Privacy Policy

Introduction

Otsuka Canada Pharmaceutical Inc. (''OCPI''), and its parent company, subsidiaries and affiliates (collectively the "Otsuka Group of Companies" or "Otsuka") operate a variety of Websites designed to provide users with information and services including but not limited to health resources, corporate news and product information. Some of Otsuka’s Websites also enable healthcare professionals to receive product information, samples and/or order product. Whether you are a patient, healthcare professional, investor, customer or job applicant, respect for the privacy of your personal information is very important to Otsuka.

In that respect, OCPI/Otsuka is committed to complying with all requirements set forth in applicable law and more particularly the ones governing the collection, use, storage, sharing and destruction of any information about an identifiable individual (''personal information''), and has put in place various measures, practices and guidelines to ensure that the privacy and the confidentiality of any personal information is preserved.

This policy describes how OCPI/Otsuka collects, uses, handles, stores, shares, retains and destroys information obtained about users when they visit any of our Websites. OCPI/Otsuka is committed to collecting, maintaining and securing personal information in accordance with the provisions set out herein and in compliance with applicable privacy laws.

What information do we collect?

In the course of providing its services and other online resources, Otsuka may collect information about yourself with your express or implied consent, it being understood that Otsuka will not collect sensitive personal information about users unless provided voluntarily or with your express consent.

Personal information

The type of information collected from you will be based on the specific program or services that you register for or online materials that you may access. The information that we may ask you to provide may include your first and last name, your mailing address, your age, birth date, email address, and information about your medical condition(s), the province you reside in, and your licence number or area of specialty if you are a healthcare professional, as further described below. Depending on which Website you visit, you may not be able to receive certain information unless you agree to provide us with personal information necessary to provide the services requested.

Otsuka limits the collection and processing of personal information to what is necessary to fulfill the purposes for which it is to be used. As such, you will be able to register online, subscribe to a service or complete any purpose described below by providing us with such “necessary” information, while you will be entitled (but not required) to disclose any additional “optional” information. Otsuka will obtain your express or implied consent to collect your personal information when you register for a program or service. We will also offer you the option to withdraw your consent at all times ("opting out" or "unsubscribing") if you later decide that you no longer wish to participate in a particular program or receive additional information from us.

De-identified information and other data

Non-personal information, namely personal information from which a person’s name and other unique identifiers have been removed, so that the information can no longer be linked to an identifiable individual, as well as other data can be used for any purpose such as statistical training, research and development.

Intended Use of Personal Information

Otsuka will collect the following information about the users and visitors of its products, services, Websites and other online resources:

Account registration: Most of our services do not require any form of registration, allowing you to visit our site or obtain access to various types of information without the need to register online or subscribe to our services. However, some services may require the creation of an online account or the completion of a registration process. When you register with us, you may need to complete certain fields (some are required and some are optional), as well as choose a username and password. In these situations, if you choose to withhold any personal information which is “necessary” (such as your name and date of birth as these services are not intended for children), it may not be possible for you to complete the registration process and gain access to certain parts of the site, as such information is required to create your personal profile and authenticate you in future connections, to communicate with you whenever required and in some cases to ascertain that you can register online or subscribe to our services.

Confirmation of user credentials: We may also collect information about physicians and other healthcare professionals, who register on our Websites or access materials, from other sources in order to verify licensure status and identity. In some instances you may be asked to provide additional information such as your email address if you want to obtain additional services, information or to resolve any complaints or concerns.

Adverse events: Any person wishing to report an adverse event, product quality complaint or any feedback on any product, shall contact the Medical Information and Drug Safety Department directly (by email OCPI-medInfo@otsuka-ca.com, phone: 1-877-341-9245 or fax: 1-844-268-9110). You may be required to disclose your name, email address, address and other contact information, as well as some details about the adverse event or other situation that you would like to report. This will allow us to evaluate the health product’s profile and take measures to protect patients and the public in general. If you are a patient, the Department may wish to know the name and contact information of your treating physician to follow up or help you report this incident to this physician and find proper healthcare resources.

Questions and comments: We may provide opportunities to contact us in order to ask questions or provide comments, ideas, and/or suggestions. When you communicate with us, our customer services will have access to any information you communicate or otherwise disclose, such as your name, email address, telephone number and address, as well as any opinion, question, or comment made.

