Sumitomo Pharma (“We”) respect your privacy rights and value the protection of your personal information (“Personal Information”). This Sumitomo Pharma Personal Information Protection Policy (“Personal Information Protection Policy”) aims to introduce to you how we collect and process your Personal Information and how you can exercise your data subject’s rights when you visit our website at www.sumitomo-pharma.com.cn (“Website”), use our other resources (when you use our WeChat public account, contact us via our hotline etc.), participate in our activities and interact with us through other means, and use our products or services or provide products or services to us or otherwise cooperate with us.
Under certain specific circumstances, we may provide you with other separate personal information protection policies regarding these specific circumstances, to inform you of how we collect and process your Personal Information under such circumstances. Related provisions in this Personal Information Protection Policy shall also apply to such circumstances, unless other separate personal information protection policies explicitly exclude the application of this Personal Information Protection Policy. If there is any conflict or inconsistency between other separate personal information protection policies mentioned above and this Personal Information Protection Policy, such separate personal information protection policies shall prevail in principle (unless otherwise mentioned or agreed upon).
This Personal Information Protection Policy is formulated according to the applicable Chinese data protection laws and regulations. “Personal Information” in this policy refers to all kinds of information recorded electronically or otherwise that are related to an identified or identifiable natural person, excluding information after anonymization. Personal Information includes Sensitive Personal Information specified in Chinese data protection laws and regulations, namely the Personal Information that once leaked or used illegally, may easily infringe on the personal dignity of natural persons or endanger personal or property safety, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts tracking, as well as the Personal Information of minors under the age of 14. We will only process your sensitive personal information when we possess a distinct objective and ample necessity and with your individual consent. We will take strict protective measures to safeguard the security of such information.
If you have any questions or concerns about how we use your Personal Information, please contact us using the contact details provided at the bottom of this Personal Information Protection Policy.
This Personal Information Protection Policy will explain the following information to you:
1. How We May Collect Your Personal Information
2. How We May Process and Share Your Personal Information
3. Notice on Cookies and Related Technologies
4. Personal Information of HCPs
5. Personal Information of Minors
6. Cross-border Provision of Personal Information
7. How We Protect Your Personal Information
8. How We Store Your Personal Information
9. Your Data Subject’s Rights and Choices
10. Update of This Personal Information Protection Policy
11. How to Contact Us
1. How We May Collect Your Personal Information
In general, we will only use the Personal Information we collect for the purposes set out below or as we have informed you at the time we collect the Personal Information from you. However, where permitted by law, we may also use your Personal Information for other new purposes that do not conflict with the purposes we have previously communicated to you.
Corporate Operations and Business
We may use your Personal Information for our day-to-day corporate operations and business purposes, payment processing and financial account management, contract management, due diligence, website management, fulfillment of corporate governance and reporting obligations. In this condition, we may collect:
1. Your direct personal identifiers and contact information, including your name, gender, ID number, mailing address, telephone number, email address, workplace, department, position, third-party platform user identifiers and nicknames, educational background and work experiences;
2. Your financial-related information, including your bank account and issuing bank, credit card number and issuing bank, payment records;
3. Relationship data, including information about products, treatments and health conditions of interest to you, as well as whereabouts tracking, access logs, usage habits, and feedback related thereto;
4. Registration information, including your username and password generated by registering an account on our platform.
Business and Product Development, Management and Optimization
In order to discover new facts to help us better understand our customers’ needs and to help develop, improve and evaluate product services, quality, materials, plans and programs, we analyze Personal Information to improve and optimize our business and products. In this condition, we may collect:
1. Your direct personal identifiers and contact information, including your name, gender, ID number, mailing address, telephone number, email address, workplace, department, position, third-party platform user identifiers and nicknames, educational background and work experiences;
2. Your health-related information, including information about your health status (including date of birth, age or age group, whether you (or your spouse) are pregnant, race, height, weight, medical history, suspected drugs or drug combinations, adverse effects, and other necessary health information), safety and health information related to any of our products, or insurance and statistical information.
