Last updated: 2nd April 2019
We are Shionogi B.V. (“Shionogi”, “we”, “our”, “us”) - the European Headquarters of Shionogi & Co., Ltd., which is a global research-driven pharmaceutical business headquartered in Osaka, Japan. We are dedicated to developing medicines that address unmet needs in the core areas of pain, infectious diseases, metabolic disorders, oncology and women’s health.
Shionogi is only responsible for the privacy practices of the websites that we own and operate. Our websites may include links to third party websites for your convenience. If you choose to access such third party websites, we recommend you check their privacy policies so that you understand their privacy practices.
Additional privacy notices and/or consent forms will, if necessary, be communicated to you relating to specific situations where Shionogi may process your personal data.
Full name and contact details of the data controller:
Our name: Shionogi B.V.
Registered office: Kingsfordweg 151, 1043GR, Amsterdam, Netherlands
Data Protection Lead: firstname.lastname@example.org
If you have any concerns or questions about our use of your personal data, or would like to exercise any of your privacy rights or choices, please contact us as set out in the “How to contact us” section below.
Shionogi collects personal data about visitors to / users of the Website and about any customers making a purchase through the Website. The type of personal data Shionogi collects depends on the nature of our relationship with you, how we interact with you, and the requirements of applicable laws. It may include:
- Order information and account registration information: information regarding your order through the Website, including your name, billing address, shipping address, payment information (including debit and credit card numbers), email address, phone number and order status.
- Your marketing preferences: your name, email address, whether you wish to be contacted with marketing communications and your communication preferences.
- Interaction data: your questions about and feedback on our business, products and services; your comments posted on our blog posts; your responses to our surveys/forms that you choose to complete.
- Technical data: information from your use of our digital platforms, including details about the devices used (e.g. your IP address, type of browser and operating system, mobile network data, time zone); access times; pages and content/products viewed (including the page you visited before our website); URLs clicked on; search terms used.
Shionogi collects personal data about you when you interact with us directly on the Website. For example, when you visit and interact on our Website, make a purchase or attempt to make a purchase through the Website; contact us to give feedback, make inquiries, complaints or request information; and choosing to complete forms or surveys.
We may combine information that we have about you from various sources.
- Fulfilling your online orders. We use your Order Information to fulfil any orders placed through the Website, including processing payment information, arranging for shipping, and providing you with invoices and order confirmations.
- Providing you with information or advertising in relation to our products or services: When in line with the preferences you have shared with us, we may use your personal data to provide you with information or advertising relating to our business, products and services that is tailored to suit what we think you will find interesting and relevant (profiling). You can choose what information you receive and how you receive it.
- Conducting our business operations. For example, responding to your questions and feedback; evaluating and improving our business, products and services, use of our digital platforms (in particular this Website) and communication strategies (for example, by generating analytics about how our customers browse and interact with the Website, and to assess the success of our marketing and advertising campaigns); contacting you for participating in surveys and market research (with your consent where legally required); communicating product safety information and responding to safety and product quality concerns (including product recalls).
- Detect potential fraud. We use your personal data to screen our orders for the potential risk of fraud.
- Complying with applicable laws, regulations, industry codes and guidance. Including responding to adverse events, product side effects, product safety and quality concerns and complaints; medical information enquiries; investigating illegal activity or misconduct, breaches of our company policies or terms and conditions governing the use of our products, services and/or digital platforms; enforcing our other legal rights or in connection with litigation.
- Complying with requests from regulators, data protection supervisory bodies, government investigations, courts and law enforcement authorities.
We may aggregate and/or de-identify any data we collect such that the information no longer identifies you as a specific individual. We may process such information for our own legitimate business purposes, without restriction (including for analysing engagement trends and other statistical analysis and business planning).
On what legal basis do we process your personal data?
Our legal basis for processing your personal data for the purposes described above will depend on the personal data concerned and the specific context in which we collect it.
- In some cases, we may seek your consent to collect and process your personal data for certain purposes. If we process your personal data on the basis of your consent, you can withdraw your consent at any time by contacting us as set out in the “How to contact us” section below.
- Contract administration. Processing is necessary to perform our obligations under a contract with you.
- Legal obligations. Processing is necessary to comply with our legal and regulatory obligations.
Legitimate Interests. Processing is necessary for our legitimate interests, where these do not prejudice or harm your rights and freedoms. For example:
- to operate, evaluate and improve Shionogi’s business and promote our innovations in the research and development of new products.
- to obtain information that may have an impact on the benefit/risk assessment of products and on the safety of those taking the products.
- to benefit from services offered by third parties.
- to sell or reorganise all or any part of our business.
- to prevent fraud and illegal activity, misuse of our products or services, and the security of our IT systems and network.
- our Shionogi group companies. Details are available here.