Furthermore, if you request a response, we may ask for your name and contact information if not already disclosed, our customer service will thereafter collect the information needed to categorize the communication, to respond to any enquiry, comment or request for information, or to investigate any privacy breach or other problematic situations. If you are a patient or consumer, we invite you to consult your healthcare professional for information on our products and for medical or health-related inquiries. Your healthcare professional (physician, pharmacist, nurse, etc.) is the most qualified person to respond since the answer to your questions may vary based on your health condition and medical history.

Bulletins and newsletters: Any person wishing to subscribe to our bulletins and newsletters will have to disclose information such as its name and email address to allow OCPI/Otsuka to send such electronic sheets and documents.

Surveys: We may invite you to fill in a survey to confirm your interest and satisfaction with respect to our products and services. If we collect this type of information, we will notify you as to why we are asking for it and how this information will be used. It is completely up to you whether or not you want to provide it.

Cookies: As you browse on Otsuka’s Websites or use other services, Otsuka may collect and store through standard operation of Otsuka’s Internet service or through the use of "cookies" or "internet tags" and other similar techniques, personal information such as: the name of the domain and host from which you access the Internet, the Internet protocol (IP) address of the computer you are using, the browser software you use and your operating system, the date and time you access our Websites and the Internet address of the Websites from which you linked directly to our Websites.

Cookies are small text files. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site. Tags (or GIFs or web beacons) are invisible tags placed on certain pages of a website and generating a notice of that visit. A Website can use the foregoing to recognize repeated usage, to facilitate the user's access to and use of a site as well as to allow a site to track usage behaviour and compile aggregate data (such as the date and time of users’ visit) that will: allow content improvement, to remember your preferences, to maintain your session open and help the Websites work properly (e.g. when moving from a webpage to another), to prevent fraudulent use of your account, or to generate targeted messaging.

While persistent cookies – such as “preference cookies” collecting information (such as your preferred language and size of lettering), “statistical cookies” and “advertising cookies” – can be blocked, temporary cookies, such as “process cookies”, “sessions state cookies” and “security cookies” – making the Websites work properly when moving from a page to another, maintaining your session open and preventing fraudulent use of login credentials – are essential to ensure the integrity and security of your online session and as such, cannot be blocked. If a user does not want information to be collected through the use of persistent cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature. However, users should note that cookies may be necessary to provide the user with certain optional features (e.g. customized delivery of information) available on Otsuka’s Websites. Likewise, you can turn off pixel tags, which will thereafter simply detect anonymous Website visits.

Marketing and Promotional initiatives: We may communicate with any person with whom we have a business relationship, namely any person who enquires about our products and services, subscribes to our services, accepts a business opportunity or otherwise contracts with us, to inform them about our products and services, invite them to events and provide them with other information of interest. Such communications will be made in strict compliance with applicable law, including Canada’s Anti-Spam Legislation.

Future Services: Otsuka is continuously striving to improve the services it offers, or create new services to better suit your needs. Furthermore, new partnerships or other business transactions may lead to the implementation of new services. The foregoing may result in the collection of new personal information. Should Otsuka start collecting additional personal information or substantially new types of personal information or materially change how it handles such information, then Otsuka will notify this change to you in accordance with the provisions herein.

Storage of personal information

Subject to applicable laws, Otsuka will store personal information only for the purposes for which it was collected and as long as it is necessary to fulfill such purposes. In that respect, Otsuka has put in place measures of control, timeframes and guidelines pertaining to the storage of personal information and to the destruction of files and other supports containing such personal information when deemed no longer required or relevant under the law or for the purposes listed in the previous section.

Sharing Your Information

Otsuka will not share your personal information with unrelated third-parties for their own separate use, unless we have obtained your opt-in consent to do so.

Information shared with our business partners

When you provide personal information to Otsuka, it may occasionally be transferred to third-parties who act for or on behalf of Otsuka, or in connection with the business of Otsuka, for further processing in accordance with the purpose(s) for which the data was originally collected, such as delivery services, evaluation or technical support. For instance, such personal information may be accessible to some of Otsuka’s business alliances and service providers, such as agencies or companies we retain to fulfill requests for information, answer telephone calls or provide assistance to us on specific programs or projects and otherwise help us fulfill any purpose described above. In addition, Otsuka may enter into business relationships with other companies for co-promotion purposes.