Communication with You and Handling Your Requests
We may also use your Personal Information to provide you with the services you request or to manage our products and services. This means that we may use your Personal Information to respond to your inquiries, provide you with the services you request, provide you with the best customer experience, fulfill our contractual obligations to you, or act on your consent. In this condition, we may collect:
1. Your direct personal identifiers and contact information, including your name, gender, ID number, mailing address, telephone number, email address, workplace, department, position, third-party platform user identifiers and nicknames, educational background and work experiences;
2. Your financial-related information, including your bank account and issuing bank, credit card number and issuing bank, payment records;
3. Relationship data, including information about products, treatments and health conditions of interest to you, as well as whereabouts tracking, access logs, usage habits, and feedback related thereto;
4. Registration information, including your username and password generated by registering an account on our platform;
5. Income and demographic information, including information collected when you request financial support for the purchase of our products.
Benefits and Recruitment Activities of the Company
We may have various benefit programs and activities for our employees’ families and friends, so we may use your Personal Information for benefit programs, corporate events and insurance programs related to our employees’ families and friends. We may also use your Personal Information as necessary in the course of your proposed employment relationship with us, including verifying your basic identification information, investigating your compliance with laws, regulations and company rules and regulations, for qualification and credit reporting, for training and learning, for investigation and evaluation, pushing information about jobs that are of interest or match you, and sharing such Personal Information with our affiliated companies. In this condition, we may collect:
1. Your direct personal identifiers and contact information, including your name, gender, ID number, mailing address, telephone number, email address, workplace, department, position, third-party platform user identifiers and nicknames, educational background and work experiences;
2. Information related to corporate benefits and recruitment, including the name, gender, ID number, telephone number, health status, emergency contact and other relevant information about employee’s family members and/or friends collected when you participate in our benefits program for employees, the name, gender, mailing address, telephone number, educational background, work experiences and other relevant information about the candidates you refer to us.
Legality and Compliance
We may process your Personal Information in accordance with laws and regulations (e.g., laws and regulations related to pharmacovigilance, laws and regulations related to the filing of pharmaceutical medical representatives, laws and regulations related to personal income tax laws, laws and regulations related to anti-corruption investigations in the healthcare industry, administrative or judicial requirements of state authorities such as courts or arbitration institutions, etc.). We may also use Personal Information to monitor compliance with our policies and procedures, to prevent fraud, and to investigate and prosecute individuals who violate our rules or engage in conduct that is unlawful or harmful to other persons or property of others.
2. How We May Process and Share Your Personal Information
In the course of our activities, we will only entrust to handle, share, disclose or transfer your personal information under lawful, reasonable and necessary conditions.
● Affiliates;
● Third-party vendors;
● Business and research partners;
● Disclosures to relevant authorities to fulfill legal obligations and for product safety purposes;
● Disclosures to subsequent owners or operators.
We do not sell Personal Information to any third parties. If we need to share, disclose or transfer your Personal Information with a third party, we will inform you in advance of the name of the recipient, contact information, purpose of processing, processing means and type of Personal Information, and obtain your separate consent in advance.
Affiliates
As a multinational corporation, Sumitomo Pharma may transmit or provide your Personal Information to its affiliates located in countries or regions within or outside of the People’s Republic of China after evaluation. We will take reasonable measures to ensure that the transmission of your Personal Information complies with Chinese laws and regulations and is securely protected.
Third-Party Vendors
We (including our affiliates) may establish commercial relationships with various third-party vendors. These vendors help us operate our business and, in the course of providing services to us, they may need to access your Personal Information. Types of vendors may include customer service and support, technology vendors, data analytics companies, third-party content platforms, event agencies, media service providers, vendors managing adverse event reporting, and professional advisors (e.g., lawyers, accountants, auditors). We require them to process your Personal Information collected through us in accordance with appropriate contractual privacy and security provisions.
Business and Research Partners
We may partner with other companies and public and private organizations to provide products, content, or services to you on a joint basis. You should be aware that in such cases, the privacy statements of the relevant partners may apply in addition to this Personal Information Protection Policy and, in limited circumstances, there may be shared privacy statements.
For jointly offered forms and websites, you will find the display of both our logo and the logo of the joint partner. You should also read our joint partners’ personal information protection policies, as they may differ from ours in some respects.
Disclosures to Relevant Authorities to Fulfill Legal Obligations and for Product Safety Purposes
If you contact us about your experience with our products, we may use the information you provide to us to file our reports with the drug regulatory authorities in the country or region where we are located, other similar health and drug government agencies around the world, and as otherwise required by law. We may also use this information to contact your prescribing physician to follow up on safety-related events involving the use of our products.
