PRIVACY POLICY

INTRODUCTION

This Privacy Policy describes how Taiho Pharma Canada, Inc., (“Taiho”, “we” or “us”) collects, uses, discloses and protects personal information in connection with both our online and offline activities in Canada. It explains to healthcare professionals, patients, clinical study participants, customers and other individuals we interact with ("you" or "your"), how we collect, use, disclose and protect your personal information (excluding information about our employees). Personal information is information about an identifiable individual, as defined by applicable privacy laws. This Privacy Policy does not apply to information which is not considered personal information.

By using this website, and otherwise submitting or requesting information, you acknowledge that you understand, and agree with, the purposes for which your personal information is collected, used and disclosed, as well as the provisions of this Privacy Policy.

WHAT INFORMATION DO WE COLLECT?

Where possible, Taiho will collect personal information directly from you. However, in some circumstances, we may collect personal information from a third party who is authorized to disclose your information (such as a health care professional or insurance company). We may also collect information from publicly available sources. When personal information that has been collected is to be used for a purpose not previously identified, Taiho will notify you of that new purpose prior to that use of the information and obtain consent, as required.

Taiho collects various types of personal information including personal information about healthcare professionals, patients, clinical study participants and customers, including:

• names, titles, addresses, telephone numbers, email addresses and other contact information;
• information about healthcare professionals, such as areas of practice and interest; qualifications and professional credentials; publications; questions, comments or opinions about our products; and other information relevant to our relationships with healthcare professionals, whether collected by Taiho sales representatives pursuant to their interactions with healthcare professionals or otherwise;
• details about patients who use our products and their healthcare professionals. In certain circumstances, this may include the patient’s health or financial information in order to administer and provide patient support program or other services to them;
• information about patients participating in clinical trials as well as clinical trial data;
• adverse drug reaction details and related information; and
• other information which has been provided with your consent or else as permitted or required by law.

In addition, we may collect personal information about you via a Taiho website, including when we ask you questions or you communicate with us via e-mail. For example, we may collect information from healthcare professionals who register on our websites to verify licensure status. The type of information collected will be based on the specific program or service you register for.

We may provide opportunities to contact us to ask questions or provide comments, ideas, and/or suggestions. When you communicate with us and request a response, we may ask you for additional information such as your name, email address, and contact information. 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.

You can use many of our websites without telling us who you are or providing us with any personal information. However, depending on the website, you may not be able to access certain information or services unless you provide us with personal information. Whenever you submit information via the website, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy and the website’s Terms of Use. If you do not agree to these terms, please do not submit information via the website.

USE OF COOKIES AND OTHER TAGS

Where permitted by law, we automatically collect certain data through the standard operation of Taiho’s Internet service or through the use of passive information collection technologies, such as “cookies” or “Internet tags” and other similar techniques. If these technologies are used, your Internet browser automatically transmits to Taiho and/or our advertising partner(s) certain information to allow us to evaluate your interest in Taiho’s websites and perform other market research activities. We may collect and store certain information such as the name of the domain and host from which you access the Internet, the IP address of the computer you are using, the browser software you use and your operating system, the date and time you access our website, and the Internet address of the website from which you linked directly to our website.

Cookies are small text files a website can use to recognize repeated usage, facilitate the user's access to and use of the site, and allow a site to track usage behavior and compile aggregate data that will allow content improvement and targeted advertising. If you do not want information to be collected through the use of cookies, you may set such preference through user-enabled settings in most devices or browsers; however, some cookies may be required to provide you with certain features on Taiho’s websites and if you turn them off when you visit Taiho’s websites, you might find functionality of the website impaired.

Internet tags (also called web beacons) are tiny image files that are used to understand browsing activity. We may deploy cookies and tags and other technologies through services like, among others, Google Analytics, a web analytical service provided by Google, Inc. ("Google"), which collects and analyzes use patterns and other information about your use of a Taiho website. In such case, the third party’s privacy policy also applies. More information on Google Analytics can be found here: www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature.

DATA INTEGRITY AND SECURITY

Taiho takes reasonable steps to ensure that personal information collected is reliable, accurate and complete for their intended use. We use appropriate technical, administrative, and physical safeguards to protect information that pertain to you from loss, unauthorized access and, disclosure, misuse or alteration. In addition, we take steps to ensure that our safeguards take into account new known threats.

However, no organization can guarantee the absolute security of personal information. You should keep in mind that Internet transmissions, particularly email transmissions, are never 100% secure or error-free. Accordingly, we caution you to guard your own computer and password against unauthorized access by others.

HOW WE USE YOUR INFORMATION

The purposes for which Taiho may use personal information include:

• interacting and managing relationships with healthcare professionals, customers and other individuals in the course of our business;
• addressing and responding to comments, requests, inquiries or complaints about Taiho’s products or services;
• marketing Taiho’s products and services, including educational or other programs;
• providing Taiho’s products or services, including our patient support programs;
• research and product development;
• adverse drug reaction related activities;
• notifying individuals about product-related matters, including product recalls;
• generally managing our business, including to monitor the safety and efficacy of our products, defending and bringing legal actions, maintaining business records for reasonable periods, and for legal, regulatory, audit, insurance, security (including to prevent fraud) and processing purposes, including disclosing to regulatory agencies;
• considering individuals for potential employment; and
• as otherwise permitted in accordance with consent or else as permitted or required by law.

Taiho may also use your personal information to create aggregated information which does not allow you to be personally identified.

