third party in countries outside Japan and/or European Economic Area.
  • You explicitly consent to the transfer.

If you would like to see a copy of any relevant transfer provisions containing standard contractual clauses, please contact us as described in Section 9.0 Contact Us section of this Privacy Policy.

6.0 How Do We Secure Personal Data?

Otsuka Medical Devices has put in place appropriate security measures to protect your Personal Data from unlawful or unauthorized processing and accidental loss, destruction, or damage. However, please note that in relation to any Personal Data 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.

7.0 How Long Do We Keep Your Personal Data?

Otsuka Medical Devices retains the Personal Data we receive as described in this Privacy Policy for as long as you use our Sites or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8.0 Your Privacy Rights

You have the right to (subject to applicable laws and with certain limitations):

  • Request confirmation of whether we are processing Personal Data about you.
  • Obtain access to or a copy of your Personal Data and 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.
  • Receive an electronic copy of the Personal Data that you have provided to us, or ask us to send that information to another company (the “right of data portability”).
  • Restrict or object to our uses of your Personal Data.
  • Seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Data.
  • Request erasure of Personal Data held about you by us.
  • Withdraw your consent, where our processing of your Personal Data is based on your consent.

If you or your authorized representative would like to exercise any of these rights, please submit a request as described in Section 9.0 Contact Us of this Privacy Policy. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity, including requiring proof of identity before fulfilling request(s).

Although we make good faith efforts to provide individuals with access to their Personal Data, there may be circumstances in which we are unable to provide access, including but not limited to:

  • Where the information contains legal privilege or is of a commercially proprietary nature.
  • Where providing you with access would compromise others’ privacy or other legitimate rights.

If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

We do not discriminate or retaliate against anyone for exercising their individual rights under applicable laws, rules, or regulations.

We encourage you to update the information you provide to us, such as providing us with a new mailing or email address, a name change, or a change to other material information you have previously provided to us. This will help us continue to provide information to you that best meets your needs.

9.0 Contact Us

You may ask questions about this Privacy Policy, submit a request to opt-out of receiving marketing communications, or exercise privacy rights.

Additionally, if you have any concerns or complaints regarding Otsuka Medical Devices’s processing of your Personal Data, you can contact us at: Contact Form.

If you consider that we are in breach of our obligations under applicable data protection laws, you are always entitled to submit a complaint to the competent governmental authority.