In certain limited circumstances, we may need to disclose your Personal Information to comply with legal obligations, processes or requirements, and for reasons of public interest, including complying with obligations to report to regulatory agencies about the safety of our products, or responding to public health or other emergencies, responding to subpoenas, or meeting national security or law enforcement requirements.
Disclosures to Subsequent Owners or Operators
We may transfer your Personal Information to a successor entity, a purchaser of all or a portion of our assets, when a merger, consolidation or other corporate reorganization occurs, or transfer your Personal Information under a financing arrangement or joint promotional agreement. We may transfer Personal Information about you to all parties to the transaction based on our legitimate interest in preparing and completing the transaction. We will notify you of the name and contact information of the successor entity. Any successor entity shall be subject to terms and conditions reasonably similar to this Personal Information Protection Policy, or the successor entity will need to obtain your consent again.
When you visit our Website or use other web resources, we may automatically collect certain information from your device. Specifically, the Personal Information we collect automatically mainly includes your IP address, device model, unique device identification number, browser model, general location information (country or city information), and other technical information. We may also collect information about how your device interacts with our Website or other web resources, including pages visited or links clicked.
Collecting the above information allows us to better understand the visitors to our Website or other web resources, such as where the visitors come from and what content attracts visitors to our Website or other web resources. We use the above information for internal analysis and for purposes related to improving the quality of our Website or other web resources. We also need to keep appropriate logs to record the operating status of our Website or other web resources to comply with Chinese laws and regulations.
These information are generally collected through our use of Cookies or similar tracking technologies. For your convenient visiting experience, we may send small data files called Cookies on your computer or mobile device to identify you when you visit our Website or use other web resources. We send Cookies to you to simplify the process of repeatedly entering information to log in to your account, to store your preferences, to help determine your login status, and for account or data security purposes, with the goal of providing you with the most user-friendly and secure service. We do not use Cookies for any purpose other than those described in this Personal Information Protection Policy, and the Cookies we send you are unique and can be managed or deleted according to your preferences. You can clear all cookies stored on your computer or mobile device, and most web browsers have a feature that blocks Cookies, and you can usually modify your browser settings to reject Cookies according to your needs, but if you do so, you may need to personally change your user settings each time you visit the Website or other web resources, which may affect your safe access to our Website or services offered by other web resources.
4. Personal Information of HCPs
As described in this section, if you are a health care professional (“HCP”), we may collect certain categories of Personal Information about you. We may also use and disclose Personal Information about HCPs for other purposes described in this section. The categories of collected Personal Information described in this section and the purposes for which they are used and disclosed are in addition to any other collection, use and disclosure practices of Personal Information described separately in this Personal Information Protection Policy.
Personal Information We May Collect About HCPs
If you are an HCP, we may collect your Personal Information directly from you, or from third-party sources, including the organization where you work, publicly available sources, interactions with us (including online available sources), and participation in programs we sponsor or support (our sponsored clinical research and development activities, third-party databases, and pharmacovigilance event reporters).
We may collect the following categories of Personal Information about HCPs:
● Detailed professional information, resumes or other documents or forms provided directly to us, practice locations, positions, professional contact information, medical specialties, professional license numbers, professional qualifications and scientific activities (past clinical trial experience, activities on social media platforms or other websites, and participation in past or pending research investigations held by us and others), organizational or institutional affiliations, academic or scientific research and publication of articles, and membership in associations and boards of directors
● Personal Information provided for participation in programs we sponsor or support, clinical development activities we sponsor, online or on-site seminars for product information, educational events and clinical information updates
● Details of interactions with us, meetings we hold, topics discussed, your knowledge and questions about our business and products, the types of materials we present to you, any feedback you provide, and your opinions and practices regarding the use of relevant medications, practices regarding your patients, diagnoses, and automated tracking information from online interactions with us
● Details of payments and other transfers of value received from your interactions with us, which may include your ID number, copy of ID card, issuing bank, bank account number (where required or permitted by law)
Other Uses and Disclosures of HCPs’ Personal Information
We may use and disclose Personal Information about HCPs for the following other purposes:
● To perform our contract with you
● To manage and improve our relationship with you, including planning, organizing and reviewing any collaboration with you and contacting you
● To help ensure that we provide you with relevant information based on your expertise and interest in the field of academic research
● To recruit and assess the suitability of medical professionals to participate in clinical trials and market research and other studies
● To conduct market and research studies in public and private sectors
● To communicate with you about our products and programs (subject to any additional marketing consent requirements), to communicate with you about scientific or educational programs, to manage our patient support programs, and to provide you with access, to respond to product orders, and to provide product samples, if necessary
● For research and analytical purposes in the development and evaluation of our products, services, materials and treatments
● For internal accounting and analysis related to our internal policies and rules
● For security monitoring, reporting and auditing and for responding to inquiries or questions regarding our products
● To comply with applicable laws and regulations, including the requirements of industrial codes of conduct for the collection and public disclosure of payment and other value transfer data to HCPs, and to comply with applicable local consent requirements for the disclosure of such data in a manner that identifies HCPs individually or in response to public health or other emergencies
5. Personal Information of Minors
Please note that, unless otherwise indicated, the Company’s website and other online resources are intended primarily for adult users. We do not intentionally collect and process Personal Information of minors under the age of 14. For specific business purposes, we may collect Personal Information of minors with the authorization of their parents or guardians (including adverse drug reactions reported in minors and children of minor's Personal Information used for benefit programs related to employees’ families).