BUSINESS TRANSACTIONS

Your personal information may be used by Taiho and disclosed to parties connected with certain contemplated or actual business transactions, including financing, insuring, sale, assignment or other disposal of all or part of Taiho’s business or assets, including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction or business relationship and to fulfil reporting or audit requirements. Assignees or successors of Taiho or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

SHARING YOUR INFORMATION WITH THIRD PARTIES

Except in situations we have described in this Privacy Policy or after we have obtained your opt-in consent to do so, Taiho will not share your personal information with other entities for their own separate use. However, Taiho may retain service providers to collect, use, disclose, store or process personal information on Taiho’s behalf for the purposes described in this Privacy Policy. For example, when you provide personal information to Taiho, it may be accessible to some of Taiho’s service providers (including our affiliates acting in this capacity) or business partners to fulfill requests for information, answer telephone calls, provide assistance to us on specific programs or projects, or for reasons such as data processing, data warehousing and administrative services.

Taiho requires those entities to whom it shares personal information with to protect personal information using substantially similar standards that are used by Taiho. We also require that they not use your personal information for any separate use not specifically authorized by Taiho.

There may also be instances where Taiho is required to share your information with other entities who have not been retained by Taiho, such as with health authorities to report possible adverse drug experiences, pursuant to legitimate research and business purposes, during inspections or audits, in response to lawful requests by public authorities including to meet national security or law enforcement requirements, as ordered or directed by courts or other governmental agencies, or as otherwise permitted or required by law. Many entities receiving personal information under these conditions have privacy requirements that apply to their handling of your information.

In addition, Taiho may disclose aggregated information which does not allow you to be personally identified to third parties.

SHARING YOUR INFORMATION WITHIN THE TAIHO GROUP OF COMPANIES

The information that you provide to Taiho may sometimes be shared with other departments within Taiho, as well as Taiho subsidiaries and affiliates within the Taiho global group. Other departments within Taiho, and other companies with the Taiho global group, that may receive your information, will abide by substantially similar privacy requirements relating to your personal information.

SHARING PERSONAL INFORMATION OUTSIDE OF CANADA

Some of the third parties, service providers, affiliates or related companies that may collect, use, store or process your information may be located outside of Canada, including in the United States. As a result, your personal information may be transferred, stored, and/or processed outside Canada in connection with the purposes described in this Privacy Policy, and will be subject to the legal requirements of the foreign jurisdictions where the personal information may be transferred, stored, or processed (including being accessed by governmental authorities in those jurisdictions).

CONSENT

We collect, use and disclose your personal information with your consent or as permitted or required by law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to Taiho or its service providers, we either collect your express consent or assume you consent to the collection, use and disclosure of your personal information as outlined in this Privacy Policy. If you provide personal information about another person to us, we assume that individual consents to the collection, use and disclosure of their personal information as outlined in this Privacy Policy, or that you are authorized to provide their personal information. There may be circumstances where legal, medical, or security reasons make it impossible or impractical for Taiho to have consent and, in such circumstances, personal information might be collected, used, or disclosed without the knowledge or consent of the individual.

If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered. You may withdraw your consent to our further collection, use and disclosure of your personal information by sending a written request to Taiho’s Privacy Officer at the address below. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide you with certain information, products, or services. Also, under some circumstances, you may not be permitted to withdraw consent to certain uses and disclosures of personal information you originally consented to.

CORRECTING, ACCESSING AND EXERCISING CHOICE REGARDING YOUR INFORMATION

We offer individuals the option to choose (opt-out) whether their personal information is (a) to be disclosed to another entity or (b) to be used for a different purpose(s) than which it was originally collected or subsequently authorized by the individual. For sensitive information (i.e. personal information specifying medical or health conditions, racial or ethnic origin; etc.), individuals are given affirmative or explicit (opt in) choice if the information is to be disclosed to another entity or used for a purpose other than that for which it was originally collected or subsequently authorized by the individual through the exercise of opt in choice.

Taiho strives to ensure that any personal information we maintain is sufficiently accurate, complete and up to date, but we do not routinely update personal information unless required to fulfill the purposes for which it was collected.

Taiho maintains a file of personal information for individuals for the purposes described in this Privacy Policy, which will be accessible at the address provided in the contact information section below. Authorized Taiho employees, agents and mandataries may have access to your personal information. To protect your information from unauthorized access by others, all requests to update or access your information will be subject to verification of your identity. Please submit any request for access to, or correction of, your personal information that we have in our custody or control, or requests about our personal information practices, to privacyofficer@taihooncology.com or by postal mail at the contact information listed below. We will respond to your request to access within 30 days.

LINKS AND EXTERNAL WEBSITES

Many of Taiho’s websites contain links or references to third-party websites as a convenience to you. This Privacy Policy does not cover the practices of those websites. Accessing those sources requires that you leave Taiho’s websites. Taiho does not control the content of these third-party websites and is not responsible for the privacy practices of those websites. Please review the privacy policies on each website that you visit.

CHILDREN'S ONLINE PRIVACY

Taiho’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. If your child has submitted personal information and you would like to request that such information be removed, please contact privacyofficer@taihooncology.com.

DATA RETENTION

Taiho retains personal information we collect during clinical studies that we process on behalf of our customers for as long as needed to provide Service to our customers, subject to our compliance with this Privacy Policy. We may further retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

UPDATES TO PRIVACY STATEMENT

The foregoing terms are effective as of Oct 15, 2020. Taiho 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. Taiho reserves the right to modify, add, or remove portions of this Privacy Policy at any time at our sole discretion. If we decide to materially revise this Privacy Policy, we will post the revised Privacy Policy at this site. We encourage you to review the Privacy Policy each time you visit our site. 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

If you have any questions about our Privacy Policy, its implementation, the accuracy of your personal information, our privacy practices, or the use of the information collected, please contact us at:

Taiho Oncology, Inc
Privacy Officer
101 Carnegie Drive, Suite 101
Princeton, New Jersey 08540
Phone: (609) 285-5214 Toll Free: 1-844-688-2446
privacyofficer@taihooncology.com