Shionogi Inc. – Online Privacy Notice

Last Modified: June 11, 2024

Introduction

Shionogi Inc. ("Shionogi" or "we") respects your privacy and is committed to protecting it through compliance with this Website Privacy Policy (“Policy”) and applicable law.

This Policy describes how we collect, use, disclose, retain, protect, and otherwise process information about you in connection with our business activities, the types of information that we process, and your rights with respect to such information. This Policy does not replace any consent form or notice that you may separately receive in connection with Shionogi’s processing of your information.

For purposes of this Policy, “Personal Information” means any information relating to an identified or identifiable natural person.

Personal Information That We Collect

The types of Personal Information that we may collect include:

Identifiers and Contact Information – physical addresses, email addresses (personal and business), telephone numbers, account names and other unique personal identifiers, online identifiers, Social Security numbers, driver’s license numbers, passport numbers, and other similar identifiers.
Biographical and Demographic Information – date of birth, age, gender, marital status, race, ethnicity, and information regarding any parents or legal guardians.
Professional or Employment Information – job title, organizational affiliations, professional credentials, employment history, education history, resume/curriculum vitae, background checks, and other similar information.
Health and Medical Information – information regarding treatments and medication, insurance information, medical history, and lab results (e.g., information provided in connection with clinical trials, patient support programs, adverse event reporting, and other research-related activities).
Financial Information – tax classification and exemption status (through IRS Form W-9), bank account information, and other payment related information (e.g., information provided in connection with an investigator-sponsored research proposal or as a consultant, service provider, or investigator in a clinical trial).
Audio or Visual Information – video recordings or photographs if you visit our locations.
Commercial Information – services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Inference Information – information used to create profiles about consumers to reflect consumer preferences, characteristics, and trends.
Security and Access Credentials – usernames and passwords that may be created in connection with accounts on our website or mobile applications.
Biometric Information – fingerprints, voiceprints, or facial recognition information, as may be necessary for identity authentication.
Other information that you may provide in emails, during telephone calls, through our website or mobile applications, or in other correspondence.

How We Collect Personal Information

We collect Personal Information:

Directly from you, when you provide Personal Information in person, over the telephone, over email, or through our website or mobile applications.
Indirectly from you, when you participate in a clinical trial.
Automatically, through your browser’s cookies, web beacons, and other tracking technologies when you view or use our website or mobile applications.
From existing and potential business partners, employees, service providers, consultants, health care professionals, patients, clinical trial participants, clinical trial investigators, data brokers, government agencies, recruiters, and social media.
From third-party employment websites.
From public databases.
When you interact with our advertising through third-party websites and services, if those advertising include links to our website.

Depending on the functionality of our website from time to time, you also may provide Personal Information to be published or displayed (hereinafter, "Posted") on public areas of our website or transmitted to other website users or third parties (collectively, "User Contributions"). Any User Contributions are Posted and transmitted to others at your own risk and we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information Collected Automatically

As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our website, including traffic data, location data, logs and other communication data, and the resources that you access and use on our website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information that we collect automatically is only statistical data and does not include Personal Information, but we may maintain such information or associate it with Personal Information that we collect in other ways or receive from third parties.

The technologies that we use for automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you refuse to accept browser cookies, you may be unable to access certain parts of our website. Unless you have adjusted your browser settings to refuse cookies, our system will automatically issue cookies when you direct your browser to our website.
Web Beacons. Pages of our website may contain small, electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Shionogi, for example, to count users who have visited those pages and for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity).
Flash Cookies. Certain features of our website may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for flash cookies, please see the “Choices About How We Use and Disclose Your Information” section below.

Data Analytics

We may use your Personal Information for data analytics to help us improve our website and deliver better and more personalized service, including by allowing us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our website according to your individual interests.
Speed up your searches.
Recognize you when you return to our website.

Children’s Privacy

Shionogi does not knowingly collect Personal Information from children under the age of 13, and our website is not intended for children under the age of 13. No one younger than 13 may provide any Personal Information to Shionogi, including through our website. If we learn that we have collected or received Personal Information from a child under the age of 13 without the consent of such child’s parent or guardian, we will delete such Personal Information. If you believe we may have collected or received any Personal Information from or about a child under the age of 13, please contact us at data.privacy@shionogi.com. California residents under the age of 16 may also have additional rights regarding the collection and sale of their Personal Information. Please see the “Your State Privacy Rights” section below for more information.

