Collection and Processing of your Personal Data – Information Notice

Otsuka Pharmaceutical Europe Limited and its affiliates (“Otsuka”) respects your right to privacy.
The data controller of your personal data is Otsuka Pharmaceutical Europe Ltd., with an address
at Gallions, Wexham Springs, Framewood Road, Wexham, SL3 6PJ, UK which is registered withthe Information Commissioner’s Office with registration number Z9584844.
In this Notice, when we talk about personal data, we mean any information that relates to an
identified or identifiable person – in this case, you.
Your personal data will be processed according to applicable legislation, including the Data
Protection Act 2018 and the EU General Data Protection Regulation (“GDPR”). You should readthis Notice, so you know what personal data we collect about you, what we do with it and how
you can exercise your rights in connection with it. You should also read any other Notices that wegive you, that might apply to our use of your personal data in specific circumstances from time totime.
What personal data does Otsuka collect?
We may collect personal data about you from a variety of sources, including directly from you:documents or forms that you provide in order to participate in Otsuka sponsored or supported
initiatives, such as clinical research or development activities, or in other contexts; third parties;
publically available sources; CVs and resumes; and online or other databases and websites.
Otsuka may collect and use some or all of the following categories of personal data for thepurpose(s) described below:--

Personal details, such as your name, age, gender and contact details;
Professional details, such as your place of practice, job title, the medical field in which you
are active, your professional qualifications and scientific activities (such as previous
clinical trial experience), and participation in past or pending research studies with
Otsuka or other companies, publication of academic or scientific research and articles,
and membership of relevant associations and boards;
Financial details such as payment-related information, including tax identification
number; andDetails of interactions with us, such as what kind of meetings we have held, topics
discussed, your knowledge of and questions you have had on our business and products,
what kind of material we have displayed to you and any feedback that you have provided,
as well as your opinions and routines on prescribing, routines regarding your patientsand diagnosis, and similar information. In some circumstances, it will also be necessary
to collect your signature.

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For what purpose does Otsuka process personal data and what is the legal basis?
We process the personal data listed above for the following purposes and legal bases, which
may vary depending on where you live and where we operate:
PurposeManaging our relationship with you, including
planning our (potential) collaboration,
arranging visits, meetings and other activities(in-person and virtual), and contacting you forany such purpose. This includes theprocessing of your personal data in ourcustomer
relationshipmanagement
system, in particular to build a profile
about you and better understand yourexpertise, interests and preferences.
Otsuka will not make any decisions about
your profile based solely on automatedprocessing and will ensure appropriate
safeguards are maintained, in order topreserve your rights and interests.

Legal basis
We have a legitimate interest in developingour business and relationship with you (Art. 6(1) f) GDPR)
In some cases this processing is conditional on
you having provided your prior consent (Art.
6 (1) a) GDPR)

Ensuring that we provide you with We have a legitimate interest in managing our
information that is relevant given your business efficiently in the case we haveexpertise, interests and preferences.
engaged with you in the past (Art. 6 (1) f)
GDPR)
In some cases, for example receiving
information relating to promotional and/or
non-promotional materials according totherapeutic areas through electronic means,this processing is conditional on you having
provided your prior consent (Art. 6 (1) a)
GDPR)
Conducting business and market research, tobetter understand Otsuka products, disease or
therapeutic areas and generally improve ourunderstanding of the pharmaceuticallandscape.

We have a legitimate interest to better
understand our products and the area we both
operate in (Art. 6 (1) f) GDPR)

Fulfilling our contractual relationship withyou, including the completion of any requireddue diligence (such as anti-bribery or
corruption checks), processing contracts,
organising travel and facilitating the paymentof fees and expenses (where relevant).

Management of our contractual relationshipin the cases where we have a contract or you
have requested that we consider executing
one with you (Art. 6 (1) b) GDPR)

In some cases this processing is conditional on
you having provided your prior consent (Art.
6 (1) a) GDPR)

In some cases, this processing may benecessary for compliance with a legal
obligation (Art. 6 (1) c) GDPR)

Complying with transparency obligations as a Compliance with a legal obligation (Art. 6 (1)member of EFPIA, in particular the EFPIA c) GDPR)
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code on disclosures of transfers of value
and/or any applicable national disclosure We may also have a legitimate interest in thecodes.
fulfilment of our regulatory obligations withregard to transparency, as well as thelegitimate interest of patients and the generalpublic in the independence of HCOs and HCPs
(Art. 6 (1) f) GDPR)
In some cases, for example, where this isprescribed by national disclosure codes, thisprocessing is conditional on you having
provided your prior consent (Art. 6 (1) a)
GDPR)
Complying with our regulatory monitoring
and reporting obligations, including thoserelated to adverse events, product complaints
and patient safety. In some cases, Otsuka may
be required to send you specificcommunications related to these topics.

