Depending on the purpose, we would collect certain types of your data, which could include the followings:

• General data: name, email address, phone number, postal address, date of birth, age, gender, nationality, etc.

• Profession & Employment: title, department, responsibilities, workplace, recruitment/termination date, working conditions, performance evaluation, etc.

• Financial details: bank account numbers, credit/debit card numbers, expenses, income, pensions, insurance, etc.

• Identification data: passport number, driver’s license number, employee ID, patient ID, etc.

• Image & Sound recordings: CCTV footage, video recording, photograph, tape/telephone recording, etc.

• Data collected through your use of our website: IP address, your browser type, the device you use to access the site, etc.

• Health data: medical record, treatment data, blood sample, biometric data, DNA data, diet, lifestyle habit, etc.

• Sensitive Data not included the above: religious/philosophical belief, racial/ethnic origin data, membership of trade union, etc.

You directly provide us with most of your data we collect. However, in some cases, we may collect your data from the following sources:

• Other Santen group companies

• Publicly available data sources, such as social media or any other data disclosed on the Internet, industry magazines, etc.

• Any other third parties, including healthcare providers, healthcare authorities, CRO, conference service providers, recruit agencies, financial institutions, a private dataset/databank service provider, etc.

• Automatic collection, through your use of our websites, or view of our advertisements

We use your data only for the specified purposes of which we inform you in advance through this privacy policy or any other supplemental policies or notices. Depending on how you interact with us, we use your data for various purposes, including:

• To communicate with you

• To provide you with our products and services, including:

  • to carry out obligations arising from any agreements,

  • to deliver our products,

  • to perform inspections and maintenance of our products, and

  • to access to our online service and application.

• To conduct research and development of products or services, including:

  • to carry out clinical trials,

  • to carry out medical and pharmaceutical researches, and

  • to develop drugs, medical devices and other products or services.

• To improve our products and services, including:

  • to conduct surveys or questionnaires,

  • to confirm the effectiveness of our promotional campaigns, and

  • to carry out market researches.

• To ensure drug safety and effectiveness, including:

  • to respond to reports of a possible adverse event, and

  • to take actions following legal and regulatory obligations.

• To provide healthcare professional with medical or pharmaceutic information, including:

  • to provide information regarding proper use of drug and medical device, quality, safety and effectiveness of drug, research and study on medical or pharmaceutic field and repair and maintenance of medical device.

• To provide you with information, including:

  • to hold events,

  • to release information through medias or our websites, and

  • to provide you with information regarding diseases.

• To respond to shareholders, including:

  • to send business reports or any required notifications,

  • to hold general meetings, and

  • to respond to the exercise of the shareholders’ rights.

• To provide you with marketing information, including:

  • to place web advertisement, and

  • to provide you with campaign or product information via email, mobile applications or any other means.

• To manage human resources, including:

  • to recruit employees,

  • to perform the joining and the retirement procedures, and

  • to perform personnel and labor management.

• To respond to requests from administrative or judicial authorities and perform obligations under applicable laws and regulations

• To personalize your experience when using our websites by presenting products and offers tailored to you

We use your data on an appropriate legal basis following the applicable laws.

For the purposes explained above, we may share your data with the following third parties:

• Companies working on behalf of Santen

• Our suppliers, service providers, vendors or other business partners

• Legal or administrative authorities

• Other Santen group companies

In cases where we share your data with companies working on our behalf, we require that such companies implement appropriate technical and organizational security measures to protect your data and monitor for such outsourcing on a regular basis.

We may share your data with third parties outside Asia. In such cases, we will take appropriate steps to comply with applicable laws.

We have implemented reasonable and appropriate technical and organizational security measures to protect your data from unauthorized access, disclosure, alteration, and destruction.

We keep your data for no longer than is necessary for the purposes for which your data is used and retention is no longer necessary for legal or business purposes. At the end of such period, we will dispose of your data with the appropriate security measures.

As an individual you have the following data protection rights:

• The right to access to your personal data

• The right to correct your personal data

• The right to have your personal data deleted

• The right to restrict processing of your personal data

• The right to complain about the processing of your personal data

• The right to object to the processing of your personal data

• The right to withdraw consent

• The right to data portability

• The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.

If you would like to exercise the above data protection rights, please submit your request via the “Santen Data Subject Request Form”.

We welcome your inquiries or comments you may have regarding this policy or your data. For such inquiries or comments, you can contact us as follows:

For the requests regarding your data protection rights, please send us the form as explained in “7. Your data protection rights.”

This privacy policy may be updated from time to time. If we make any changes, the updated version will be posted.

Last updated on [1 March 2022]