How We Use Personal Information

We use the Personal Information that we collect or receive to the extent permitted by applicable law, including:

To provide and improve our website and related applications, including interactive features.
To communicate information to you regarding our products, programs, business, or services.
To analyze communication strategies (e.g., your interactions with us, including on our websites and mobile applications).
To notify you about changes to our website or any products or services that we offer or provide.
To staff, facilitate, conduct, and manage clinical trials, patient support programs, and other product or investigational programs.
To track and respond to safety and product quality concerns, including product recalls.
To comply with regulatory monitoring and reporting obligations (including those related to adverse events, product complaints, spend transparency, and patient safety).
To comply with any court order, law, or legal process, including responding to any government or regulatory request.
To identify and facilitate business relationships, enter into and enforce contracts, and facilitate payment or billing.
To process and evaluate employment applications.
To fulfill any other purpose for which you provide Personal Information.
To protect the rights, property, or safety of Shionogi, our customers, or others (e.g., exchanging Personal Information with other companies or organizations to prevent fraud and reduce credit risk).
In any other way that we may describe when you provide Personal Information.
For any other purpose with your consent or as disclosed by us at the time we collect or receive Personal Information.

How We Disclose Your Information

We may disclose without restriction aggregated information about website users and information that does not identify any individual.

We may disclose Personal Information that we collect or that you provide for the purposes described above:

To our subsidiaries and affiliates.
To contractors, service providers, vendors, and other third parties that we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which such Personal Information is disclosed.
To other business partners with whom we collaborate regarding our products and programs, such as scientific advisors, joint venture partners, and strategic collaboration partners.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which we are transferring Personal Information as an asset.
To legal, regulatory, or other enforcement authorities.

How We Retain Your Information

We may retain the information we collect, including Personal Information, for as long as necessary for the purpose for which such information was collected and for as long as allowed or required by applicable law.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the use and disclosure of your Personal Information. You can use the following mechanism to control your Personal Information:

Tracking Technologies. You can set your browser to (i) refuse all or some browser cookies or (ii) alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, third parties may allow you to opt out of their collection or use of your Personal Information for such purposes. For example, you can opt out of receiving targeted advertisements from members of the Network Advertising Initiative ("NAI") via the NAI's website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah, may have additional rights and choices with respect to their Personal Information. Please see the “Your State Privacy Rights” section below and our CCPA Privacy Policy and Notice for more information.

Accessing and Correcting Your Information

You may email us at data.privacy@shionogi.com to request access to, correct, or delete any Personal Information that we have collected or received. Please note, however, that we cannot delete your Personal Information without also deleting your user account. Further, we may not accommodate a request to correct Personal Information if we believe such correction would violate any law or legal requirement or cause such Personal Information to become incorrect.

As noted above, residents of certain states, including California, Nevada, Colorado, Connecticut, Virginia, and Utah, may have additional rights with respect to their Personal Information. Please see the “Your State Privacy Rights” section below and our CCPA Privacy Policy and Notice for more information.

Your State Privacy Rights

State consumer privacy laws may provide residents with additional rights regarding our use of their Personal Information. To learn more about California residents' privacy rights, please see our CCPA Privacy Policy and Notice.

Colorado, Connecticut, Virginia, and Utah each provide their residents with rights to:

Confirm whether we process their Personal Information.
Access and delete certain Personal Information.
Data portability.
Opt-out of Personal Information processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their residents with rights to:

Correct inaccuracies in their Personal Information, taking into account the nature and processing purpose(s) of such Personal Information.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Nevada also provides its residents with a limited right to opt-out of certain Personal Information sales. However, Shionogi does not currently sell Personal Information in a way that would be subject to this opt-out right.

Shionogi complies with other state privacy laws that may be adopted from time to time, and this Policy will be updated in the future as needed to comply with such laws.

To exercise any of the rights above or to appeal our decisions regarding any of these rights, please email us at data.privacy@shionogi.com or notify us in writing using the following address: Shionogi Inc., 300 Campus Drive, Florham Park, NJ 07932.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. All Personal Information that you provide to us is stored behind firewalls on our secure servers and will be encrypted using SSL technology.

The safety and security of your Personal Information also depends on your efforts. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping your password confidential. We ask that you not to share your password with anyone. We also urge you to take care when disclosing Personal Information in public areas, including on this website (e.g., on message boards).

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of Personal Information transmitted to our website. Any transmission of Personal Information is done at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

EU-U.S. Data Privacy Framework, United Kingdom Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework

We comply with the EU-U.S. Data Privacy Framework, United Kingdom Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework (collectively, “DPF”) developed by the U.S. Department of Commerce and the European Commission, United Kingdom Government, and Swiss Federal Administration. We have certified to the U.S. Department of Commerce that we adhere to the Data Privacy Framework Principles (“DPF Principles”) with regard to the processing of Personal Information received from the European Union, United Kingdom (“UK”), or Switzerland in reliance on the DPF. You can read more about the DPF Principals here . If there is a conflict between this Policy and the DPF Principles, the DPF Principles shall govern. To learn more and to view our certification, please visit the U.S. Department of Commerce’s website on the DPF.