Compliance with a legal obligation (Art. 6 (1)c) GDPR)
In some cases this processing is conditional on
you having provided your prior consent (Art.
6 (1) a) GDPR)

Moreover, Otsuka may also offer mobile apps, provide access to websites, special programs,activities, events or promotions or may sponsor clinical trials (“Initiatives”) that may have uniqueor additional specific terms, Notices and/or consent forms that explain how any information you
provide will be processed in connection with the Initiatives.
Where we have entered into an agreement with you, or where we have a legal and/or regulatory
reporting obligation, the provision of your personal data is mandatory. If your personal data is
not provided we cannot interact with you.
Who does Otsuka share my personal data with?
We disclose your personal data to the following categories of recipients:
to our group companies, third party services providers and partners who provide
data processing services to us, or who otherwise process personal information for
purposes that are described in this Notice or notified to you when we collect yourpersonal data;to any competent law enforcement body, regulatory, trade association, government
agency, court or other third parties where we believe disclosure is necessary (i) as amatter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights(on the basis of our interest in the defence of our rights), or (iii) to protect your vitalinterests or those of any other person;to a potential buyer (and its agents and advisers) in connection with any proposed
purchase, merger or acquisition of any part of our business, provided that we inform thebuyer it must use your personal data only for the purposes disclosed in this Notice (on thelegal basis of our legitimate interest in ensuring the business operation);to any other person with your consent to the disclosure.

These recipients of your personal data may be acting on our behalf or as data controllers in theirown right.
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How does Otsuka keep my personal data secure?
We use appropriate technical and organisational measures to protect the personal data that wecollect and process about you. The measures we use are designed to provide a level of security
appropriate to the categories of personal data processed.
International data transfers
We may transfer your personal data to other Otsuka group companies, service providers andpartners located outside of the European Economic Area (“EEA”), for example in the USA or Japan.
Please note that countries outside of the EEA may not provide the same level of protection foryour personal data as within the EEA. Where we transfer your personal data outside of the EEA,
we ensure that appropriate safeguards are put in place and that all transfers of your personal data
comply with applicable data protection laws.
The appropriate safeguards that Otsuka uses are based on the model clauses approved by theEuropean Commission. To find out more about how we safeguard your information in relation todata transfers outside the EEA, please contact us using the details in the ‘How to contact us?’section below.
How long will your information be kept?
We retain personal data we collect from you for as long as necessary where we have an ongoing
legitimate business need to do so (for example, to provide you with a service you have requested
or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal data, we will either
delete or anonymise it or, if this is not possible (for example, because your personal data has been
stored in backup archives), then we will isolate it from any further processing until deletion ispossible.
Where you have entered into a contract with Otsuka, we will retain your personal data for theduration of the contract and, beyond that, until both the periods for which (i) the applicable laws
require the data to be kept and (ii) the statutes of limitation of any actions for which such data or
the documents containing them may be relevant, have elapsed. We retain records related to alltransfers of value, for at least five (5) years after the end of the calendar year to which they relate.
Your rights
You have a number of rights, which apply to our use of your personal data. The availability ofthese rights depends upon our lawful basis for processing your personal data and your rights
may also be subject to certain conditions and restrictions. These rights are:Right
1. The rightinformed

What does this mean?
tobe

2. The right of access3. Theright
rectification

You have the right to be provided with clear,transparent and easily understandable information
about how your information is used and your rights.
This is provided in this Notice.
You have the right to obtain access to your information(if an organisation is processing it), and certain otherinformation.

toYou are entitled to have your information corrected if
it is inaccurate or incomplete.

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4. The right to erasureThis is also known as ‘the right to be forgotten’ and, in
simple terms, enables you to request the deletion or
removal of your information where there is nocompelling reason for an organisation to keep using it.
This is not a general right to erasure; there areexceptions (for example, where you have provided
consent to processing, this applies only where you
have withdrawn your consent, if we are processing inconnection with performance of a contract or forcompliance with law, this applies only where such data
are no longer necessary and where we are relying on
our legitimate interests this applies only if there are nooverriding legitimate interests).

5. The right to restrict
processing

You have rights to ‘block’ or suppress further use ofyour information in certain circumstances. When
processing is restricted, the relevant organisation canstill store your information, but may not use it further.
Please note that your right to restrict processing islimited in certain situations; for example, when we areprocessing personal data that we collected from youwith your consent, you can only request restriction on
the basis of inaccuracy of data or where our processing
is unlawful and you don’t want your personal dataerased or you need it for a legal claim. You do not havethis right where we are processing your personal datafor compliance with law.

6. The rightportability

You have rights to obtain and reuse your personal data
in a structured, commonly used and machine readable
format in certain circumstances, which do not include
where we are processing on the basis of legitimate
interests or for compliance with law.

todata

7. The right to object

You have the right to object to certain types ofprocessing, in certain circumstances such as when
we rely on our legitimate interests.

Where your personal data is processed on the basis of your consent, you have the right towithdraw your consent at any time. If exercised, this will not affect the lawfulness of processing
prior to withdrawal.
You also have the right to complain to a data protection authority about our collection and useof personal data. For more information, please contact your local data protection authority. A listof data protection authorities in the European Economic Area is available here.
How to contact us?
Should you have any questions in regards to the protection of your personal data or if you wish
to exercise your legal rights, please submit your query here or contact Otsuka by emailing:privacy@otsuka-europe.com.
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