1. We care about your Privacy
1.1. Terumo Corporation and its Affiliates (hereinafter collectively "Terumo" or "we") are committed to protecting your Privacy and Personal Data and to respecting your rights. This Privacy Notice ("Notice") explains the types of Personal Data we may collect and how we use, share, store and secure your Personal Data, in accordance with the applicable laws.
1.2. We have designed this Notice specifically for you, our customers, vendors, HCPs, patients, website visitors, job applicants and other contact persons.
1.3. For the purpose of this Notice, Personal Data or Data means the information that identifies you or allows you to be identified either on its own or in combination with other information, such as your first and last name, gender, date of birth, home address, phone number, email address or other contact details, preferred language, identification numbers and license plate numbers.
2.We collect your Data in different ways
2.1.We may collect Data that you have voluntarily provided to us (for example by applying or registering for an event, visiting our booth at a congress, participating in trade fairs, webinars, seminars, training events, by submitting your resume or business card, responding to a survey or participating in a Website feature) or that was provided to us by the company or organisation you work for.
2.2. It may be possible that we receive or indirectly collect Data about you, for example, from our business partners, from data brokers, or from public sources such as social networks or public websites.
3. We process different categories of Data
3.1. We may collect and use the following categories of Personal Data, depending on your relationship with Terumo:
|Category of data||Examples|
|Contact information and identification data||such as your name, address, e-mail address, telephone or mobile phone number, your signature, gender, birth date, your account details (e.g. log-in to portal or website)|
|Official identification numbers||your VAT Tax number, your passport number (when we help you obtaining a permit), your national ID number, your license plate number (when you visit our premises), social security number, professional registration number.|
|Financial data||such as your bank account number and bank details, payment terms and credit limits (for suppliers)|
|Professional data||such as your language skills, professional knowledge or expertise, certifications, references and other information you could find on a resume, your job title and the company you work for, any mandates you may hold, your professional location and travel data (for business contacts we know are flying in to attend an event), your professional remuneration, evaluation and performance reports (e.g. for our consultants), your memberships or network contacts (e.g. when we meet you at an event or get in touch with you through someone within your network)|
|Electronic localization data||such as your whereabouts on the premises (based on badge data)|
|Preferences, interests, lifestyle or behavior||such as the products or activities you are interested in, the events you attend, the news or information you have requested or, your purchasing history (e.g. also through cookies, logs, expenses, …)|
|Health and clinical data||medical certificates of contactor; clinical data, medical history, testing results, medical images and other relevant data included in the hospital patient file|
|Image data||photographs, pictures, surveillance images|
3.2. In addition to the Data categories listed above, we may use other types of Data relating to you that you may have voluntarily provided to us, that were provided to us in the context of our business relations or that we have deducted or generated from Data that were already in our possession.
4. We use your Data for specific purposes
4.1. We may use your Personal Data for one or more the following purposes:
- Contact you for specific requests or inquiries (for example to obtain consultancy services, to respond to your queries;
- Manage the performance of our (contractual) engagements and our business relation;
- Communicate with you (via regular mail, email or telephone) about our products and related services;
- Identify your interest as an existing or potential customer in particular products for marketing and product promotion (prospecting and profiling), to provide you better support and to better respond to your inquiries and needs and of those of our patients;
- Invite you to provide feedback or participate in customer surveys, market research and surveys to develop or improve our products and related services;
- Use this information for our overall customer relationship management (CRM);
- Protect our legal rights (including disputes and litigation) and ensure security and protection of our organization, our customers, patients and the public in general;
- To comply with laws, regulations and industry standards (such as transparency reporting), to detect fraud and to ensure compliance;
- To manage product failures and recalls;
- To perform pre- and post-market research, including clinical trials (with patients)
- To consider and handle your recruitment (for example when you apply for a job through our website) or contactor relationship.
4.2. The legal basis for using and processing your Data are, as the case may be, your consent for the use for specific purposes such as direct marketing to prospects, the performance of contracts, services and business transactions, compliance with our legal obligations, protection of your vital interests or our legitimate business interests such as proper handling of our activities, developing and improving our products, informing and communicating with our customers, vendors and partners, protecting our organization, our activities, partners, patients and the general public.