In certain circumstances, we may disclose Personal Information in response to lawful requests from public authorities, including to meet national security or law enforcement requirements. As explained in the “How We Use Personal Information” section above, we may share your Personal Information as appropriate with third parties that process Personal Information on our behalf. Under certain circumstances, we may remain liable for the acts of certain third parties if those third parties process Personal Information originating from the European Union, United Kingdom, or Switzerland that we disclose to them in a manner that is inconsistent with the DPF Principles.

If you have a question or complaint regarding how we handle your Personal Information under the DPF, please contact us using the information provided in the “Contact Us” section below and we will attempt to resolve your question or complaint. If we are unable to resolve your question or complaint, you may choose to have JAMS, a neutral third party, mediate your concern. You may submit your unresolved concern to JAMS for resolution by contacting them at: https://www.jamsadr.com/eu-us-data-privacy-framework.

You may also have the option to select binding arbitration for the resolution of your complaint with respect to Personal Information originating in the European Union, United Kingdom, or Switzerland. For more information regarding binding arbitration, please see the Data Privacy Framework: Annex I Introduction on the U.S. Department of Commerce’s website.

Our compliance with the DPF is subject to the jurisdiction of the Federal Trade Commission. For more information about the DPF or to view our certification page, please visit the U.S. Department of Commerce’s website on the DPF or visit our Data Privacy Framework privacy policy.

Information for Residents of the European Economic Area and the United Kingdom

If you are located in the European Economic Area (“EEA”) or the UK, your Personal Information may be protected by data protection laws in the EEA or UK, such as the European Union General Data Protection Regulation (GDPR). Shionogi will comply with applicable data protection laws when it uses and shares your Personal Information as described in this Policy.

When using or sharing your Personal Information as described in this Policy (including transfers out of the EEA and UK described below), Shionogi relies on the following lawful bases, as appropriate:

Where you have provided consent to the processing of your Personal Information for one or more specified purposes.
- Subject to limitations under applicable law, your consent may be withdrawn at any time in the manner specified by us when we obtain your consent. However, withdrawal of consent will not affect the legality of our processing based on consent prior to such withdrawal.
Where processing is necessary to fulfill a contract or to take steps prior to entering into a contract.
Where processing is necessary to comply with legal obligations.
Where processing is necessary to protect a person’s vital interests.
Where processing is necessary for the performance of a task carried out in the public interest.
Where processing is necessary for the purposes of the legitimate interests pursued by Shionogi or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual whose Personal Information is processed.
- Legitimate interests may include, for example, (direct) marketing to consumers without intrusive profiling, customer service, processing employment applications, general human resource management and performance assessment, and CCTV cameras for security purposes.

As a result of Shionogi’s operations in the United States, your Personal Information may be processed by Shionogi in the United States. Shionogi may contract with service providers to process your Personal Information on Shionogi’s behalf, which service providers may be located outside of the EEA and UK.

Data protection laws in the United States or other countries may not offer you the same protections as the laws of the country in which you are residing when your Personal Information is collected. By using this website and by submitting your Personal Information to Shionogi, you consent to the transfer of your Personal Information to any country and its use and disclosure in accordance with applicable U.S. federal and state laws and this Policy.

By submitting an employment application to Shionogi through a third-party employment website, you are consenting to Shionogi’s processing of your Personal Information (including special categories of Personal Information) in connection with Shionogi’s consideration of your application and for Shionogi’s compliance with applicable laws.

Data protection laws in the EEA and UK may provide you the following legal rights with respect to your Personal Information used and shared by Shionogi:

To withdraw consent at any time, if we are using and sharing your Personal Information on the basis of consent.
To access the Personal Information that we have about you.
To request that we rectify or erase your Personal Information.
To request that we restrict the way that we use or share your Personal Information.
To object to the way that we use or share your Personal Information.
To ask us to transfer your Personal Information to someone else.
To lodge a complaint with a data protection authority in the EEA or UK.

Shionogi’s ability or obligation to comply with your requests may be limited by applicable law. If you are located in the EEA or UK, please contact data.protection@shionogi.com. to request to exercise one of these rights.

Acceptance of Our Privacy Policy

Please read this Policy carefully to understand our practices regarding your Personal Information. If you do not agree with the practices outlined in this Policy, you may choose not to use our website. By using or accessing our website, you agree to this Policy.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Policy on our website. If we make material changes regarding how we treat users' Personal Information, we will notify you through a notice on our website home page. The date that this Policy was last revised is also identified at the beginning of this Policy. Your continued use of this website after we make any changes constitutes your acceptance of those changes, so please check this Policy periodically for updates.

You are responsible for ensuring that we have your up-to-date email address, and for periodically visiting our website and this Policy to check for any changes.

Contact Us

If you have any questions about this Policy or our privacy practices, or to submit a complaint, please contact us via email at data.privacy@shionogi.com or in writing using the following address: Shionogi Inc., 400 Campus Drive, Florham Park, NJ 07932.