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PRIVACY POLICY

Our Privacy Commitment

Eisai Limited (“Eisai”, “we”, “us”, “our” and similar expressions) is committed to maintaining the accuracy, security and privacy of Personal Information (defined below) in accordance with applicable Canadian privacy laws. This policy (the “Privacy Policy”) applies to the collection, use of and disclosure of Personal Information by Eisai Limited in Canada. This policy, and the website(s) on which this policy appears, is intended for Canadian residents.

This Privacy Policy is a statement of principles and guidelines concerning the protection of Personal Information of our customers, service providers and other individuals (“you”, “your” and similar expressions).

Your Consent

BY SUBMITTING PERSONAL INFORMATION TO EISAI OR ITS AGENTS AND SERVICE PROVIDERS, THROUGH ANY MEANS, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY APPLICABLE LAWS AND EXPRESSLY CONSENT TO ALL SUCH COLLECTIONS, USES, AND DISCLOSURES.

Subject to legal and contractual requirements, and reasonable notice, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting Eisai’s Privacy Officer using the contact information provided below. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

If you provide us with the Personal Information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such individual (or, if such individual is a minor in their jurisdiction of residence, from their parent or legal guardian) to enable us to collect, use and disclose such Personal Information for the purposes set forth in this Privacy Policy.

What is Personal Information?

Canadian privacy laws define Personal Information broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, Personal Information means information about an identifiable individual, as may be defined from time to time in applicable privacy laws and includes personal health information which you provide to us or ask others to provide to us (“Personal Information”).

What Personal Information do we Collect?

Some of our websites might require you to register in order to log in, in which case you will be required to provide personal information about yourself to us. Typically, the types of Personal Information that Eisai may collect, use and disclose about you includes (where applicable) some of the following, but this list is not exhaustive:

  • Contact details, such as your name, telephone number, and e-mail/postal address.
  • Basic information about you, such as age and gender.
  • Health and treatment data, including biometric information.
  • Other information may also be requested, when relevant, and could include information about lifestyle or the household you live in as these impact aspects of managing medical conditions, or information regarding your education and employment history if you are seeking a position with us.

Whenever we ask you for any Personal Information that can be used to identify you as an individual, we provide an explanation as to why we gather the information, how we gather it, how we store it, and how we plan on treating and using it.

Except as described in this Privacy Policy or as may be permitted or required by applicable law, we will only gather Personal Information about you if you specifically agree to ‘opt-in’, i.e. you explicitly give us your consent to collect this information regarding you.

We will only gather and store Personally Information for the purpose stated during the gathering process and for such other purposes permitted or required by applicable law. When we finish processing your information for the stated purpose, we will erase and destroy it, following any legal or Eisai retention periods, to help ensure your privacy.

There is always a lot of information that a company can ask you for, but Eisai will only ask for information where there is a clear and necessary need for that information, which is clearly and adequately explained to you.

WHAT TYPES OF NON-PERSONAL INFORMATION DO WE COLLECT?

We may also collect certain non-personal information about you, that does not directly or indirectly reveal your identity, such as browser type and version, time zone setting, browser plugins and version, operating system and platform, or information about your internet connection, the equipment you use to access our website, and usage details. It may also include non-personal details about your interactions with our website, including the full Uniform Resource Locators (URLs), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service centre.

WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

Eisai limits the collection, use and disclosure of your Personal Information, both in the amount and type of Personal Information, to that which is necessary to fulfill the purposes identified within this Privacy Policy or otherwise disclosed to you. We will identify the purposes for which your Personal Information is collected at or before the time your Personal Information is collected.

In general, Eisai collects, uses and discloses Personal Information in order to provide our customers with our products and services including to administer service contracts. More specifically, Eisai may collect, use and disclose your Personal Information for the following purposes:

