Privacy Policy
In compliance with the "Act on the Protection of Personal Information" (Act No. 57, 2003, hereinafter referred to as the "Act"), EA Pharma Co., Ltd. (hereinafter referred to as "EA Pharma") has established the privacy policy to ensure proper handling of personal information as follows (hereinafter referred to as the “Privacy Policy”):
１．Compliance with relevant laws, regulations and guidelines
EA Pharma will handle personal information properly in compliance with the Act and other related laws and regulations, as well as the guidelines of the Personal Information Protection Commission and other guidelines related to the protection of personal information.
２．Acquisition and use of personal information
When acquiring personal information, EA Pharma will announce, or notify the identifiable person of, the purpose of use (including the announcement by this Privacy Policy). In addition, when EA Pharma acquires personal information that appears in a written agreement or other documents (including an electronic or magnetic record) directly from the identifiable person, EA Pharma will explicitly specify the purpose of use to the identifiable person in advance and acquire the personal information by lawful and fair means. EA Pharma will use personal information properly to the extent necessary to achieve the purpose of use.
（１）SSL（Secure Sockets Layer）
This website (hereinafter referred to as the “Website”) uses SSL (Secure Sockets Layer) encrypted communication function to improve the security level.
（２）Access logs
On this Website, access logs of the person who accesses this Website are recorded. Access logs include IP address, date and time of access, browser type, domain name, number of accesses but do not include any information that can identify the person. Access logs are used for statistical analysis of the usage status of this Website as well as for service improvement.
３．Purpose of use of personal information
EA Pharma uses personal information for the purposes set forth in the linked page below.
”Purpose of use and other details of personal information” （privacy_en.pdf (eapharma.co.jp)）
４．Shared use of personal information
EA Pharma may share the personal information of ① medical professionals, ② EA Pharma’s directors, executive officers, auditors, and employees (hereinafter collectively referred to as "Employees and so forth"), and their families, and ③ business partners; more specifically,
（１）Items of personal information to be shared
① Personal information of medical professionals*
・Physician and medical facility database
・Database of pharmacists belonging to the medical facilities
・Pharmacy and drug store database
・Dentist and dental clinic database
・Database of other facilities that purchase EA Pharma’s products
*Please see the website of Nihon Ultmarc Inc. for more details of the items and others of personal information to be shared.
（https://www.ultmarc.co.jp/privacy/shared_use/index.html）
② Personal information of Employees and so forth
・Name
・Date of birth, sex, nationality
・Address, postal code, telephone number, email address
・Family information (name, date of birth, sex, and so forth)
・Financial account information
・Workplace information (name, address, telephone number, fax number, email address)
・Department, job role
・Position, title
・Birthplace
・Alma mater, year of graduation
・Qualification, year of registration
③ Personal information of business partners
・Name
・Workplace information (name, address, telephone number, fax number, email address), and so forth
（２）Scope of the parties who share
① Personal information of medical professionals
・Nihon Ultmarc Inc.
・Member companies of the medical database provided by Nihon Ultmarc Inc.
(For more specific information of the scope, please see the website of Nihon Ultmarc Inc. in （２）, ① above.)
・Pharmaceutical companies and so forth that partner with EA Pharma
② Personal information of Employees and so forth
・Consolidated companies and equity-method affiliates of EA Pharma described in the securities reports of EA Pharma and Eisai Co., Ltd.
・Ajinomoto Co., Inc. and its domestic affiliates
・Pharmaceutical companies and so forth that partner with EA Pharma (only the personal information of Employees and so forth)
③ Personal information of business partners
・EA Pharma, and Eisai Co., Ltd. and its subsidiaries/affiliates
（３）Purpose of shared use
① Personal information of medical professionals
・Provision and collection of information on proper use of pharmaceuticals
・Provision and collection of information on the quality, safety, and efficacy of pharmaceuticals.
