Welcome to Ono's privacy policy. Ono respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Introduction

ONO Pharma USA and its affiliated legal entities (“OPUS”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy (“Privacy Policy”) describes the type of information that OPUS may collect from you or that you may provide when you visit the OPUS website (“Website”) or other online or mobile-enabled technology, digital tools and other services and products provided by OPUS (together with the Website, the “Platform”).

Use of the Platform is governed by this Privacy Policy and our Terms and Conditions. We encourage you to read this Privacy Policy in its entirety before using the Platform. This Privacy Policy is incorporated into our Terms and Conditions. It is also important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

This Privacy Policy may change from time to time (see “Revisions to Our Privacy Policy” below). Your use of the Platform after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. If any term in this Privacy Policy is unacceptable to you, please do not access or use the Platform or provide any personal data to OPUS.

This Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. You should check the privacy policies or terms of service for other websites or applications.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (if applicable), please contact us using the details set out in the “Contact Details” section below.

The Data We Collect About You

Personal data, or personal information, means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. It does not include data where the identity has been removed (anonymous data).

When you use the Platform, personal data may be collected directly from you, automatically as you navigate through the Platform or from third parties with whom we partner to provide you with services. The personal data we collect depends on the context of your interactions with the Platform and the choices you make, the services and features you use, your location, and applicable laws, but can include the following:

Personal Data You Provide

• Marketing and Communication Information. When you connect with us such as contact us, provide feedback or request marketing information be sent to you, we collect certain contact and other communication-related information you provide such as your name, mailing address, telephone number and email address. We also collect records and copies of your correspondence such as when you contact us with an inquiry about our Platform or services or to report a problem with our Platform.
• Demographic Information. If you complete a survey, we may receive personal data including demographic information, such as marital status and gender.
• Billing and Collection Information. We collect billing information such as your name, postal address, credit card or bank account information in order to provide services on the Platform, including when you purchase products. When you provide or update your payment processing information, we transmit the payment via an encrypted connection to a third-party credit card processor. OPUS does not collect or store your full credit card details.
• Account Information. When you register an account with OPUS, interact with or use the Platform, we may collect information such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, and other similar information you voluntarily provide.
• Third Parties. We also may combine the personal data that we have collected about you with other information about you obtained from other sources (both online and offline), such as from third parties and public sources. For example, if you connect with us on social media, including LinkedIn, so that we can provide you with news and other updates on these platforms, we may use the platforms’ data analytics and advertising tools to obtain personal data about you such as your demographics, interests, location and other characteristics, to use for research and analytical purposes, as well as for targeted or online behavioral advertising on other websites.
• Other Information. We may collect other personal data we specifically request or you voluntarily provide.

Data We Collect Automatically As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Device Information. When you use and access our Platform, we receive information about your device, which may include your web browser type, operating system version, device model, device manufacturer and model, your Internet Service Provider (ISP), and unique device identifiers. 
• Usage Information. We automatically receive information about your interactions with our Platform including details of your visits to our Platform, traffic data, location, logs, language, date and time of access, frequency and other communication data and the resources that you access and use on the Platform. 
• Details of Referring Websites (URL). We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). 

Cookies and Other Technologies

When you use our Website, we and our third-party service providers may collect information from you through the following ways:  