- our third party service providers. Examples include: our e-commerce platform provider, Shopify Inc., that powers our online store (you can read more about how Shopify uses your personal data here: https://www.shopify.com/legal/privacy), our order fulfilment and packing provider, DMC Distribution Limited (you can read more about how DMC uses your personal data here: https://www.dmcdist.co.uk/privacy-policy.html), providers of product quality services; pharmacovigilance service providers; product recall service providers; call centres; market research programme providers; technology suppliers; data storage and analytics suppliers; payment providers; shipping and fulfilment providers; auditors; lawyers and insurers.
- worldwide regulatory bodies, data protection supervisory authorities, law enforcement bodies, government authorities, courts, tribunals, arbitrators or other judicial committees.
- third parties (including other Shionogi group companies) in connection the sale, transfer or reorganisation of our business or assets (or any similar business changes).
- any other person with your consent.
Specifically, we may transfer personal data from the EEA or UK to:
- countries that the European Commission have deemed to adequately safeguard personal data by issuing an adequacy decision; or
- third countries where the European Commission has not issued an adequacy decision where: (a) the recipient has entered into the EU standard data protection contractual clauses; (b) the recipient is certified under the EU-US Privacy Shield; (c) the recipient has regulator approved Binding Corporate Rules; (d) you have given your consent to the transfer; or (e) as otherwise permitted by EU law.
Shionogi maintains safeguards to protect your personal data from accidental, unlawful or unauthorised access, loss, alternation, disclosure or use. We limit access to your personal data on a need-to-know basis and take measures such as data encryption and pseudonymisation wherever possible. However, we cannot guarantee that the measures we maintain will ensure the security of your personal data. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Shionogi has a records retention policy that specifies how long we will keep your personal data. In general, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
In determining the appropriate personal data retention periods, we 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 process your personal data and whether we can fulfil those purposes through other means; and applicable legal, regulatory, tax, accounting or other requirements.
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- to request to have access to your personal data, known as a “subject access request”. This enables you to receive a copy of the personal data Shionogi holds about you and to check we are lawfully processing it.
- to request the correction of your personal data. This enables any incomplete or inaccurate data we hold about you to be corrected, though we may need to verify the accuracy of the new data you provide to us.
- to request erasure of your personal data. You have the right to ask us to delete your personal data where there is no good reason for us continuing to process it, or where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- to object to the processing of your personal data where Shionogi is relying on a legitimate interest (or those of a third party) and you feel that our processing of your personal data impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- to restrict the processing of your personal data where: you want us to establish the data's accuracy; our use of the data is unlawful but you do not want us to erase it; you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and/or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- to request the transfer of your personal data to a third party in a structured, commonly used and machine-readable format. Note that this right only applies to automated information.
- to withdraw your consent to the processing of your personal data in circumstances where Shionogi is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before your consent was withdrawn. If you withdraw your consent we may not be able to provide certain products or services to you and we will advise you if this is the case at the time you withdraw your consent.
- to make a complaint at any time about our processing of your personal data. We would appreciate the opportunity to resolve your concerns in the first instance. You can also make a complaint to the Information Commissioner’s Office at ico.org.uk.
You can exercise these rights by contacting us as set out in the “How to contact us” section below and we will respond in accordance with applicable data protection laws. We may need to request specific information from you to help us confirm your identity and to discuss your request as there may be circumstances where we are legally entitled to continue processing your personal data or refuse your request.
- Manage your account settings
If you do not wish to receive marketing emails from us, you can opt-out by clicking on the “unsubscribe” link at the bottom of our email. Where you have registered for an account with Shionogi, you can manage your email preferences via your account settings.
- Manage your cookie and other preferences
- Opt Out of Online Behavioural Advertising
When a Shionogi online behavioural advertisement is delivered to you, you will see an “Ad Choices” icon or link. Clicking on the icon or link will take you through to a website where you can manage or opt out of your browsing history data being used to deliver online behavioural advertising. On an iOS mobile device, you may have a “Limit Ad Tracking” setting and on an Android device, you may have a “Opt out of Interest-Based Ads” setting - these allow you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.
Opting out of interest-based advertising does not mean you will no longer see advertising online. It does mean that you will no longer be shown ads that have been tailored to your interests. You may still see advertisements from Shionogi that are based on other information (e.g based on the content of the page being viewed rather than your prior web-browsing activity). In some cases, data may still be collected about your browsing activity by these third-party advertisers, but they will not use this data to deliver advertisements that are based on your past online browsing behaviour.
To learn more about the choices that advertisers provide generally for individuals to influence how information about their online activities is collected and used, visit the Network Advertising Initiative at http://optout.networkadvertising.org/?c=1, the Digital Advertising Alliance at http://www.aboutads.info/,
or the European Digital Advertising Alliance at http://youronlinechoices.eu/.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you have concerns about how Shionogi is handling your personal data, please email our Data Protection Lead at email@example.com. We would appreciate the opportunity to resolve your concerns in the first instance. You can also make a complaint to the Information Commissioner’s Office at www.ico.org.uk.
If you would prefer to contact us by mail, please use the following address: 33 Kingsway, London, WC2B 6UF, United Kingdom and mark the correspondence for the attention of the Data Protection Lead.