Except as otherwise noted below, this Policy applies to the personal information that Eisai processes related to:
- our websites, mobile applications, products and services (the “Services”), including our clinical research and patient support programs, and other healthcare and patient programs we administer, sponsor, or operate
- healthcare professionals
- individuals who register for or participate in our webinars and other events
- individuals who are subscribed to receive news, information, and marketing communications from us
- individuals who participate in contests, sweepstakes, surveys, and research conducted by us
- individuals that otherwise communicate, engage, or interact with us related to our business or our Services
This Privacy Statement does not apply to the personal information that we collect and process about employees and personnel, which is subject to separate privacy notices/policies.
Additional Notices. In some cases, additional or supplemental privacy notices may be provided and will apply to certain personal information collected and processed by us. For example, we may provide an additional notice to patients that participate in clinical trials or patient assistance programs sponsored by Eisai. The additional notice will control to the extent there is a conflict with this Policy, with respect to your personal information that is subject to that notice.
COLLECTION OF PERSONAL INFORMATION
The personal information that we collect and process varies depending upon our relationship and interactions with you. In some cases (such as where required by law), we may ask for your consent, or give you certain privacy choices as described in this Policy, regarding your personal information.
As further described below, we collect personal information from variety of sources, including:
- Directly from you and other consumers
- From others, including:
- From health care professionals and medical institutions
- From contract research organizations and clinical trial investigators
- From individuals enrolled in clinical trials
- From government agencies or public records
- From third party service providers, data brokers or business partners
- From industry and patient groups and associations
- From time to time, we may use or augment the PII we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties.
- Information that we derive about you or collect automatically related to your use of our Services or other interactions with us including:
- Through our websites and mobile apps
- Through automated technologies and online tools (e.g., cookies)
- Through devices that you use or wear
Personal information provided to Eisai.We may collect and process personal information that you provide to us, as well as personal information about you that is provided on your behalf (such as by your authorized representative, legal guardian, healthcare provider, and others with whom you interact related to our Services). This information generally includes:
- Contact information and preferences (such as, but not limited to, name; email address; mailing address; phone number; and emergency contact information)
- Biographical and demographic information (such as, but not limited to, date of birth, age, gender, ethnicity and marital status)
- Health and medical information (such as, but not limited to, information about physical and mental health conditions and diagnoses; treatments for medical conditions; genetic information; family medical history; test results; blood data; and medications an individual may take, including the dosage, timing and frequency)
- Physical and biological information (such as, but not limited to, voice, heart rate, blood pressure, height and weight), whether self-reported or obtained through devices
- Information collected in connection with managing clinical trials; conducting research; providing patient assistance programs; distributing and marketing our products; managing compassionate use and expanded access programs; and tracking adverse event reports
- Information regarding any parents or legal guardians
- Financial information to complete a transaction or determine eligibility for patient assistance programs
- Username and password that you may select in connection with establishing an account on our websites or mobile apps
- Your photograph, social media handle or digital or electronic signature
Additional personal information about health care professionals.If you’re a health care provider, Eisai may also collect the following personal information:
- Professional credentials, educational and professional history; institutional and government affiliations; and information included on a resume or curriculum vitae education and work history (such as work experience, education and languages spoken)
- Information about Eisai and third-party programs, products and activities with which you have engaged
- Details about our interactions with you; your prescribing of our products; the agreements you have executed with us; and any payments made to you for services provided
- Information related to your practice, such as license information; disciplinary history; prior litigation and regulatory proceedings; and other due diligence-related information
- Information regarding circumstances which may create a conflict of interest
- Information provided to participate in our sponsored or supported initiatives, such as our sponsored clinical research and development activities, online or in-person seminars, educational events, and clinical information updates
Information collected from third parties.We may also collect personal information about individuals from other third-party sources, such as social media platforms and channels, forums and other third-party sites, and public databases, as well as from other third parties who support our business activities. For example:
- If you post information that is related to us, our products, therapeutic areas or our Services or engage with us on third party platforms or social media, we may collect personal information about you from that third party platform or account. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
- In some cases, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases and other third parties. For example, we may use such third-party information to confirm or verify licensure of healthcare professionals or to better understand your interests by associating demographic information with the information you have provided.