In those cases, these contractually related other companies may also have access to your personal information. Otsuka requires third-parties, to whom it discloses personal information, to protect personal information using substantially similar standards to those employed by Otsuka and to comply with the provisions of this privacy policy. Otsuka also requires that these related third-parties do not use your personal information for any separate use that is not specifically authorized by Otsuka in accordance with your implied or express consent previously secured. Finally, these third parties have contracted with Otsuka that they will only use personal information for the agreed upon purpose, and will not sell your personal information to third parties, and will not disclose it to third parties except with your consent, or as may be required by law (e.g. in support of any legal or criminal investigation).

Likewise, should the information provided be shared with other Otsuka Group of Companies, including other affiliates, subsidiaries or departments within a particular Otsuka Company then Otsuka will ensure that such other departments or entity within the Otsuka Group of Companies that may receive your information, will abide by substantially similar privacy requirements relating to your personal information and to comply with the provisions of this privacy policy.

Where such disclosure of personal information to a third party occurs, Otsuka will ensure that the processing is performed in accordance with the purposes and within the limits under which the person information was originally collected.

Information shared with other third-parties

There may also be instances where Otsuka may be required to share your information with third-parties who have not been retained by Otsuka, such as with health authorities, in order to report possible adverse drug events, during inspections or audits, or as ordered or directed by courts or other governmental agencies. These entities receiving personal information under these conditions have some privacy requirements that apply to their handling of your information.

Personal information may also be transferred to a potential purchaser or other corporation in connection with a business transaction or corporate reorganization, such as if Otsuka is to be sold, merged or amalgamated or if substantially all of Otsuka’s assets are to be sold or disposed of, the whole to the extent however that such communication is necessary for the purposes of deciding whether to proceed with the sale or other transaction.

Finally, Otsuka reserves the right to use or disclose personal information if it reasonably believes that such use or disclosure is necessary to protect Otsuka’s rights, to comply with a judicial proceeding, a court order, or a legal process or for any other purpose set forth in the law allowing or requiring the disclosure of personal information.

Information shared by third parties

Otsuka have concluded agreements with business partners such as Google, offering technological services, such as Google Analytics, allowing the collection of information about users’ interactions with the Websites. This collection of information is made through codes placed on the Websites, compiling information about the pages consulted and the type of browser and device that was used. The information collected will then be processed by Google or other business partners on their platform and subsequently transmitted to Otsuka, and updated from time to time. The information obtained from these tools is used on an aggregated de-identified basis to improve the Websites.

Data Integrity

Otsuka takes reasonable steps to ensure that personal information collected is reliable for its intended use, accurate, complete and current. To that end, Otsuka ensure that you can consult, correct and update such information at all times as follows:

Registration information (if applicable): You may update or change your registration information on your account by logging in and clicking on “Modify my profile”. You can also update your contact information (e.g. for bulletins and newsletters) by contacting our customer service (using the contact information included below).

Withdrawal from the mailing list (if applicable): You can contact us at any time to be removed from one or more of our mailing lists, as indicated below. You can always unsubscribe from receiving emails simply by clicking on the ready-to-use “unsubscribe” link provided at the bottom of every email. Should you wish to be removed from one or more of the mailing lists, you can do so by specifying, on an email or letter or when calling us from which list(s) you wish to be removed.

Fees: Modification of your information and removal of mailing lists is free of charge.

Request for access and correction: Please see next section.

Updating and Accessing Your Information

You are entitled to review any file we can maintain about you and request that any inaccurate, incomplete our outdated information be modified by communicating with us in the manner set forth below. We encourage users to update the information provided to Otsuka, such as providing a new mailing or email address, a name change, or a change in the medical condition(s) that you have notified us about. This will help Otsuka to continue providing information to you that best meets your needs.

In addition, the Otsuka Group of Companies comply with applicable laws and regulations within their jurisdictions, including the right to amend your data in our files. In order to protect your data from unauthorized access or alteration by third parties, all requests to update or access your information will be subject to verification of your identity.