  • to providers, financial institutions, and affiliates, in order to provide ongoing products and services, administer accounts, make and receive payments, and fulfill contractual obligations;
  • to communicate with, understand and respond to website visitors, customers and potential customers’ needs and preferences, and improve the website experience;
  • to conduct surveys, promotions, research and statistical analysis;
  • to facilitate customer service assistance;
  • to distribute our newsletters, promotional information and other material to registrants that have voluntarily enrolled on our mailing list and/or e-mailing list;
  • to develop, enhance, market, sell, provide and inform you of Eisai’s products and services;
  • to communicate with you regarding other consulting or business opportunities;
  • to update and verify our databases and information provided by third parties;
  • to develop and manage our databases;
  • to handle or conduct litigation and/or investigations, and comply with government (regulatory, judicial, legislative) requests or orders;
  • to respond to your requests, questions or inquires;
  • to create a record of complaints and adverse event reports relating to our products and reporting these to the relevant regulators, related companies, or other third parties;
  • administering disease awareness and management programs, or similar programs;
  • to provide patient support and/or meetings;
  • to conduct market research, including without limitation with relation to health economic data and other demographic matters;
  • in the case of healthcare professionals, supplying you with clinical evaluation materials regarding our products, administering clinical trials, continuing education, conferences panels, or seminars you agree to participate in;
  • to otherwise operate our business in the normal course and managing risks, including for auditing and security purposes
  • to create aggregated, de-identified information for analytical or reporting purposes;
  • as permitted by, and/or to comply with, any legal or regulatory requirements or provisions;
  • to evaluate you for a position to which you have applied, or other positions that may become available in the future; and
  • for any other purpose to which you consent

TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We will not sell, lease or rent your Personal Information or our customer lists.

We disclose Personal Information in accordance with this Privacy Policy, or for the purpose(s) for which you have given consent.

We keep your Personal Information, questions, and transactions with us confidential; and we employ the appropriate security safeguards.

However, from time to time, Eisai may disclose your Personal Information to:

  • service providers, including an organization or individual retained by Eisai to perform functions on its behalf, including, but not limited to, marketing, data processing, document management and office services;
  • service providers providing offsite servers to store information;
  • to Eisai’s affiliates to carry out the purposes indicated in this Privacy Policy;
  • a person who, in the reasonable judgment of Eisai, is providing or seeking the information as your agent;
  • to a privacy commissioner acting in the authority of administering applicable privacy laws; or
  • any other third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

We reserve the right to disclose and transfer any Personal Information we have about you in the event that we merge with or are acquired by a third party (or propose to do so). We may also disclose your Personal Information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law or policies; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) to protect our rights, safety or property; or (iv) to investigate security breaches or cooperate with government authorities pursuant to a legal matter.

Among other obligations, Eisai is required by law to report adverse events with respect to any of its products to the appropriate authorities around the world. We may use your Personal Information to contact you where we reasonably believe that you have additional information with respect to any adverse events that may have been experienced in connection with our products or to notify you of a product recall. We may also disclose your Personal Information to any authority where we are required to do so by law for related adverse reporting and product recall issues.

Personal Information you provide to us may be transferred outside of your province of residence, and outside of Canada, including to our offices in the United States, the European Union, the United Kingdom, Switzerland and/or Japan. You agree that by providing us with your Personal Information, your Personal Information may be subject to the laws of such jurisdictions, regulations and/or court orders and may be disclosed to third parties or authorities in complying with the laws, regulations and/or court orders of such jurisdictions.

Further, please note that certain governmental agencies in jurisdictions where Eisai conducts business, such as the United States, require pharmaceutical companies to disclose information on compensation, gifts or other remuneration provided to physicians and other health care professionals. Eisai may report information about remuneration provided as required by local laws. Once reported, such information may be publicly accessible and your Personal Information may be required to be disclosed. Under this privacy policy your Personal Information can be disclosed for this purpose and may be made public.

HOW DO WE COLLECT AND USE INFORMATION THOUGH AUTOMATIC MEANS?

Eisai and third parties with whom Eisai has contracted to provide services to Eisai may also collect information from you through browser navigational tools, “cookies”, pixel tags and other similar technologies. These may include:

  1. Browser Navigational Tools. We and our service providers may collect and use certain technology data, such as your computer type (Windows or Macintosh), screen resolution, Operating System (OS) version, Internet browser, and Internet browser version. This type of information is collected by many browsers, and can be used to help optimize your experience on our website.
  2. Cookies. We and our service providers may use “cookies” on our websites. A cookie is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences. There are two principal types of cookies:
    1. “Session” cookies are temporary bits of information that are used to improve website navigation, block website visitors from providing information where inappropriate and to collect aggregate statistical information on a website. These cookies are erased once you exit your web browser or otherwise turn off your computer.
    2. “Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer so that we can, for example, retrieve information you have previously provided (such as passwords), better determine what areas of the website you find most valuable, and customize the website based on your preferences on an ongoing basis.
    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. To learn more about cookies, please visit http://www.allaboutcookies.org/.
  3. Pixel Tags. We and our service providers may also use so-called “pixel tags,” “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 website users and email recipients (including activity on other websites); determine the success of marketing campaigns; and compile aggregate statistics about website usage and response rates.
  4. Other Sources. Eisai also may collect information (such as indications of your interests, your geographic location, and other demographic information) that you or others provide, and we also may aggregate this information and/or other information in our possession in a manner such that the end-product does not personally identify you or any other individual and so is not Personal Information. For example, we might aggregate information to calculate the percentage of our users who have a particular telephone area code, or to better understand certain medical usage patterns. Such aggregate information is not considered Personal Information for purposes of this Privacy Policy.