- If we become aware of information about us or our Services that relates to product or treatment quality or safety, or is otherwise reportable pursuant to our regulatory obligations, we will maintain records of such information in accordance with our regulatory and reporting obligations, including information that has been communicated on third party social media sites or otherwise shared by or with a third party.
Information we may collect via automated means or derive about you. We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:
- Profiles. Inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, behavior, attitudes and abilities
- Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items and content viewed, and time spent within the Services.
- Location information. We may collect or derive location information about you, such as through your IP address. Further, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings.
PURPOSES OF PROCESSING AND USE
While the purposes for which we may collect, use, disclose and otherwise process personal information will vary depending upon the circumstances, in general we do so for the purposes set forth below or as otherwise directed or authorized by you:
- Fulfilling and responding to requests. We and our service providers may use personal information you provide to fulfill your requests, such as to send you information; fulfill or ship a purchase order; or enroll you in an Eisai program.
- Responding to your inquiries. We may use personal information you provide in order to respond to your questions about applications, clinical trials and other services.
- Administrative communications. We may use personal information to send you important information, such as changes to our terms, conditions, policies and/or other administrative information. Because this information may be important, you may not opt out of receiving such communications. For example, you can’t opt out of receiving communications regarding the safety or recall of an Eisai product.
- Marketing communications. We may use personal information that you or third parties provide to inform you of products, programs, services and surveys that we believe may be of interest to you. You may opt out of receiving such communications, as described in the “Choices” section below.
- Education and research. We may use the information we collect from you, our service providers, health care practitioners, publicly available sources and other third parties to conduct surveys; to identify and recruit individuals to participate in our research programs; to interview individuals relating to our research; to provide educational content; or to create directories and compile databases of contact information.
- Administering clinical trials. If you participate or apply to participate in a clinical trial, Eisai will use personal information collected in connection with that clinical trial. For example, Eisai may use your personal information to determine your eligibility for a clinical trial now or in the future.
- Payments and transactions. We use financial information to complete requested transactions. We may also use your personal information to provide payment to individuals who receive honoraria.
- Online services. We collect and use information about how you and other users interact with our online services through our websites, apps and online tools. We use this information in order to compile statistics for analysis of our Services and our business.
- Security and protection of rights. Where we believe necessary to investigate, detect, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our terms and other agreements. We may also use certain information as evidence in litigation in which we are involved.
- Planning and implementing business transactions. In order to plan and implement an actual or contemplated merger, acquisition, financing, sale, bankruptcy or restructuring of all or part our business or assets.
- Internal business purposes. We may use personal information collected from any of the sources listed in the “How Does Eisai Collect personal information?” section of this policy for our internal business purposes, such as data analysis; audits; developing new products and projects; compensation; enhancing our website; improving our services; identifying usage trends; and determining the effectiveness of our promotional campaigns.
- Legal and regulatory. Eisai may use any personal information to meet legal and regulatory requirements and to protect against fraud, suspicious or other illegal activities.
DISCLOSURES OF PERSONAL INFORMATION
We may disclose the personal data that we collect for the purposes described above, in order to provide our Services to you, to respond to and fulfil your orders and requests, as otherwise directed or consented to by you. Generally, this includes the following types of disclosures:
- Affiliated entities. We may share personal information with our affiliated companies, including Eisai Co. Ltd. (our parent company in Japan), and with any other companies within the Eisai group of companies.
- Service providers. We may share personal information with service providers who provide us with services, such as data analysis; payment processing; order fulfillment; infrastructure provision; IT services; legal services; customer service; email delivery services; credit card processing; and other similar services. We grant our service providers access to personal information only to the extent needed for them to perform their functions, and require them to protect the confidentiality and security of such personal information.