5. Minimizing and securing your Personal data
At all times we aim to minimize the Personal Data we process, to make sure we only use your Data when and in so far we need it. Where possible we also pseudonymise or key-code your Data so that you cannot be directly identified. For example the hospitals and clinical centers involved in our clinical studies link your clinical data to a patient number before sharing the data with us and we only process such key-coded data.
6. Sharing your Personal Data
6.1. Within Terumo we restrict access to your data to employees and any person acting under our authority on a need-to-know basis, who respect our confidentiality rules and comply with our instructions.
6.2. We may share your Data to selected third parties outside Terumo who provide services to us or on our behalf, such as advertising and marketing services, IT services, hosting services, data analytics services, event management services and other professional services.
6.3. We may also share your Data with authorized distributors, business partners or other suppliers, who are involved in providing our products and services to you, to communicate with you or to respond to your queries.
6.4. We may also need to transfer your Data to other recipients if we believe in good faith that this is necessary or useful, such for example Hospitals, HCPs, or ethical committees in the context of pre- and post-market research and clinical trials; attorneys, insurance companies, auditors, public prosecutors, enforcement authorities and courts to safeguard the rights and interests of our organization, our people, our customers and partners or the public in general;
6.5. We may also share your Data to other Terumo companies in order to optimize the use of information or to improve the quality of our products and effectiveness of our activities.
6.6. When we share your Personal Data with third parties or other Terumo entities who process Data on our behalf as processors we will ensure those parties provide sufficient guarantees on the lawfulness, transparency and security of your Personal Data in line with applicable data protection law.
6.7. As a Japanese company offering goods and services to the persons in EU, we will treat your Personal Data in accordance with both Act on the Protection of Personal Information of Japan and EU privacy and data protection law. Also, we are an international organization, operating globally and may therefore transfer your Personal Data outside the European Economic Area (EEA). Transfers from our entities in the European Economic Area to entities outside the EEA are covered by intercompany data transfer agreements in line with EU privacy and data protection law. When your personal data is shared by us with or transferred by or to a third party outside the EEA, when required, we will enter into the appropriate data transfer agreements or otherwise make sure appropriate safeguards are in place.
7. We keep your data for a limited period of time
We will only use your Personal Data for as long as it is necessary for the purposes listed above. In this respect, we have established a data classification and retention policy in the framework of our internal Data Retention Policy.
8. We respect your rights
8.1. We have implemented reasonable, risk-based technical and organizational measures to ensure that your Data is protected from loss or disclosure, unauthorised use, modification or destruction.
8.2. Under the privacy laws you have certain rights in relation to the Personal Data we hold about you, such as the rights of information about and access to your Personal Data, rights to rectify or complete your Personal Data, rights to object to or restrict or cease certain processing, rights to delete your personal data and the rights to be forgotten.
8.3. You can request the exercise of your rights by contacting us using the contact details below.
8.4 In order to guarantee the security of your Data and to avoid any misuse, before responding to your request, we will ask you to provide us with an acceptable proof of your identity and will verify the legitimacy of your request and whether all the conditions have been satisfied.
9.3 You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled. You also have the possibility to remove from your browser cookies set by the Website. Please refer to your browser instructions to learn more about how to adjust or modify your browser settings.
10. Contact us
If you have any questions or concerns about the way we collect, store and use your Data, don't hesitate to direct them to your contact person at Terumo, who will, where necessary, redirect them to our Privacy Office.You can also reach us at IFU_support@terumo.co.jp by attaching a recto verso copy of your identity card to your request.You can also contact Terumo Corporation, Post-market Surveillance & Vigilance Department, 2-44-1 Hatagaya, Shibuya-ku, Tokyo, JAPAN, 151-0072. We will deploy our best efforts to find a quick and fair solution to any concern that you may submit to us. In addition, if you have reasons to believe that the Processing of your Personal Data by Terumo infringes the Applicable Laws, you have the right, at all times, to lodge a complaint with the supervisory authority of your choice.