PRIVACY POLICY

This US Privacy Policy (this “Policy”) describes how Eisai Inc. (“Eisai”, “we”, “us”) collects, uses, discloses and otherwise processes personal information, other than information about Eisai employees, as well as the rights and choices individuals have regarding the personal information we collect about them. For purposes of this Policy, “personal information” means information that identifies or is identifiable to (linked to, relates to) an individual natural person.

This Policy applies to the personal information of residents of the United States. Please be sure to read this entire Policy before using or submitting any personal information to us or using any of our websites or mobile applications that link to this Policy. Your use of our websites, mobile applications, products and services, including our clinical research and patient support programs, and other healthcare and patient programs we administer, sponsor, or operate (the “Services”), and any dispute over privacy, are subject to this Policy and the terms of service under our Legal Notices, including their applicable limitations on damages and the resolution of disputes.

If you are a resident of California, please also refer to the California Privacy Supplement for information about the categories of personal information we collect and your rights under California privacy laws.

If you are a resident of Nevada or Washington State, or believe your personal data might be collected in either of those states, please also review our Consumer Health Data Privacy Policy Supplement.

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. To the extent there is a conflict with this Policy, the additional notice will control 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 some or all of your personal information. We may, for example, seek your consent to collect and process information that may be considered sensitive, such as health information, genetic information financial account information, ethnic or racial origin, and other similar information.

Personal information you provide (directly or through others). 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 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 your parents or legal guardians
Financial information to complete a transaction or determine your 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

If you are 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 résumé 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 you from 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.
We may augment the personal information we have about you with information obtained from public databases and other third-party sources. For example, we may gather personal information from available third-party databases to confirm or verify licensure of healthcare professionals, or to better understand your interests by associating demographic information available from third-party sources with the information you have provided.

Information we may collect via automated means or derive about you. We and our service providers may automatically collect personal information related to your use of our Services and interactions with us. For example:

Device and browsing information. We and our service providers may use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. These technologies include:
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.

Google Analytics. Google Analytics allows us to better understand how our customers interact with our services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-on here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Double Click advertising cookie) or other third-party cookies to inform, optimize and display ads based on your past visits to our services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preference Manager, currently available at Ad Settings.

At this time, our websites do not respond to Do-Not-Track signals.

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. We may use any of the types of personal information described above for these purposes, but we will use only the specific types of personal information needed for each purpose.:

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 your contact and other 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. Subject to applicable law, we may use your contact and other personal information 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 “Your Choices and Rights ” section below.
Education and research. We may use your personal information 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 apply to participate in a clinical trial administered by Eisai, we will use personal information collected in connection with your application to determine your eligibility for a clinical trial now or in the future. If you participate in such a clinical trial, you will receive additional notices about how your personal information collected as a trial participant will be used in connection with the trial.
Patient advocacy and support programs. We may use your personal information to administer and manage patient advocacy and patient support programs.
Payments and transactions. We may use your financial information to complete requested transactions. We may also use your personal information to provide payment to individuals who receive honoraria.
Online services. We use information about how you and other users interact with our online services through our websites, apps and online tools to compile statistics for analysis of our Services and our business.
Security and protection of rights. We may use your personal information 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, or as evidence in litigation in which we are involved.
Profiles. We use your personal information to create a profile of you that reflects your preferences, characteristics, behavior, attitudes and abilities.
De-identified data. We may use your personal information to create de-identified, anonymized, and/or aggregated information that is not personal information because it cannot be used to identify you.
Planning and implementing business transactions. We may use your personal information 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 your personal information 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 your 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 information that we collect about you for the purposes described above (see “Purposes of Processing and Use”) and as otherwise directed or consented to by you. Generally, this includes disclosures in the following contexts:

To 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.
To our 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.
To our 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.
As part of 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 transaction, 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 transaction.
To third-party platforms, providers and networks. We may disclose or make available to third-party platforms and providers personal information 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 personal information available to third parties in support of our marketing, analytics, advertising and campaign management (see the Interest-Based Advertising section below for more information).
To law enforcement, government authorities, for 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 the terms and conditions for our Services
- 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, separate from this Policy, of such disclosures, except as required by applicable law.

AGGREGATE AND NON-IDENTIFIABLE INFORMATION

We may create, use and disclose aggregate, anonymous, and other non-identifiable data (data that is no longer linked or reasonably linkable to an identified or identifiable natural person, household, or personal or household device) for quality control, analytics, research, development and other purposes. Where we plan to maintain information in deidentified form, we will not attempt to reidentify you or anyone else from this data, except in order to determine whether our deidentification and anonymization processes are reasonable and adequate pursuant to applicable privacy laws. If we do re-identify any such data and therefore create personal information, we will treat the resulting personal information as such, in accordance with this Policy.