- Commercial and collaboration partners. We may share personal information with unaffiliated third parties who partner with us to deliver a Service or on our commercial or research activities. Depending on the choices you’ve made and the nature of the joint activity, these third parties may contact you regarding Eisai-related products, programs, services and promotions that may be of interest to you.
- Business transfers or assignments. In the event of any reorganization, merger, sale, joint venture or collaboration, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), we may transfer any and all personal information that we collect to a third party. We may also share certain personal information as necessary prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
- Third party platforms, providers and networks. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information that includes personal data available to third parties in support of our marketing, analytics, advertising and campaign management (see the Interest Based Advertising section below for more information).
- Law enforcement, government authorities, emergencies and compliance. We may disclose personal information about you to others as we believe to be appropriate:
- Under applicable law, including laws outside your country of residence
- To comply with legal process
- To respond to requests from public and government authorities (including public and government authorities outside your country of residence), as well as to comply with any legal or regulatory obligations imposed by such authorities
- To enforce our terms and conditions
- To protect our operations or those of any of our affiliated companies
- To protect the rights, privacy, safety or property of Eisai, our affiliated companies, you or others
- To permit us to pursue available remedies or limit the damages that we may sustain.
We have no obligation to notify you of such disclosures, except as required by applicable law.
AGGREGATE AND NON-IDENTIFIABLE INFORMATION
We may also use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.
Information collected by automated means and online tools
Eisai and third-party service providers used by Eisai also may collect PII from you through browser navigational tools, cookies, pixel tags and other similar technologies. Below are descriptions of the online tools Eisai may use:
- “Session” cookies are temporary bits of information that are used to improve website navigation, block website visitors from providing information where inappropriate, and collect aggregate statistical information on a website. These cookies are erased once you exit your web browser or otherwise turn off your computer.
- “Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there until you delete the cookie. Persistent cookies store information on your computer so that we can, for example, retrieve information you have previously provided (such as passwords); better determine what areas of the website you find most valuable; and customize the website based on your preferences on an ongoing basis.
You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. If your browser is set to reject cookies, websites that are cookie-enabled won’t recognize you when you return to the website, and some website functionality may be lost. learn more about cookies.
At this time, our websites don’t respond to Do-Not-Track signals.
INTEREST-BASED ADVERTISING (IBA)
We try to deliver advertising for products and services you have expressed an interest in. We may partner with advertising companies that may place or recognize a unique cookie on your browser (including through the use of pixel tags), or use other technologies, to serve you ads based on your web browsing activity, purchases, interests and/or other information. This practice is commonly referred to as interest-based advertising (IBA) or online behavioral advertising (OBA). Advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use. Read more about IBA .
Want to see your current IBA status? Check it now
SPECIAL PROGRAMS AND CLINICAL TRIALS
Eisai may offer apps, special programs, clinical trials, activities, events, discounts or promotions (“Program(s)”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information you provide will be processed in connection with such Program(s). You should review the terms applicable to the specific Program(s) before interacting or participating in the program.
CHOICES AND RIGHTS
We make available a number of ways that you can manage your privacy choices and submit privacy requests related to your personal information. These include:
- Marketing communications. If you no longer wish to receive promotional emails from us on a going-forward basis, you may opt out of receiving such emails by following the “unsubscribe” directions on the emails or by changing your preference settings. We’ll endeavor to comply with your request as soon as reasonably practicable.
- Review, update and delete personal information.
You may also have certain rights and choices regarding our processing of your personal information. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right to:
- Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared.
- Access a copy of the personal information we retain about you.
- Request deletion of your personal information.