Requests for access and correction are free of charge. However, we may require a reasonable fee for the reproduction and forwarding of documents containing personal information if you wish to receive a copy of such documents as allowed under applicable law. Otsuka will notify ahead of time of the amount of these fees if applicable.

Security

We use appropriate technical, administrative and physical safeguards and other measures to protect data that pertains to you from loss, misuse or alteration.

In addition, we take steps to ensure that our safeguards take into account any known threats. Of course, no organization can guarantee the absolute security of personal information. You should keep in mind that Internet transmissions, particularly email transmissions, just like any other mode of transmission are never 100% secure or error-free.

Furthermore, please be aware that identity thieves sometimes send fraudulent emails to trick individuals into divulging personal or financial information. Should you receive an email that looks like it is from Otsuka asking for personal information, you shall avoid responding to such email. Otsuka will never request account password or financial information through emails. If you have received or entered personal information in response to a suspicious email, pop-up or phony website claiming to be affiliated with Otsuka Websites, please contact Otsuka immediately.

Transfer of Your Information Outside of Canada

Your information may be processed and/or stored outside of Canada. Otsuka undertakes measures to protect your personal information when it is stored and/or processed in other jurisdictions and to ensure that such information received the same level of protection as those offered under local applicable law and this privacy policy. Despite the foregoing and even if OCPI/Otsuka implements measures to protect your personal information, when it is stored and/or processed in other jurisdictions, its disclosure may be allowed or required under other or additional circumstances pursuant to applicable foreign law, and accordingly it may be available to the foreign government authorities and other persons of the country in which the information or entity controlling it is situated under a lawful order made in that country or as otherwise allowed under foreign laws and used for purposes other than those described herein. By providing us with your information, you understand the foregoing and are allowing your personal information to be transferred outside of Canada.

Children's Online Privacy

OCPI/Otsuka’s Websites are not directed at children. The services offered on our Websites are designed for individuals who are 18 years of age or older and Otsuka does not knowingly collect personal information from individuals who under 18 years of age.

Links and Third-Party Websites

In some instances, Otsuka’s Websites may contain links or references to third-party websites. These hyperlinks are provided for convenience only. Furthermore, these third parties websites are not affiliated to, created or operated by us and as such this Privacy Policy does not cover the content or practices of third-party websites. Accessing these third-party sources requires that a user leave Otsuka’s Websites. As Otsuka does not control the content of these third-party websites, Otsuka is not responsible for the practices of those websites. You are responsible for deciding to review such websites and for any decision and consequences flowing from such use. Please review the respective third-party’s privacy policies on each website that you visit.

Amendments and Reviews to the Privacy Policy

Otsuka may update this Privacy Policy from time to time based on, among other things, changes in applicable laws, development of new Websites and advances in technology. Otsuka reserves the right to modify, add or remove portions of this Privacy Policy at any time, at our discretion. If we decide to change this Privacy Policy, we will post those changes on this Website, using a web banner or other means to bring these changes to your attention. Should any material change be made to this policy then we will provide you with a prior notice of such change. Your continued used of the Websites after the entry into force of such change will constitute acceptance of any amendments introduced. Should you disagree with the amendments made to the Privacy Policy, you shall immediately stop accessing or using these Websites and online account.

You can tell if this Privacy Policy has changed by checking the effective date that appears at the end of said Privacy Policy.

This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

How to Contact Us

General contact information

If you have any questions, comments, or concerns about this Privacy Policy or the information collection practices of Otsuka, or if you would like to opt out of receiving further communication please contact us at:

Attention: Privacy Officer

Otsuka Canada Pharmaceutical Inc. Telephone: 514-332-3175

Fax: 514-332-3107

Email: OCPI-PrivacyOfficer@otsuka-ca.com

Adverse reactions and other comments about our products

Any person wishing to report an adverse event, product quality complaint or any feedback on any product, shall contact the Medical Information and Drug Safety Department:

Email: OCPI-medInfo@otsuka-ca.com

Phone: 1-877-341-9245

Fax: 1-844-268-9110

Last updated: Jan 2022