If you're a minor, please ensure that your parents or guardians read this Personal Information Protection Policy and obtain their consent before disclosing any Personal Information to us
If you, as a parent or guardian of a minor, provide us with Personal Information about the minor, before providing us with such data, please read and understand this Personal Information Protection Policy or any other information that we inform you of before collecting Personal Information from you.
If you are a parent or guardian of a minor under the age of 14 and have questions on how we process minors’ Personal Information, please contact us using the contact information provided in “How to Contact Us” in this Policy.
6. Cross-border Provision of Personal Information
We may transfer Personal Information overseas as described in this section. If we provide your Personal Information to any recipient outside of China, we will inform you of the name of the overseas recipient, the contact information, the purpose of processing, the processing means, the type of Personal Information, and the manner and procedure for you to exercise your rights under relevant laws and regulations to the overseas recipient, and, where appropriate, obtain your separate consent.
Transfers among Group Companies
To provide you with our products or services or to establish a business relationship with you, to better interact, conduct business cooperation and academic communication with you, to deal with your inquiries and complaints, and to fulfill our requirements for these business administration and compliance records, your Personal Information may be provided by us to, transferred to, and processed by our parent company in Japan and the Sumitomo Pharma Group’s subsidiaries or affiliates in other countries/regions. Please refer to https://www.sumitomo-pharma.com/profile/office/ for a complete list of the Sumitomo Pharma Group’s subsidiaries and affiliated companies. Our transfers within group companies are made in accordance with applicable data protection laws (including, where required by applicable law, in accordance with your consent and cross-border data transfer agreements). We have implemented a number of intragroup cross-border data transfer agreements covering the transfer of Personal Information among all subsidiaries and affiliated companies of the Sumitomo Pharma Group to ensure that the Personal Information relating to you maintains the same level of protection as in your country/region of residence.
Transfers to Third-Party Vendors and Partners
We may also transfer and process your Personal Information to vendors, commercial and business partners in other countries or regions. Any cross-border transfers of Personal Information to third parties (including in countries/regions other than the country in which the Personal Information about you was collected) will be made in compliance with the applicable cross-border data transfer restrictions and requirements under data protection laws (including, where appropriate, obtaining your separate consent and using data transfer contracts for cross-border transfer of Personal Information) to ensure that the Personal Information relating to you maintain the same level of protection as in your country/region of residence.
Transfers to Regulatory Bodies
Our products may be marketed in various countries and regions around the world. To ensure the safety of our products, we may submit the adverse event information you have provided to regulatory bodies in other countries or regions where the products have been marketed.
7. How We Protect Your Personal Information
We use appropriate technical and organizational measures to protect the Personal Information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. However, please be aware and understand that we cannot ensure an absolutely secure network. If you find that your Personal Information is breached, please contact us using the contact details provided in “How to Contact Us” immediately so that we can take corresponding measures.
In the event of any accident, force majeure event, or other circumstances leading to the breach of your Personal Information, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and you can take and other relevant information. In the event of a security incident related to Personal Information, we will report to the competent authorities in accordance with the requirements of relevant laws and regulations, promptly investigate the problem, and take emergency measures.