Recruiting and Onboarding Portal/Site. Eisai also operates a recruiting and onboarding portal and website (“career portal/site”) to support Eisai’s recruitment efforts. The following additional provisions are applicable only to the career portal/site. Any employment offer that may result from your submitting information in response to a job opening listed on the career portal/site is in accordance with the specific terms of that offer and isn’t based in any way on the description of the job on the career portal/site. Except as otherwise prohibited by law, nothing on the career portal/site shall be construed as a contract of employment or as a guarantee of continued employment or employment for any specific duration. Employment with Eisai is "at will." That means if you’re hired, either you or Eisai can separate your employment at any time without notice or cause.
Personal information you submit through the career portal/site may include, but isn’t limited to: name; log-in and password, for users of the career portal/site; telephone number; email address; mailing address; age; date of birth; gender; Social Security number; driver’s license number; CV, résumé, cover letter, previous work experience and education information; employment preferences; willingness to relocate; desired salary; professional and other work-related licenses, permits and certifications held; language and other relevant skills; awards and professional memberships; eligibility to work in the United States; and available start date. We don’t require, but you may voluntarily choose to provide, other relevant information as part of your application. We’d prefer that you avoid submitting the following sensitive information, except where such information is legally required, or needed for us to comply with our legal obligations and internal policies relating to diversity and anti-discrimination: medical or health conditions; sexual orientation; race; ethnic origin; religious or philosophical beliefs; marital status; trade union membership; creed; nationality; national origin; and/or color.
The information that you submit in the career portal/site will be stored in the United States. It may be accessed, collected, used, transferred and disclosed by employees, consultants and/or service providers of Eisai around the world for Eisai’s recruitment functions and for related management and planning purposes, including, as permitted by local law, to: process your application; assess your capabilities and qualifications for a job; provide you with any services available on the career portal/site from time to time; communicate with you; comply with any applicable law or regulation; compile internal reports, including diversity and distribution metrics; and monitor and record services whether provided by a Eisai company or a third party.
Personal information you submit through the career portal/site will be added to Eisai’s candidate database and will be used for the purposes of considering whether your profile is suitable for other job vacancies at Eisai. If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. If you become an employee, any personal information that you submit may become part of your employment file and may be used for other employment/work-related purposes as permitted by local law. Personal information you submit through the career portal/site will be reviewed by Eisai employees or agents who have a business need to access such personal information. This may include recruiters, human resources personnel, technical services personnel and managers. We may share personal information you provide as part of your application with selected service providers or consultants acting on our behalf, such as third parties assisting Eisai with the operation of the career portal/site and the storage of information collected on the career portal/site. Any such third party will be required to use appropriate measures to protect the confidentiality and security of personal information which are no less protective that those set out in this Policy.
We have implemented organizational, technical and administrative measures intended to help protect personal information that we collect against the loss, misuse and alteration. However, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure. Please don’t send us information you consider confidential via email.
This website and any accompanying services offered aren’t directed at children who are under 13 years of age. It’s Eisai’s policy to require that individuals requesting information on our products be 13 years of age or older. Please note, we may collect the Personal Information of minors in connection with other business activities, such as adverse event reporting. Should we receive Personal Information from a person who we know is under 13, we’ll endeavor to delete such information from our website database. If you believe that a person under 13 has provided us with his or her Personal Information, please notify us so that we can take reasonable steps to remove the information from our database.
200 Metro Blvd.
Nutley, NJ 07110
CALIFORNIA PRIVACY SUPPLEMENT
In this section, we provide additional information to California residents about how we handle their personal information, as required by the California Consumer Privacy Act (“CCPA”), and the privacy rights they have under the CCPA. This section does not address or apply to our handling of personal information that is exempt under the CCPA.