・Surveys and research in the fields of medicine and pharmacy
・Provision, collection, and investigation of healthcare and medical science information
・Membership authentication and membership management of internet sites for medical professionals
・Requesting and conducting clinical trials, post-marketing surveillance, and so forth
・Compliance audit and response
・Time and attendance management, schedule management, payment of salaries and allowances, human resources, general affairs, evaluation, skill development, welfare benefits, health and safety, and so forth
・Contacting and providing information to health insurance associations, stock holding associations, life insurance companies, and non-life insurance companies (limited to those companies brokered by the parties who share the personal information hereunder), EA Pharma's consolidated companies and equity-method affiliates listed in the securities reports of EA Pharma and Eisai Co. Ltd., as well as Ajinomoto Co., Inc. and its domestic affiliates
・Notification and reporting to the government authorities
・Compliance audit and response (only the personal information of Employees and so forth)
③ Personal information of business partners
・Review, investigation, and response related to business transactions and activities in the industry
・Contacts and information sharing related to business transactions and activities in the industry
・Notification and reporting, as well as other necessary administrative procedures, related to business transactions and activities in the industry
・Building smooth relationships necessary to achieve the purpose of use
（４）Name, address, contact, and so forth of the company responsible for the management of personal information
For inquiries about the shared use, please contact as shown below.
【Company responsible】
① Personal information of medical professionals
Nihon Ultmarc Inc.
Please see the following website for details of contact information.
https://www.ultmarc.co.jp/privacy/shared_use/index.html
② Personal information of Employees and so forth, and business partners
Personal Information Consultation Desk
Compliance Promotion and Risk Management Department
EA Pharma Co., Ltd.
2-1-1, Irifune, Chuo-ku, Tokyo 104-0042
Tel +81(0)80-7440-0699
Reception hours Mon-Fri (excluding national holidays and year-end and New Year holidays)
9:00 – 12:00, 13:00 – 17:00
５．Provision of personal information to third parties
EA Pharma will not provide the personal information held by EA Pharma to any third parties except:
（１）when the identifiable person has given prior consent;
（２）outsourcing to the extent necessary to achieve the purpose of use;
（３）when EA Pharma provides, or is required to provide, according to laws and regulations and so forth;
（４）when there is a need to protect the life, wellbeing, or property of an individual, and it is difficult to obtain the consent of the identifiable person;
（５）when there is a special need to improve public wellbeing or promote healthy child development, and it is difficult to obtain the consent of the identifiable person;
（６）when there is a need to cooperate with a national government organ, local government, or person entrusted thereby in performing the functions prescribed by laws and regulations, and obtaining the consent of the identifiable person is likely to interfere with the performance of such functions; and
（７）when provides based on Article 4. Shared use of personal information hereabove to those who are listed in the Scope of the parties who share in the same article.
６．Acquisition of information related to personal information
EA Pharma may obtain the information that is defined as “iInformation related to personal information” under the Act, including website browsing history, (hereinafter referred to as the “Information related to Ppersonal Iinformation”) from a partner company, and link the same to the personal information already held by EA Pharma to use within the scope of the Purpose of use of personal information set forth in Article 3 hereabove.
７．Pseudonymized personal information
EA Pharma may prepare pseudonymized personal information in a way that makes it not possible to identify a specific individual unless collated with other information, based on the related laws, regulations, and so forth, and handle such pseudonymized personal information within the scope of the Purpose of use of personal information set forth in Article 3 hereabove.
８．Anonymized personal information
EA Pharma may acquire or prepare anonymized personal information prepared in a way that makes it not possible to identify a specific individual nor to restore that personal information, based on the laws, regulations, and so forth, and may continually provide the same to a third party with an explicit statement that the information is anonymized personal information.
The items of iInformation related to individualspersonal information included in the anonymized personal information that EA Pharma creates or provides, and the method of providing such anonymized personal information are set forth below.
