Privacy Policy

Eiken Chemical Co., Ltd. ("EIKEN") has established the following policy regarding protection of personal information handled by EIKEN in accordance with applicable laws, regulations and other standards in connection with personal information.

Acquisition of Personal Information

EIKEN will collect Individual’s personal data directly as Individual navigate through the Company’s website or indirectly from business partners and will process its personal information through legally appropriate and fair means. EIKEN is the data controller which determines how and for what purposes the personal data is processed.

EIKEN will collect and process the following personal data:

- Full name
- E-mail address
- Phone Number
- Date of birth
- Gender
- Address
- Organization
- Country

Legal grounds of the processing of personal data

The processing of the personal data is justified on legal grounds depending on the use EIKEN makes of the personal data. Below are the legal grounds and retention periods EIKEN applies to its main processing operations.

Consent: Individual clearly agrees to the processing of its personal data by means of express and prior content (to fill in an online “opt-in” form, click on check box, signing and sending documents with personal data, etc.). Individuals can withdraw this consent at any time.
Agreement: the processing of the personal data is necessary for the performance of the agreement contracted with the Individual. If the Individual does not wish EIKEN to process its Personal Data in that context, EIKEN may or will be obliged to refuse to enter into such agreement with the Individual or will not be able to provide the products or services covered in this Agreement.
Legal compliance: the processing of personal data is necessary for compliance with a legal obligation of the Individual.
Protect of vital interest: the processing of personal data is necessary for the protection of the vital interests of the Individual.
Public interest: the processing of personal data is necessary for the protection of the public interest or in the exercise of official authority vested in EIKEN.

Legitimate interest: EIKEN has a scientific and/or commercial interest (s) in processing Individual’s personal data and does not infringe relevant Individual’s privacy. Individuals may object to processing based on legitimate interest at any time by notifying EIKEN.

Retention period of personal data

EIKEN will retain the personal data only for the period necessary to fulfill the purposes outlined in this policy and archived with a limited access for legal reasons. The criteria used to determine the retention periods include: (i) the length of time EIKEN has an ongoing relationship with the Individual; (ii) whether there is a legal obligation to which EIKEN subject; or (iii) whether retention is advisable in light of EIKEN’s legal position (such as litigation or regulatory investigations).

Cross Border Transfer

EIKEN has partners and subcontractors located in many countries around the world. Therefore, EIKEN may need to transfer Individuals’ personal data in other jurisdictions, including from the European Economic Area to outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction the relevant Individual is based in.In cases where EIKEN needs to transfer Individual’s personal data outside the European Economic Area, it shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented (including, notably, the European Commission’s Standard Contractual Clauses, as applicable).

Utilization of Personal Information

EIKEN handles personal information within the scope necessary for the purposes of its operations and the achievement of the purpose of use'as follows. Unless the two parties have so agreed in advance or if permitted by law, EIKEN shall not use the personal information beyond the scope necessary to achieve the purpose of use.

1In the case of personal information regarding a physician, dentist, pharmacist, clinical laboratory technician, nurse, pharmacy, drugstore, medical or pharmaceutical researcher or other medical professional, or of a user of products for patients or participants in clinical trials (including past and expected future users of said products):

To provide and collect information regarding the appropriate use of drugs, medical devices and other products manufactured and/or sold by EIKEN
To provide and collect information regarding the quality and safety of drugs, medical devices and other products manufactured and/or sold by EIKEN
To provide, collect and analyze product-marketing information regarding status of use, form of use and user needs
To provide, collect and examine information regarding EIKEN's operations, including academic information
To conduct clinical trials, post-marketing studies and other surveys and research regarding EIKEN's operations
To provide submissions and reports based on laws and other norms
To provide the personal information to third parties within the necessary scope to execute the above actions

2In the case of personal information regarding Company business partners, such as product wholesalers, product material vendors and product manufacturers; lenders and others holding rights with respect to EIKEN; and lessors (past or present):

To fulfill duties or exercise rights based on this contract and related credit relationships, or to respond to same
To provide and collect information regarding this contract and related credit relationships
To form new contractual and credit relationships
To manage transaction histories

3In the case of personal information regarding commissioned clinical testing services

To Conduct commissioned testing, measure, and analyze
To Report, bill, and response to inquiries related to commissioned testing, measurements, and analyses
To perform quality control tasks necessary for testing

4In the case of personal information regarding Company debtors; lawyers, certified public accountants and other consultants of EIKEN; other contractors related to Company operations or persons with credit relationships to EIKEN (past or present)

5In the case of personal information of persons related to the neighborhood, private organizations or other stakeholders

To receive or respond to contacts, consultations, investigations, negotiations, provision of information or dissemination of publications regarding public relations
To operate joint projects or to receive contacts, consultations, examinations, provision of information or dissemination of publications regarding same