Our Website, WeChat, or other web resources may contain links to other third-party websites, and we are not responsible for the collection and processing of your Personal Information by such third-party websites.
8. How We Store Your Personal Information
Retention Location: Generally, we will store your Personal Information in China. In order to provide you with our products or services or to establish a business relationship with you, to better interact with you and communicate with you commercially and academically, to handle your inquiries and complaints, and to meet our business management and compliance record requirements for these interactions, we will allow the storage of your Personal Information by the relevant overseas entities, as described in the “Cross-Border Provision of Personal Information” section of this Personal Information Protection Policy.
Retention Period: Except as provided otherwise by laws or regulations, we will retain your Personal Information for the following periods:
We will store your Personal Information only to the extent as necessary to our proper business needs (including the purposes of providing services to you, or complying with legal, tax and financial requirements), the specific consideration factors are as follows:
● The required period for us to provide our products and/or services to you;
● Ensure the safety and quality of the products and/or services we provide to you;
● Whether you agree to a longer retention period;
● Retention period meeting the purposes of this Personal Information Protection Policy;
● Whether there are any other special agreements or legal and regulatory provisions for the retention period.
When there is no such business need to use your Personal Information or the retention period stipulated by Chinese laws or regulations expires, we will delete or anonymize your Personal Information.
9. Your Data Subject’s Rights and Choices
Unless otherwise provided by laws and regulations, you have the following data subject’s rights:
● You have the right to know and decide on the processing of your Personal Information, and you have the right to restrict or refuse our processing of your Personal Information;
● You have the right to access and copy your Personal Information;
● If you find that your Personal Information is inaccurate or incomplete, you have the right to request us to correct and supplement them;
● You have the right to withdraw your consent for personal information processing activities based on your consent. If you withdraw your consent, it does not affect the validity of the personal information processing activities already carried out based on your consent before the withdrawal;
● You have the right to request the transfer of Personal Information to another personal information processor designated by you;
● You have the right to ask us to explain the relevant personal information processing rules;
● You have the right to request us to delete your Personal Information in the following specific circumstances;
(1) If our processing of Personal Information violates laws and regulations;
(2) If we collect and use your Personal Information without your consent;
(3) If we process Personal Information in violation of our agreement with you;
(4) If you no longer use our products or services, or if you de-register your account; or
(5) If we terminate our services and operations.
When you delete your data from our services, we may not immediately delete the corresponding data in our backup system, but we will delete such information when the backup is updated.
If you have any objections to the personal information processing activities conducted by us and this notice, you have the right to contact us using the contact information provided in “How to Contact Us” in this Policy.
We will respond to requests from you to exercise your rights in accordance with the requirements of applicable data protection laws within the required time limit. To the extent as permitted by laws and regulations, we may not be able to respond to your request to exercise your rights in the following circumstances:
● If your request is contrary to our obligations under laws and regulations;
● If the requested data is directly related to national security, national defense security;
● If the requested data is directly related to public safety, public health, or significant public interest;
● If the requested data is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.;
● If we have sufficient evidence of your subjective malice or abuse of rights;
● If it is in the interest of safeguarding your or other individuals’ significant legitimate rights and interests, such as life and property, but it is difficult to obtain your authorization or consent;
● If responding to your request to exercise your rights would result in serious harm to your or other individuals’ or organizations’ legitimate interests;
● If the requested data involves trade secrets.
10. Update of This Personal Information Protection Policy
We may update this Personal Information Protection Policy from time to time in response to changing legal, technical, or business developments. When we update our Personal Information Protection Policy, we will take appropriate measures to inform you, depending on the significance of the changes we make. We will obtain your consent to any material changes to this Personal Information Protection Policy if and where this is required by applicable data protection laws.
You can see when this Personal Information Protection Policy was effective by checking the “Effective Date” displayed at the end of this Personal Information Protection Policy. If you continue to use the functions on our Website or contact us through the contact information shown on the Website, you are deemed to have accepted the updated Personal Information Protection Policy.
11. How to Contact Us
If you have any questions or concerns about how we process your Personal Information and this Personal Information Protection Policy, especially if you consider that our processing of your Personal Information impairs your legitimate interests, please contact us by sending email to privacy.support@sumitomo-pharma.com.cn. We will review your problem without delay and make a timely reply according to the applicable laws and regulations.
Last updated in July 2024
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