Categories of Personal Information Collected and Disclosed. While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we have collected about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.
|Categories of Personal Information Collected||Categories of Third-Party Disclosures|
|Customer Records||Includes personal information, such as name, account name, user ID, contact information, education and employment information, account number, and financial or payment information that individuals provide us in order to purchase or obtain our Services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and Services.||
|Commercial information||Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach HCPs and other users and customers.||
|Internet and electronic network activity information||Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services.||
|Location data||Location information about a particular individual or device.||
|Audio, visual and other electronic data||Includes audio, electronic, visual, thermal, or similar information, such as, thermal screenings and video recordings/CCTV footage (e.g., collected from visitors to our offices, photographs and images (e.g., that you provide us or post to your profile) and call recordings (e.g., of customer support calls and webinars).||
|Professional information||Includes professional and employment-related information such as current and former employer(s) and position(s), business contact information and professional memberships).||
|Education Information||Information about an individual’s educational history, such as the schools attended, degrees you were awarded, and associated dates.||
|Profiles and inferences||Including inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, behavior or attitudes.||
|Protected classifications||We collect some information that is considered a protected classification under California/federal law, such as your gender, race/ethnicity, date of birth, marital status, sexual orientation, and disability status.||
|Biometric information||Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity.||
|Sensitive personal information||As identified above, in limited circumstances, we may collect Social Security Number (SSN) and other government identifier; racial or ethnic origin, personal information concerning a consumer’s health and/or sexual orientation, financial information, passport number and other government identifiers; race and ethnicity; sexual orientation and other data that may be considered protected classifications under California and federal law; and data concerning an individual’s health.||
Sales and Sharing of Personal Information. We may “share” (as defined by the CCPA) identifiers and profiles and inferences with third party ad companies and social networks in order to improve and evaluate our advertising campaigns and better reach health care providers and practitioners with more relevant content. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.
Sources of Personal Information. In general, we may collect the categories of personal information identified in the table above from the following categories of sources:
- Directly from the individual
- Advertising networks, analytics providers and social networks
- Service providers
- Affiliates and agents
- From healthcare professionals
- From contract research organizations and clinical trial investigators
- From government agencies and/or public records
- From third-party service providers, data brokers, or business partners
- From business and collaboration partners
- From industry and patient groups and associations
Purposes of Collection and Use. As described in more detail in Purposes of Use and Processing, we collect, use and otherwise process the above personal information in order to provide our Services to you, respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:
- Fulfilling and responding to requests
- Responding to your inquiries
- Administrative communications
- Marketing communications
- Administering clinical trials
- Payments and transaction
- Online services
- Security and protection of rights
- Planning and implementing business transactions
- Internal business purposes
- Legal and regulatory
Sensitive Personal Information. Notwithstanding the purposes described above, we do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA. Accordingly, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.
Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection, including an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, comply with legal obligations and
California Residents’ Rights. Under the CCPA, California residents have the following rights (subject to certain limitations):
- Opt out of sales and sharing: To opt-out of our sale and sharing of their personal information.
- Limit uses and disclosures of sensitive personal information: To limit certain uses or disclosures of sensitive personal information to those uses authorized by the CCPA. However, as noted we do not use or disclose your sensitive personal information beyond the purposes authorized by the CCPA.
- Deletion: to request deletion of their personal information, subject to certain exceptions.
- To know/access: to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
- Correction: to request correction of inaccurate personal information.
- Non-discrimination: to not be subject to discriminatory treatment for exercising their CCPA rights.
Submitting CCPA Requests. California residents may submit CCPA requests regarding their personal information maintained by us through our California Residents Only portal, or by calling our toll-free number, 1-833-746-2910. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. For requests to access/know, correct and delete, we will take steps to verify your request, which may include (i) sending you an email; and (ii) matching the information provided by you with the information we have in our records. You must provide us with adequate information to verify and process your request. If we are unable to adequately verify a request, we will notify the requestor. If you’re an authorized agent making a request on behalf of a consumer, we may require and request additional information and an authorization to verify that you’re authorized to make that request. We reserve the right to deny your request to access/know, correct and delete if we can’t verify your identify. Where we deny your request in whole or in part, we’ll endeavor to inform you of the denial, provide an explanation of our actions and provide the reasons for the denial. We won’t restrict or deny you access to our Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the Services. For example, if you apply to participate in a clinical trial and then ask Eisai to delete your information, we won’t be able to evaluate your eligibility for that trial or future trials.
For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.