Social Media Privacy Notice

Last updated: 3 April 2023

Astellas Pharma a/s, Arne Jacobsens Allé 15, 2300 Copenhagen S, Denmark – CVR.: DK10888638 (“Astellas“) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you in relation to any pages and accounts that Astellas may operate in social media platforms such as indicatively Facebook, Twitter, LinkedIn, and how you can exercise your privacy rights. This Privacy Notice also explains how Astellas uses personal information when engaged in social media monitoring activities in general (see below for more details). If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

Important note: Astellas is not responsible for the collection and use of your personal information by the social media platform providers, including in connection with any information you disclose to such other organizations through or in connection with Astellas social media accounts. We ask you to visit those social media platform providers and read carefully their Privacy Policies or Notices before you use their services for any purpose. Also, Astellas welcomes the opportunity to hear from you via mentions and replies or posts in our social media accounts, however we would like to ask you to ensure that you do not include any direct personal identifiers about you or any other person such as email addresses, home or business addresses or phone number in your posts and that you do not post any information containing proprietary, confidential, sensitive, or non-public information about you or any other individual or third party and that you fully respect the terms of service of such social media platform providers.

 

What does Astellas do?

Astellas is a global pharmaceutical business, whose ultimate parent company is headquartered in Tokyo, Japan. Our mission is to improve the lives of patients in the following key areas: transplantation, urology, oncology, anti-infectives, and haematology.

For more information about Astellas, please see the “About” section of our Website at https://www.astellas.com/eu/about/.

 

What personal information does Astellas collect and why?

We may collect personal information that you have made available to us in our social media channels (for example by sending a message or a post to an Astellas social media account) or made publicly available on public social media platforms (including blogs, forums etc.), related to Astellas, Astellas products, and more generally about disease and disease treatment. This activity is also called “social media monitoring. Astellas may process your personal information as part of campaigns on our social media accounts that involve targeting of individuals using mechanisms offered by the social media providers.

Astellas collects and uses the following categories of personal data for the purpose described below:

Types of personal information Why we collect it

Content of your profile, information on your activities and other information you share with us or make publicly available. This may include your personal information in form of comments, messages, blogs, photos and videos, your social media user name or social media ‘handle´, and any other information you may publicly disclose.

 

 We collect data on various social media platforms, including but not limited to LinkedIn, Twitter and Facebook (social media monitoring), to (i) have a better understanding of how healthcare professionals or patients experience certain diseases or react to the use of Astellas’ products, and of how public opinion develops, influenced by online stakeholders such as healthcare professionals, patient groups, journalists, publishers and politicians, (ii) have a better understanding of Astellas’ reputation as well as other market trends, (iii) identify key stakeholders from whom we may benefit interacting with, (iv) inform our communications activities, including the content and target audience of the posts from our social media accounts and other communication and/or marketing or non-promotional activities; this includes campaigns published in our social media accounts for which targeting mechanisms offered by the social media providers are used, and (v) to respond to your queries or process any adverse events reports or products complaints made by you via social media channels.

 

Who does Astellas share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • To our group companies, third party services providers and partners, who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A list of our current group companies is available here;
  • To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
  • To any other person with your consent to the disclosure.

 

Legal basis for processing personal information (EEA visitors only)

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above is our legitimate interests in so far as our interest is not overridden by your data protection interests or fundamental rights and freedoms. This also means that we will take appropriate steps to limit any personal information to the minimum necessary and keep it for no longer than necessary for any activities, including any social medial monitoring activity. Please note that if we use social media providers for targeting purposes, i.e. to identify appropriate users who may be interested in our campaigns and other initiatives in social media accounts, such social media providers, who may be joint controllers for those activities, will typically rely on the consent you have provided to those social media providers to receive advertising and/or to collect your personal information. If you wish to limit further who can see or process your personal information, we recommend that you use the privacy settings available to you on the relevant social media platform, e.g. LinkedIn or Facebook. We also suggest that you familiarize yourself with the privacy policy of the specific social media platform that you use, as these platforms are not owned and managed by Astellas.

In some cases, we may also have a legal obligation to collect personal information from you as in the case of reporting potential adverse events that may have been notified to us by you in our social media accounts or when conducting social media monitoring activities in publicly available posts or may otherwise need the personal information to protect your vital interests or those of another person, e.g. to inform patients of possible adverse side effects related to medication they are taking.

If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

 

How does Astellas keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include storing the personal information in an online system with restricted access for certain only users and the appropriate contractual and other technical safeguards.

 

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our servers are located in the United Kingdom, the USA and Japan, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

 

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

Your data protection rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
  • In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
  • Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

 

Information provided by minors

We do not knowingly collect personal information about anyone under the age of 18, unless we have a legal obligation, as described above.

 

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

 

How to contact us

To exercise any of your privacy rights, please submit your query here. If you have any questions or concerns about our use of your personal information, please contact our data protection officer using the following details: privacy@astellas.com.

The data controller of your personal information is Astellas Pharma a/s, Arne Jacobsens Allé 15, 2300 Copenhagen S, Denmark – CVR.: DK10888638.