This Privacy Notice contains important information about how our company Kyowa Kirin Pharma s.r.o., company ID no. 06583521 (“KKP”) collects, uses and protects your personal data. This Privacy Notice applies to processing of your personal data on this webpage. In certain situations, during cooperation with our company there may be other processing, for which we will provide you with other privacy notices.

Who are we?

KKP is part of the Kyowa Kirin Group made up of different legal entities, details of which can be found here.

KKP is a "data controller" of the personal data. This means that we are responsible for deciding how we hold and use personal information about you.

What personal data do we collect?

Personal data means any information, which on its own or connected with other information, allow your identification.

We may collect, use, store and transfer different kinds of personal data about you. What information we collect, use, store or otherwise process will depend on your interactions with us.

Below, we have grouped together the types of information that we may collect from you as follows:

  • Identity Data including name, gender, date of birth, marital status, family members, occupation, professional registration number;
  • Contact Data including home address, business address, email address, phone numbers;
  • Financial Data including bank account details;
  • Transaction Data including details about payments to and from you;
  • Technical Data including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Usage Data including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
  • Communications Data including any phone number used to call us and your preferences in receiving communications from us;
  • Profile Data including your username and password, preferences, feedback and survey responses.

How do we collect your personal data?

  • From you. You may give us such information directly, for example by registering with us, completing forms, corresponding or speaking with us by phone, email, letter or otherwise, submitting a query, providing us with feedback about a product, visiting our website, requesting that we provide you with services / communications, or when we appoint you as a service provider.
  • By collecting.
    • When you visit our website and receive e-mails from us we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this by using cookies.
    • Personal data provided by cookies.
      • Cookies are small files saved to the user's hard drive that track, save and store information about the user's interactions and usage of the website. This allows our website, through its server, to provide users with a tailored experience.
      • If you wish to prevent the use and saving of cookies from this website on to your computer's hard drive, you should take necessary steps within your web browser's security settings to block all cookies.
      • Our website uses tracking software to monitor its visitors to better understand how you use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to the user's hard drive in order to track and monitor engagement and usage of the Website, but will not store, save or collect personal information. You can read Google's privacy policy here for further information.
      • Other cookies may be stored on your hard drive by external vendors when our website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer.
    • When we e-mail you, such e-mails may contain tracking facilities. Activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but is not restricted to: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.
    • We may receive information about you if you use any of the other websites we operate or the other services that we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
  • From third parties
    • We may receive information about you from healthcare professionals or pharmacies as a result of an adverse event report or complaint.
    • We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
    • We may receive information if you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal data, you should check their privacy notices carefully.
    • We may take information from publicly available sources (where possible) to keep your information up to date, for example, from public registers.
    • We may occasionally purchase the contact details of people who might be interested in hearing from us. Before purchasing such information, we will check with the vendor that your information was originally collected in a compliant manner, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.
    • We may receive information about you if you apply for a vacancy at KKP.

For what purposes we process your personal data?

We use information held about you in the following ways:

  • To manage and administer our relationship with you
  • To conduct clinical trials
  • To carry out our obligations arising from any contracts entered into between you and us
  • To respond to your requests
  • To provide you with information about our activities or tailored information about a programme that you have signed up to
  • To improve our level of service
  • To notify you about changes to our service and notify you of new products and services
  • To seek your views on our products and services
  • To consider your application for employment
  • For administrative and quality assurance purposes
  • To ensure that content from our website is presented in the most effective manner for you and for your computer
  • For the purposes of the establishment, exercise or defence of legal claims.
  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • To provide and improve our site to ensure that content is presented in the most effective manner for you and for your computer
  • To allow you to participate in interactive features of our service, when you choose to do so as part of our efforts to keep our site safe and secure
  • To manage and follow up on Adverse Events reports
  • To record, investigate and respond to complaints

What is our legal basis for processing your personal data?

We may process your personal data only when we have a lawful reason for doing so.

  • Legitimate interest

    • One of lawful reasons is called ‘legitimate interest’ and means that we can process your personal data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your interests or fundamental rights and freedoms of the data subject which require protection of personal data.

    Our aim is the development and commercialisation of innovative medicines for the treatment of unmet therapeutic needs.

    We will use your personal data in order to help us achieve those goals and to give you the most appropriate information, products and services and to provide you with the best experience when dealing with us.

    Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.

Other legal bases that we will rely on include the following:

  • If you purchase a product or service from us, we may process your personal data in order to fulfil our contract with you.
  • If we are providing you with e-mail communications, we will only do so with your consent, unless you have purchased services from us, in which case we may rely on our legitimate interests to contact you further, in accordance with information under “Commercial Communication” below.
  • Where we are required to comply with our legal obligations.
  • To establish and defend our legal rights, or to prevent and detect crimes such as fraud, based on our legitimate interest.

Commercial communications with you

In case we provided you with services or product, or if we have your consent, we may e-mail you to provide you with information about our activities and products and services supplied by us. You can un-subscribe at any time through an automated system. This process is detailed at the footer of each email. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will be detailed instead.

We may occasionally, with your consent, call you to provide you with information about our activities or provide you with information about products and services supplied by us. You may unsubscribe to calls by instructing the person calling you or by contacting us at any time on the details set out in the ‘Contact Us’ section of this notice.

We may also communicate with your through postal marketing when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our services, products and other activities and those of other carefully selected organisations. You have the right to contact us at any time and opt-out of receiving postal communications.

