Privacy Notice for Takeda Philippines HCP Websites

Effective date of this privacy notice: December 2024

Your privacy and the protection of your personal data is important to us. This Privacy Notice explains what type of personal data we may collect from you and how we use it for the purpose of our Customer Relationship Management (CRM).

Takeda is a globally operating group of companies. The Takeda enterprise includes the parent company Takeda Pharmaceutical Company Limited, and its affiliated entities (together “Takeda” or “We”). For contact information related to your local affiliate, please refer to Takeda website at: https://www.takeda.com/who-we-are/company-information/worldwide-offices/.

What Personal Data do we collect?

The personal data we collect includes your (business) contact information, professional life information (such as your curriculum vitae, professional certifications, licenses, and any other relevant documents, as well as information about your specialty and interests), medical registration licence number; and information about our interactions and meetings.

How do we collect your Personal Data?

Your personal data will be collected through your interactions with our staff, affiliates and/or representatives via our various channels and/or platforms, including but not limited to physical meetings; website interactions; phone and virtual conversations; social media account interactions (such as Instagram, Whatsapp, Viber, etc); and/or any written correspondence.

We may also collect personal data from third parties (including partners, government institutions and other parties whom we collaborate or partner with). In these conditions, we will only collect your personal data for or in connection with the purposes involving those third parties or the purposes of our collaboration with these third parties.

How do we Use your Personal Data?

Our processing of your personal data may be for our legitimate interests in promoting our products and disease awareness; to fulfil our contractual obligations towards you; to comply with our legal obligations; or based on your consent.

We process personal data about you for the following purposes:

To manage our interactions, including to respond to your inquiries and requests;
To perform conflicts of interest checks and such other checks as applicable;
To facilitate our sales and marketing of Takeda products;
To facilitate the organization of meetings and events;
To collaborate on our research and development activities;
To generate statistical information and analytical data for the purposes of testing, research, analysis, product development, commercial partnership and cooperation;
To provide you with information or product samples that may be of interest to you;
To manage, support and improve the efficiency of the performance, development, experience and functions of our services;
Where applicable, to comply with all obligations under prevailing laws and regulations, including but not limited to responding to requests, investigations or decisions in accordance with regulations, complying with filing, reporting and licensing requirements required by law and conducting audits, due diligence and investigations; and
Where necessary and/or applicable, for the purposes of administration and disclosing to the Department of Health (“DOH”), the Food and Drug Administration (“FDA”) and general public any payment or transfer of value made to, and/or received by, you by or on behalf of Takeda (collectively, “Transfers of Value”).

We may also process sensitive personal information about you, such as your medical registration licence number, in order to verify your identity, facilitate any Continuing Medical Education (“CME”) accreditation processes / activities you may participate in.

(Collectively, the “Purposes”)

Disclosure of your Personal Data

We may share your information with service providers and business partners around the world with whom we collaborate to fulfil the above purposes (e.g. travel agencies, event management agencies, contractors, fulfilment services, technical support, external consultants and external counsel). We may also share your information with other Takeda affiliates and subsidiaries.

The sharing of your personal data may involve transfers to other countries. The data protection and privacy laws in these countries may provide a different level of protection. Takeda will put in place appropriate safeguards to protect your personal data in connection with such transfers.

Disclosures of Transfers of Value under Disclosure Code(s)

Takeda is committed to abide by transparency requirements to disclose and publish details of all Transfers of Value provided to Healthcare Organisations (“HCOs”) and Healthcare Professionals (“HCPs”) in compliance with any applicable laws, rules, regulations and/or industry codes of practice including in particular under the EFPIA Code on Disclosure of Transfers of Value from Pharmaceutical Companies to Healthcare Professionals and Healthcare Organisations, Republic Act No. 11223 (Universal Health Care Act of the Philippines) and its implementing rules and regulations, as further clarified in the Department of Health Administrative Order No. 2021-0036 (“Disclosure Code(s)”).

Under the Disclosure Codes, Takeda and/or its affiliates is required to disclose the following details to the DOH through the FDA, which shall then make the information publicly available, in accordance with applicable laws:

your name, e-mail address, address of principal practice;
your contact information;
your hospital affiliation and name of the head of the establishment or organization;
your professional registration details (e.g. physician number);
Any transfers of value transfer of benefits or gains, whether in cash, in kind, or otherwise, made to, and/or received by, you, including, business meals, donations, educational grants, research funding, sponsorships related to events, travel, and accommodation, registration fees, honoraria, support for continuing professional development, royalties, current or prospective ownership or investment interest, consultancy or speakership fees, or other contractual arrangements, either given, incurred or reimbursed in cash or benefits in kind, from Takeda and/or its affiliates.

The above information is required to be submitted to DOH and FDA through FDA’s Online Disclosure Reporting System (“ODRS”) on or before 15th of July covering the report of the 1st half of the year, and on or before 15th of January of the succeeding year for reports covering the 2nd half of the preceding year, except that for 2021 submission, this may be disclosed on or before 15 September 2021, unless further extended by the FDA. Takeda will retain the information for a minimum period of ten (10) years after the end of the relevant reporting period. The disclosure reports filed in the ODRS system shall be made available to the public through a request to the DOH, using the Presidential Communication Operations Office-Freedom of Information online platform.

How Long do we Keep your Personal Data for?

We keep your personal data for the period necessary to fulfil the above Purposes; and for as long as your relationship with us persists, subject to local laws, regulations and legitimate business needs.

What are my Data Subject Rights?

You may have the right to request access to, rectification, erasure, and/or a transfer of your personal data, or object to or request restriction of its processing. Where our use of your personal data is based on your consent, you may also have the right to withdraw your consent at any time.

How to Reach Us

To exercise any right available to you, please send us your request using our Privacy Request Form at https://www.takeda.com/individualrights

If the form is not available in a language you would like to communicate in, or you have any other queries or requests, you may also contact Takeda’s Data Protection Officer at privacyoffice@takeda.com.

If you have a complaint on the way your personal data is being processed, you may also contact the National Privacy Commission.

For further information about how Takeda processes your personal data and your rights related to this processing please refer to Takeda’s Privacy Notice at www.takeda.com