INTEREST-BASED ADVERTISING (IBA) AND MARKETING COMMUNICATIONS

In order to provide you with information about products and services in which you have expressed an interest, we may use certain of the personal information we have collected about you, or we may engage service providers to use your personal information, to deliver advertising to you about such products and services. For example, 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. 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 opt out of having your information used for IBA purposes on the device on which you’re accessing this Policy? Learn how

Want to see your current IBA status? Check it now

We also may share identifiers, profiles and inferences with third-party advertising companies and social networks in order to improve and evaluate our advertising campaigns and to better reach health care providers and practitioners with more relevant content. We offer you the opportunity to opt out of our sharing of your personal information for such targeted advertising, as indicated in the “Your Choices and Rights” section below.

If prefer not to receive promotional emails from us, you may opt out of receiving such emails by following the “unsubscribe” directions on any such email that you have received or contacting us as indicated in the “Contact Us” section below. We’ll endeavor to comply with your request as soon as reasonably practicable.

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.

YOUR CHOICES AND RIGHTS

You may have certain rights and choices regarding our processing of your personal information. Depending on your state of residence and other factors, applicable law may grant you the right to:

Opt out of the use of your personal information for certain targeted advertising.
Opt out of the selling your personal information
Request access to and a copy of your personal information, including to provide your personal information directly to another organization
Request a description of the personal information we have collected about you and the ways in which we process that information
Request correction of your personal information
Request deletion of your personal information.
Opt out of the processing of your sensitive personal information
Appeal the denial of a request;
Lodge a complaint with the data protection authority in your jurisdiction.

If you wish to exercise any rights with respect to your personal information that you may have in the state in which you live, please complete the form located here or, if you prefer, you can call us toll-free at 1-833-746-2910. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you Products and Services or it may otherwise affect the way we are able to interact with you.

We will process your request based upon your residence, applicable law, and 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. We reserve the right to deny your request to access/know, correct and delete if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to provide the reasons for the denial. You may submit an appeal of our denial of a request you have made by sending us a written explanation of your grounds for the appeal, either by postal mail or email, using the addresses provided in the “Contact Us” section below.

We will not 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 will not be able to evaluate your eligibility for that trial or future trials.

In the event you wish to make a complaint about how we process your personal information, please contact us at esi_privacyandrequests@eisai.com.

EISAI’S RECRUITING AND ONBOARDING PORTAL/SITE.

Eisai operates a talent recruiting and onboarding portal and website (“career portal/site”) to support Eisai’s recruitment efforts. This section of the Policy applies 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 that if you are 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 do not require, but you may voluntarily choose to provide, other relevant information as part of your application.

We would 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.

THIRD-PARTY SITES

The Services may contain links to and/or operate on third-party websites. These linked sites (including, without limitation, the websites of our affiliates in the Eisai group of companies) aren’t under Eisai’s control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. If you provide any personal information through any such third-party website, your transaction will occur on such third party’s website and the personal information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which aren’t governed by this Privacy Policy.

SECURITY

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 do not send us information you consider confidential via email.

DATA TRANSFERS

Any personal information you provide to us may be stored and processed, transferred between and accessed from the United States (including our group companies and our external IT service providers), Japan and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored/accessed. We take reasonable steps to ensure that the overseas recipients of your personal information adhere to applicable privacy obligations relating to your personal information.

CHILDREN’S PRIVACY

This website and any accompanying Services offered are not directed at children who are under 13 years of age, and we do not intend to provide information on our products to children under 13 years of age. (Please note, we may collect the Personal Information about minors in connection with other business activities, such as adverse event reporting.) Should we receive Personal Information online from a person who we know is under 13, we will endeavor to delete such information. 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.

RETENTION OF PERSONAL INFORMATION

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 business requirements.

CHANGES TO OUR PRIVACY POLICY

We may at any time in our sole discretion revise or update this Privacy Policy. We’ll post any changes on this page and indicate at the top of this page the date this Privacy Policy was last revised. You may read a current, effective copy of this Privacy Policy at any time by visiting this page. If we make material changes to how we collect, use and disclose the personal information we have previously collected about you, we will endeavor to provide you prior notice, such as by posting a prominent notice on our website or within the Services.

CONTACT US

If you have any questions, comments, requests or concerns related to this Privacy Policy, Eisai’s information practices or how to access this policy in another format, please contact us at:

Eisai Inc.
Privacy Office
200 Metro Blvd.
Nutley, NJ 07110
P: 833-746-2910
Fax: 201-746-2600
E: esi_privacyandrequests@eisai.com