• Cookies:  We may collect some information from you using a “cookie.” “Cookies” are small bits of data cached or stored on your computer based on Internet activity. They can be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, help us track and understand how individuals use and interact with our Website and otherwise manage our Website.
  • There are two broad categories of cookies: 
    • First party cookies, served directly by us to your computer or mobile device. 
    • Third party cookies, which are served by a third party on our behalf.  We use third-party cookies for functionality, analytics, marketing and other technologies, and social media purposes. The third parties may change their terms of service, purpose and use of cookies, etc. See below additional information on how to manage such cookies. 
  • Cookies can remain on your computer or mobile device for different periods of time: 
    • Single-session (temporary) cookies: Temporary cookies last only as long as your web browser is open and are used for technical purposes such as enabling better navigation on our Website. Once you close your browser, the cookie disappears.  
    • Multi-session (persistent). Persistent cookies are stored on your computer or device for longer periods and are used for purposes including session management (for example, to recognize you and recall your individual login information and preferences). 
  • We generally use cookies to track the number of unique visitors to our Website and information such as the number of view a page gets, how much time a user spends on a page and other web statistics; monitor the performance of our Website and to continually improve it; and customize and enhance your online experience. 
• We classify cookies in the following categories:
  • Essential Cookies: These cookies are essential to provide you with services available through the Website and to use some of its features. Without these cookies we will not be able to provide services that you require, such as transactional pages and secure login accounts. 
  • Performance / Analytics Cookies: We use performance/analytics cookies to analyze how the website is accessed, used, or is performing. We do this in order to provide you with a better user experience and to maintain, operate and continually improve the Website.  For example, these cookies allow us to better understand our Website visitors so that we can improve how we present our content; determine the number of unique users of the website; and improve the website by measuring any errors that occur.  
  • Functional Cookies:  These cookies record information about choices you have made and allow us to tailor the Website to you by enhancing functionality and personalization. These cookies allow us to provide you with our services in the way in which you have required, as you continue to use or come back to our Site.  If you do not allow these cookies then some or all of these services may not function properly. 
  • Targeting Cookies: These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. 
• How to control or delete cookies:  You may have the right to decide whether to accept or reject cookies. Most browsers also allow you to adjust your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to adjust these settings, please consult the “Help” function of your browser, or the documentation published online for your particular browser type and version. 
• Web Beacons: We also collect information using web beacons (also referred to as gifs and pixels), alone or in conjunction with cookies. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or service tied to the web beacon, and a description of a website or service tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Website. We use web beacons to understand usage, and to operate and improve our Website and email communications. 
• Social Media Plug-ins: We may use social media plug-ins on our Platform to enable you to easily share information with others. We use the information collected from the plug-ins to learn about your interests and to help us better understand how to serve you. This information may include your preferences about how to contact you or further develop a business or professional relationship with you, your product preferences, languages, marketing preferences, and some demographic data. These plug-ins may include those from companies like Facebook, Instagram, Twitter and LinkedIn.1 The social media plug-ins may allow these companies to receive directly identifiable personal data about you and your visit to our Platform. When you visit our Platform, the operators of the social media plug-ins on our Platform place cookies on your computer that enable them to recognize you on websites belonging to them and their affiliates and partners after you have visited our Platform, or that enable them to add the information collected from your visit to our Platform with your prior activity on those websites. The social media plug-ins collect this information about users whether they specifically interact with the plug-in or not, and it may enable social media companies to share information about your web-browsing navigational information with some of their other users. OPUS does not control what information is collected by the social media plug-ins or the information practices adopted by those social media companies. For more information about social plug-ins from social media websites, you should refer to those companies’ privacy and data sharing statements.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under applicable law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. 

We do not collect any special categories of personal data about you, including, for example, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences. 

Failure to Provide Personal Data 

You are not required to provide us with any personal data that we request from you. However, failure to provide such data may limit what we are able to do for you. For example, refusing to provide your email address may prevent us from providing you with important information about the Platform and our services.

3. How We Use Your Personal Data

We have set out below, a description of how we process the information collected about you (including personal data), as well as the corresponding legal basis. We have also identified what our legitimate interests are where appropriate. We process your information where the processing is:  

• Necessary for entering into, or the performance of, a contract with you, in particular:  
  • To carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information, products and services you request from us; 
  • To register you as a new customer;  
  • To manage job opportunities at OPUS for recruitment; and 
  • To validate, confirm, verify, and track your account, products or services (including to process payment card transactions, or to contact you about your account, products or services). 

The personal data are necessary to enter and perform the contractual relationship with you. Without such information, we may not be able to enter into and OPUS the contractual relationship with you.

• Necessary for us to comply with a legal obligation.  
  • The processing of your personal data is a statutory requirement.  
• Necessary for the purposes of the legitimate interests pursued by a third party or us (to the extent it does not infringe on any individual’s fundamental rights and freedoms), in particular, OPUS’s legitimate interests in (i) managing its public and communication relations, (ii) providing information about its products and services, (iii) running its business, (iv) improving the user’s experience, (v) promoting OPUS’s position in the market, (vii) ensuring the proper functioning of the company for the following purposes:  
  • To provide you with technical support and to improve our content, products and services available through the Platform; 
  • To provide you with information that you have requested and respond to your inquiries submitted through email or any other means; 
  • To notify you of changes to our Platform, the Privacy Policy or our Terms and Conditions; 
  • To carry out promotional operations and direct marketing surveys (either directly or indirectly through a third party);  
  • If you are an existing customer, to communicate (including by email and text message) with you to provide information about goods and services similar to those that were the subject of a previous sale, that may be of interest to you or, where permitted by applicable law, were negotiations of a sale to you; 
  • To recognize your online activities over time and improve our content, products, and services; and 
  • To protect the security and integrity of the Platform, and our business, such as by protecting against fraud, unauthorized transactions, claims and other liabilities and managing risk exposure, including by identifying potential hackers and other unauthorized users; 
  • Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us;  
  • To use your data in an aggregated non-specific format for analytical and demographic purposes;  
  • To administer the Platform, including troubleshooting unexpected issues with your connected devices and other OPUS products, data analysis, testing, systems maintenance, support, and reporting and hosting of data; and 
  • If you use the Platform to connect with third-party services, to use information from and about you, on your behalf, to interact with these third-party services based on your requests. 
• Depending on the jurisdiction on which you reside, we rely on your consent as a legal basis for processing your personal data under the following instances:  
  • To provide you with third-party direct marketing communications via email or text message; and  
  • For any other purpose where you have provided consent where it is legally required. 