6In the case of personal information regarding persons who access EIKEN's advertising website in connection with consultation or inquiries

To respond to or otherwise contact the Individual regarding said access
To manage access histories

7In the case of personal information of shareholders (past and present)

To fulfill duties or exercise rights based on the Companies Act or other laws
To send materials for distribution to shareholders
To implement various measures to ensure smooth relations with shareholders

8In the case of personal information related to prospective employees

To examine and decide whether to hire the Individual
To provide the Individual with information regarding EIKEN, its employment practices, its decision on hiring the Individual or other information, or otherwise to contact the Individual

9In the case of personal information of directors or employees (past or present) or families thereof

To contact or exchange information with the Individual regarding operations, assign personnel appropriately, evaluate personnel or develop their skills, manage attendance, pay wages and salaries, deliver employee benefits, ensure safety and hygiene, and otherwise manage labor
To contact or provide information to labor-management conferences, health insurance societies, pension and benefit funds, subsidiaries, affiliated companies and the like
To contact the Individual and send publications regarding alumni meetings and other friendly get-togethers
To submit information and reports to government administrative offices, organizations in which the Individual participates, or the like

To send company newsletters or other publications, or to contact the Individual in case of emergency
EIKEN uses as data solely for Company-internal use in improving service, except in the following cases.

In the event of danger to the life, limb, property or other rights or interests of the individual to whom the personal information belongs ("the Individual") or of a third party.
In the event of danger to the rights or appropriate interests of EIKEN.
In the event that a national agency or local public body, or a person acting under contract to same, requires the cooperation of EIKEN to execute said person's duties as stipulated by law, and obtaining the consent of the Individual may obstruct the execution of said duties.

Management of Personal Information

In handling personal information, EIKEN appoints a person responsible for management and exercises the strictest care to prevent the unlawful use of personal information. EIKEN implements necessary and appropriate measures for safe management to prevent unlawful access to and the leakage, outflow, damage or loss of personal information.
In some cases, to improve service to customers, EIKEN may contract some duties to outside contractors. In such cases, the contract concluded with such contractors includes provisions stipulating the necessary protection of personal information and the duty of necessary and appropriate measures for safe management.

Disclosure to Third Parties

EIKEN does not disclose the personal information it acquires to any third party except in the following cases.

The Individual agrees to said disclosure.
The disclosure is in accordance with the law.
The disclosure is required to protect the life, limb or property of a person or persons, and it is difficult to contact the Individual to obtain consent.
The disclosure is particularly required to improve public hygiene or promote sound education for children, and it is difficult to contact the Individual to obtain consent.
A national agency or local public body, or a person acting under contract to same, requires the cooperation of EIKEN to execute said person's duties as stipulated by law, and obtaining the consent of the Individual may obstruct the execution of said duties.
The disclosure is provided in a way that does not permit identification of the Individual.
The disclosure is made to a contractor that has concluded a confidentiality agreement with EIKEN in advance of the disclosure, and the scope of the disclosure is the minimum required for the contractor to fulfill the objectives of the contractor's contract with EIKEN.
The disclosure is in response to an inquiry from an affiliated company of EIKEN, or EIKEN judges that the disclosure is appropriate.

Rights of Individual

Individual in the European Economic Area have certain legal rights listed below regarding Individual’s personal information. Some of these rights may be subject to some exceptions or limitations under European data protection law.
< Rights of Individual>

Right of access.
Right to rectification.
Right to erasure (right to be forgotten).
Right to restrict processing.
Right to data portability.
Right to object to processing.
Right not to be subject to a decision based solely on automated processing.
Right to withdraw consent; and.
Right to lodge a complaint with a supervisory authority.

Individuals may also file a complaint before a competent data protection authority regarding the processing of their personal data. While EIKEN suggests that Individual contact EIKEN beforehand, if Individual wish to exercise this right, Individual should contact directly the competent data protection authority.”

Inquiries

For an inquiry regarding the Individual’s own personal information, or requests the notice of the purpose of use, disclosure, modification, correction, addition or deletion of personal information, suspension of use, withdrawal of consent of the processing of such personal information without affecting the lawfulness of processing, where Individual’s personal data has been collected and processed on the basis of its consent,and stoppage of disclosure to third parties, including the exercising Individual’s rights, please contact the following Contact Person. EIKEN will respond promptly to said inquiry or request within a reasonable scope, upon confirmation of the Individual's identity.

Linked Websites

Please note that the Company accepts no responsibility for the collection and management of personal information on external websites linked from the Company's website.

Changes and Notifications

For the purpose of improvements to its content, this Privacy Policy is subject to appropriate revision and change from time to time as required.

Contact for Personal Information

<Contact Person>
Consultation Service for Personal Information
4-19-9 Taito, Taito-ku, Tokyo, Japan 110-8408
Email: kojin@eiken.co.jp