    As noted above, we and our service providers may use tracking technologies, such as cookies and Pixel Tags, to improve the usefulness and value to you of our website, as well as to gauge the success of marketing initiatives and to improve our marketing campaigns, by tracking your online visits to our websites and other websites not operated by us. For example, we may use such technologies to remind you of Eisai products when you are browsing another website or may collect aggregate information about other websites you have browsed. We reserve the right to use information that is not Personal Information for any other purpose as well. For example, we may use aggregated non-personal health information to publish reports on particular topics. In some instances, we may combine non- personal information with Personal Information (such as embedding email addresses in cookies). If we do combine any non-personal information with Personal Information, the combined information will be treated by us as Personal Information for so long as it is so combined.
  5. IP Addresses. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (“ISP”). This number may be identified and logged automatically in our server log files whenever users visit the website, along with the time(s) of such visit(s) and the page(s) that were visited.

    Collecting IP Addresses is customary on the internet and is done automatically by many websites.

    We may use IP Addresses for purposes such as calculating website usage levels, helping diagnose server problems, ensuring appropriate access rights by authorized users, facilitating website security, and administering the website.

WHERE DO WE STORE YOUR PERSONAL INFORMATION?

Your Personal Information is stored in secured locations and/or on servers, including in locations and servers located in Mississauga, Ontario, Nutley, New Jersey, or at the locations of our service providers or United States affiliates.

Eisai retains your Personal Information only for as long as is necessary in order to fulfill the purposes identified within this Privacy Policy, for as long as may be required to comply with applicable laws, or as required under Eisai’s record retention policies.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

To help protect the confidentiality and security of your Personal Information, Eisai employs physical, administrative and technological safeguards appropriate to the sensitivity of your Personal Information. If your Personal Information is sent to a third party for processing, we seek to make sure, through our contracts with such third parties, that all of your Personal Information is to be kept secure. Personal Information may only be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes identified to you or permitted or required by law. We also operate secure data networks protected by industry standard firewall and password protection systems. We try to keep your Personal Information as accurate, complete and up-to-date as is necessary to fulfill the purposes identified in this Privacy Policy. However, we do not routinely update your Personal Information. If any Personal Information you have provided to us has changed, please contact us for the purposes of updating it.

HOW CAN YOU OBTAIN ACCESS TO YOUR PERSONAL INFORMATION?

Upon your written request, and subject to certain exceptions, Eisai will give you access to the Personal Information we hold about you. Access requests should be sent to Eisai’s Privacy Officer using the contact information outlined below.

If access to your Personal Information is denied, Eisai will notify you in writing, give reasons for the denial, and inform you of the recourses open to you. If access is granted, Eisai will give you a reasonable opportunity to review your Personal Information. Your Personal Information will be provided to you in an understandable form within a reasonable time, generally within 30 days. Eisai may extend such 30 day period by up to an additional 30 days in certain circumstances, including in cases where meeting the time limit would unreasonably interfere with the activities of Eisai or the time required to undertake any consultations necessary to respond to your request would make the time limit impracticable to meet. You will be able to challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.

CHILDREN AND PARENTS

Eisai does not typically collect Personal Information from children. If a child has already provided us with Personal Information, his, her or their parent or guardian may contact us for the purpose of deleting this information.

THIRD PARTY WEBSITES

Our websites may contain links to other third party websites, plug-ins, services, social networks or applications. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any such third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from our websites to other websites, or references to products, services or publications other than those of Eisai, do not imply the endorsement or approval of such websites, products, services or publications by Eisai.

HOW CAN YOU OBTAIN FURTHER INFORMATION REGARDING THIS PRIVACY POLICY?

Eisai has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For more information on Eisai’s privacy practices, please contact our Privacy Officer at (905) 361-7130 or by writing to Privacy_Officer_Canada@eisai.com.

CHANGES TO OUR PRIVACY POLICY

Eisai reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will make such revised policy and changes available on our website. However, Eisai will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those for which your consent has been previously obtained, unless otherwise required or permitted by law. Your continued access to and/or use of our website after any such changes constitutes your acceptance of, and agreement to be legally bound by, this Privacy Policy, as revised. Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it.


Date last revised: January 16, 2023