Profiling

We may use profiling and screening methods to produce relevant communications and provide you with a better experience.

To do this we may use additional external sources of data to increase and enhance the information we hold about you (address and other contact details).

If you do not wish for your information to be used in this manner or have any queries about how we use your information, you can contact us on the details provided in the ‘Contact us’ section of this notice.

You will always have a right to object against processing of your personal data, if such processing is based on our legitimate interest, including profiling. Based on your objection we will not be processing your personal data for such purposes, unless we prove that we have demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of our legal claims.

How long will we hold your information for?

We process your personal data for as long as is necessary to fulfil the purposes that we collected it for, and as long as we have legal basis for processing.

By law, we are required to retain certain information for a prescribed period of time, particularly in connection with our accounting and tax obligations.

To determine the appropriate retention period, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we are processing your personal data and whether we can achieve those purposes through other means.

Therefore, some information may be kept for more or less time depending on how long we reasonably feel it is required for.

We review our retention periods for personal data on a regular basis.

When we anonymise your personal data (so that it can no longer be associated with you), we may process them without further restrictions. We use such anonymised data mainly for research or statistical purposes.

If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.

Who we might share your information with?

KKP will not under any circumstances sell your personal data to any third parties.

We may share your personal information with any member of our Kyowa Kirin group where we have a legal basis for doing so.

We may share your information with selected third parties including:

  • When we use other companies to provide services on our behalf, e.g. answering questions about products or services, sending mail and emails, patient analysis, assessment and profiling and when using auditors or other professional advisors.
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • IT service providers.
  • Clinical Research Organisations.
  • Healthcare Professionals.
  • If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register.

If we merge with another organisation or form a new entity, your personal data may be transferred to that new entity. We will inform you of such change.

We may disclose your personal information to third parties to:

  • Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies;
  • Enforce or apply our terms of use and any other agreements;
  • Protect the rights, property, or safety of us, our employees or others. This may include exchanging information for the purposes of criminal offences prevention.

International transfers of personal data

KKP as a member of international enterprise that consists of numerous entities worldwide, the data that we collect from you may be transferred to, and stored at, a destination outside the European Union ("EU") for the purposes described in this policy, in particular to our parent company Kyowa Hakko Kirin in Japan. Transfer of your personal data to Japan is provided under Commission Implementing Decision (EU) 2019/419 of 23 January 2019 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by Japan under the Act on the Protection of Personal Information.

For a list of the other entities that your personal data may be shared with, please see http://www.kyowa-kirin.com/about_us/worldwide_locations/index.html#pharmaceuticals.

It may also be processed by staff operating outside the EU who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services.

Data may be transferred to and hosted by a third-party IT service provider in the countries outside of the EU as part of selected ‘Cloud’ services adopted by Kyowa Kirin International for the purposes of carrying out normal business practices. We may also share your data with other selected unaffiliated service providers or consultants acting on our behalf, such as external marketing agencies, speciality advisory services or lawyers.

If we do this, your personal information will continue to be subject to one or more appropriate safeguards set out in the law, for example we may use model contracts in a form approved by regulators. You can find more information about model contractual clauses here. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you or if you wish to participate in a programme and you fail to provide that data when requested, we may not be able to perform the contract we have with you or permit you to participate in the programme. If this is the case, we will notify you at the time.

Your rights

You have a number of rights. If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section. If you exercise any of these rights, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances that we will inform you about (for example unfounded repetitive request).

Your rights include:

  • transparency over how we use your data and to make a subject access request (right of access);
  • a right to withdraw consent to our use of personal data, where you have previously given us consent. Please, be advised that withdrawal of consent applies for the future and it does not affect previous processing (right to withdraw consent);
  • a right to have your personal data updated and corrected (right of correction/rectification);
  • a right to ask us to delete your information, when we are not entitled to process them (right to be forgotten);
  • a right to ask us to stop processing your information in certain situations (right to restriction);
  • a right to object to (i) processing based on our legitimate interests; (ii) processing of your information for direct marketing purposes; and (iii) automated decision making and profiling (right to object);
  • right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (right not ot be subject to automated individual decision-making).
  • a right to receive a copy of your information in a readable format, and/or have this sent to a different controller, if technically feasible (right to data portability); and
  • a right to claim compensation for material or non-material damage caused if we breach the data protection rules (right to compensation).

You also have the right to lodge a complaint with the data protection regulator, the Office for Personal Data Protection, if you have concerns about how we use your personal information. You can contact the Office at: https://www.uoou.cz/en/

How you can access and update your information

We strive to maintain accurate, complete, and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it. It is important that the personal information we hold about you is accurate and current.

What security precautions we put in place to protect against the loss, misuse or alteration of your information?

To prevent your personal information from accidental loss and from unauthorized access, use, alteration and disclosure, we have implemented reasonable measures designed to secure your personal data. Details of these measures can be obtained on your request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our security measures are regularly reviewed.

Contact Us

If you have any questions regarding this policy or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact us at:

  • E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
  • Address: Senovážné náměstí 992/8, Praha 1, 110 00, Czech Republic

Contact of our Data Protection Officer (communication in English):

  • E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
  • Post: Kyowa Kirin International Ltd, Head Office, Galabank Business Park, Galashiels, TD1 1QH, United Kingdom and marking your query for the attention of The Data Protection Officer
  • Telephone: +44 1896 664 0000

This policy was last updated on 1.9.2020. We may change this Privacy Notice following actualization of our processing procedures.