The provision of your personal data for such purposes is voluntary. If you do not want us to use your data in this way, simply do not opt in when we ask for your consent on the relevant forms on our Platform where we collect your data. You can withdraw your consent at any time with effect for the future and can always exercise your right to ask us not to process your personal data for marketing purposes by contacting us as specified in the section “Your Privacy Rights and Choices” or with regard to cookies, by disabling them on your browser.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out above.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosure of Personal Data

OPUS will only grant access to personal data on a need-to-know basis, and such access will be authorized and limited to the personal data that is necessary to perform the function for which such access is granted. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

Subject to applicable law and regulations, OPUS discloses the personal data we collect from and about you in the following ways:

• With internal third parties, such as affiliate companies and subsidiaries that are part of the “OPUS Group,” and act as controllers or processors and who are based in Japan, United Kingdom, South Korea and Taiwan and provide IT and system administration services and undertake leadership reporting. 
• With external third parties, including (i) service providers acting as processors based in Japan, United States of America, United Kingdom, South Korea and Taiwan who provide IT and system administration services; and (ii) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Japan, United States of America, United Kingdom, South Korea and Taiwan who provide consultancy, banking, legal, insurance and accounting services. Our external third parties are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. 
• With our agents, licensees, and other companies that assist us in providing a product or service to you, including, but not limited to, making your purchase and installation; providing you with customer assistance; processing and/or confirming your transactions; providing you with the services you requested; billing and collecting any amounts owed in connection with your account or products or services purchased; or recovering any monies due, such as through debt collection agencies; 
• With our select licensees, affiliates, retailers and business partners that we believe may have offers of interest to you, including for their own marketing purposes; 
• As necessary if we believe that there has been a violation of our Terms and Conditions or of our rights or the rights of any third party; 
• To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; 
• As otherwise described to you at the point of collection or with your consent when required by applicable law and regulations;  
• With 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 personal data held by one or more of our entities about our users is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal data provided through the Platform in a manner that is consistent with this Privacy Policy; 
• To insolvency administrators in the event of bankruptcy; and 
• To fulfill the purpose for which you provide it. For example, if you request us to contact a third party, we may transmit the content of your request to the recipient.

OPUS may also share aggregate or anonymous non-personal data about you and other users with third parties for their marketing or analytics uses, without restrictions.  

5. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at the details provided in the “Contact Details” section below. 

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Do Not Track

Some web browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our Platform does not currently respond to such signals. If you want to restrict ads in general on your devices, you may opt out from ad tracking by enabling “Limit Ad Tracking” or “Opt Out of Ads Personalization” (as applicable to your device) in your device settings.

If you wish to exercise any of the rights set out above, please contact us at the information provided in the “Contact Details” section below. We have also created the following mechanisms to provide you with control over your information, including personal data:

• Opt-Out From Marketing Communication.  You can opt out of receiving one of our emails by following the instructions for unsubscribing contained in the emails or by emailing [email protected] and asking to be removed from the mailing list. Please allow us ten (10) business days from when the request was received to complete the removal. Please note that even if you unsubscribe from commercial email messages, we may still email you non-commercial (transactional) emails related to your account and your transactions via the Platform. 
• Cookies.  The means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. Please note that if you disable functional cookies on your browser, some parts of the Website may not work fully. 

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

Verification Request

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Third-Party Websites

The Platform and email messages from us may contain links to third-party websites, which may have privacy policies that differ from our own. You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy. OPUS therefore encourages you to read the privacy policies and terms and conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal data. OPUS DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.

9. Children’s Privacy

We do not knowingly collect, maintain, or use personal data from children under 18 years of age, and no part of the Platform is directed to children under the age of 18. If you learn that your child has provided us with personal data without your consent, you must contact us at the email address provided in the “Contact Details” section below. If we learn that we have collected any personal data from children under 18, then we will promptly take steps to delete such information.

10. Revisions to Our Privacy Policy

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, the revised version will be effective the date it is posted, which is identified at the top of the page. Your continued access or use of the Platform following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing the Platform. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you. 

It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

11. Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways: 

For individuals in the U.S.:  

• Full name of legal entity: ONO Pharma USA
• Email address: [email protected]
• Postal address: 1 Main Street, Suite 1050, Cambridge, MA 02142