（１）Items included in the iInformation related to personal informationindividuals:
information related to the body (date of birth, sex, body height, body weight, age, nationality, and so forth), medical information (disease information, medication information, examination information, hospitalization information, and so forth), and other information related to health condition
（２）The anonymized personal information will be provided by any of the following methods:
① Upload to a server
② Sending by an email
③ By DVDs or other external recording media
④ Posted on a website
９．Measures for managing the security of personal information
EA Pharma will take the necessary and appropriate measures for managing the security of personal information including prevention of the leaking, loss or damage of the personal information that EA Pharma handles. EA Pharma will exercise the necessary and adequate supervision over its employees as well as its outsourcing business partners (including subcontractors) who handle personal information. The main measures for managing the security of personal information are set forth below.
(Establishment of the basic policy - personal information protection policy）
In order to ensure the proper handling of personal information, EA Pharma has established the basic policy set forth in this Privacy Policy, which provides, among others, "compliance with relevant laws, regulations, guidelines, and so forth" and "contact point for inquiries and complaints".
（Development of rules for handling personal information）
EA Pharma has established the internal rules for handling method, duties and responsibilities of managers and persons in charge, and so forth, for each stage of acquisition, use, storage, provision, deletion and disposal, and so forth, of personal information, respectively.
（Institutional measures for managing the security of personal information）
In addition to appointing the personal information protection manager who is responsible for the handling of personal information, EA Pharma clarifies the access limits of personnel who handle personal information as well as the categories of information that the respective personnel handle, with a reporting system to the general manager responsible for personal information protection in case of identification of the fact or signs of any breach of the Act or the internal rules.
EA Pharma also regularly conducts self-inspections on the status of handling personal information and audits by other departments and external auditors.
（Personnel measures for managing the security of personal information）
EA Pharma provides employees with training about the matters that require attention when handling personal information on a regular basis. EA Pharma’s internal rules stipulate personal information confidentiality.
（Physical measures for managing the security of personal information）
In the areas where personal information is handled, entry and exit of employees are controlled, and there are restrictions on bringing equipment and devices, with preventive measures against unauthorize access to personal information.
EA Pharma has implemented the measures to prevent theft or loss of equipment, electronic media, documents, and so forth that contain personal information. When carrying such equipment, electronic media, and so forth, including within the workplace, preventive measures are taken against easy disclosure of personal information.
（Technological measures for managing the security of personal information）
Access control is implemented to limit the scope of database and so forth that include personal information as well as the personnel who are authorized to access the same. EA Pharma has introduced the process to protect the information system that handles personal information against unauthorized access from outside and malware.
（Understanding the external environment）
EA Pharma has implemented the measures for managing the security of personal information based on understanding of the personal information protection systems in the countries where personal information is stored.
１０．Requests for disclosure of personal information
When EA Pharma receives a request from the person or his/her agent for notification of the purpose of use, disclosure, correction/addition/deletion on the content, ceasing to use, deletion, ceasing to provide to a third party, or disclosure of records of provision to third parties, of personal information (hereinafter collectively referred to as "Disclosure and so forth"), EA Pharma confirms the identity of the person or the person’s agent by predetermined procedures and respond appropriately according to laws and regulations. If you have any questions or wish to exercise your rights regarding this Privacy Policy, please refer to the contact information in Article 11 below. When EA Pharma responds to your request for Disclosure and so forth, EA Pharma may ask you to bear a fee.
１１．Contact information
If you have any questions or complaints regarding the handling of personal information by EA Pharma, please contact:
（１）Address
Personal Information Consultation Desk, Compliance Promotion and Risk Management Department
EA Pharma Co., Ltd.
2-1-1, Irifune, Chuo-ku, Tokyo 104-0042
（２）Tel +81(0)80-7440-0699
（３）Reception hours Mon-Fri
(excluding Japan’s national holidays, Year-end and New Year holidays)
9:00 – 12:00, 13:00 – 17:00
１２．Others
All or part of this Privacy Policy may be changed. EA Pharma will announce any significant changes on EA Pharma’s website.
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