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GDPR PRIVACY NOTICE
Otsuka Electronics Co., Ltd. (hereinafter referred to as “Company”, “we”, “us”, or “our”) has established this Privacy Notice as a policy regarding the handling of personal data provided to us by our customers and other individuals (hereinafter referred to as “Customers”, “you”, or “your”) residing in the European Economic Area (EEA) or the United Kingdom ("UK"). Personal data subject to this Privacy Notice (hereinafter referred to as “Personal Data”) is limited to the definition of personal data covered by the EU General Data Protection Regulation (Regulation (EU) 2016/679) (hereinafter referred to as “EU GDPR”) and the UK General Data Protection Regulation (hereinafter referred to as “UK GDPR”) (the EU GDPR and the UK GDPR are hereinafter collectively referred to as the "GDPR").
１．Personal Data that we collect from Customers and other individuals
(1) Processing of Personal Data at our Company
The categories of Personal Data that we may obtain from Customers are listed in the table below. We respect the privacy rights of individuals and comply with the GDPR and other laws and regulations relating to data protection and privacy. We may collect certain information from you through cookies, when you visit our service-related websites. In addition, our marketing e-mails may contain tracking pixels and tracked links that allow us to see whether our e-mails are opened and which links are clicked. For a detailed breakdown of the information collected by cookies and how we use this data, please refer to our cookie policy.
We render various services to our Customers, and in connection with the provision of these services, we may process your Personal Data. In such cases, we ensure that we will obtain Personal Data by fair and appropriate means, notify the Customer or publicly announce the purpose of use of the Personal Data, obtain the consent of the Customer where required, and use and process the Personal Data only within the scope of its purpose.
The purposes and legal basis for the processing of Personal Data that we process as a controller are listed in the table below.
When we collect Personal Data from the Customers, we will clearly state whether the provision of Personal Data is a legal or contractual requirement for a Customer, or a requirement necessary to conclude a contract, as well as whether the Customer is obligated to provide such Personal Data to us, and of the possible consequences of failure to provide such Personal Data by the Customer.
In addition, while we may obtain the Customer’s consent for the processing of its Personal Data in certain cases, except where the legal basis is explicitly stated as “consent”, the legal basis for processing is typically based on the necessity of processing for pursuing legitimate interests or for the performance or conclusion of a contract.
(2) Withdrawal of Consent
Customers have the right to withdraw their consent at any time using the method specified by the Company at the time of obtaining consent. However, the legality of data processing that was based on consent before its withdrawal will not be affected by such withdrawal of consent. Customers have an absolute right to opt out of direct marketing at any time, and they may opt out of it, by following the instructions provided via electronic communication, or by contacting us using the contact information set forth in Section 8 of this Privacy Notice.
We do not make decisions based solely on automated data processing that would have legal or similarly significant effects on you.
| Specific purpose of processing | Categories of Personal Data | Legal basis for processing |
| Transaction and payment processing |
|
Performance of contracts |
| Response to inquiries |
|
Legitimate interests (to provide necessary information or respond appropriately to inquiries to provide better products, services, etc.) |
| Measuring engagement with our marketing e-mails (including whether e-mails are opened and which links are clicked) |
|
Customer consent |
| Analysis of website usage and improvement of our websites, products and services |
|
Customer consent |
２．International Data Transfer
Transfer of Your Personal Data Outside the UK or EEA
When transferring your Personal Data outside the UK or the European Economic Area (EEA), we ensure that an appropriate legal framework is in place. If the European Commission or the UK Government has recognized the destination country or region as ensuring an adequate level of protection for the rights you have over your personal data (Adequacy Decision), we rely on such Adequacy Decision. Otherwise, we secure the transfer by concluding Standard Contractual Clauses (SCCs) as defined in the European Commission Decision of June 2021 (Commission Implementing Decision (EU) 2021/914). Where applicable, for data transfers from the UK, we also conclude appropriate contractual arrangements, including the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs. You may obtain a copy of the non-confidential parts of the above safeguards concerning transfers made by us by contacting us at the contact information provided below.
Transfer of Your Personal Data to Japan
Your Personal Data may be transferred to and processed in Japan, where the Company is located. For transfers of Personal Data from the EEA to Japan, the Company relies on the European Commission’s adequacy decision in respect of Japan. For transfers of Personal Data from the UK to Japan, the Company relies on the UK’s adequacy regulations in respect of Japan.
Transfer of Your Personal Data to the United States
We use Google Analytics to analyze the use of our Website. In connection with this service, Cookie-related information about your visit to our Website is shared with Google LLC. The transfer of data via Cookies to Google may involve transfer to the United States; however, Google LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) or the UK Extension to the EU-U.S. DPF.
For further information on how Google LLC handles or transfers your data, please refer to Google's Privacy Policy as below.
https://policies.google.com/privacy
https://policies.google.com/privacy/frameworks
３．Sources of Personal Data
We collect Customer’s Personal Data either directly from the Customers or indirectly through third parties including:
- - Companies that provide data processing and hosting services;
- - Companies that provide us with data analytics and marketing tools (Google, Adobe, etc.);
- - Distributors of our products; and
- - Companies operating web advertisements to which the Customer made inquiries in response to the web advertisement regarding the Company.
４．Sharing of Personal Data
In accordance with the GDPR, we may disclose your Personal Data to the following categories of recipients for the purposes described in this Privacy Notice or otherwise communicated to you at the time your Personal Data is collected:
- a) our group companies, including our parent companies, Otsuka Pharmaceutical Co., Ltd. and Otsuka Holdings Co., Ltd.;
- b) our business partners and service providers, including manufacturers and distributors of our products, as well as third-party operators and vendors that support our website, mobile applications, documents, workflow management systems, and other business systems, such as technology vendors, delivery companies, payment processors, cloud service providers, and hosting service providers;
- c) competent law enforcement authorities, regulatory bodies, industry associations, government agencies, courts, or other third parties, where we believe such disclosure is (i) required by applicable law or regulation, (ii) necessary for the establishment, exercise, or defense of legal claims, or (iii) necessary to protect your vital interests or those of another person; and
- d) a prospective or actual buyer, and its representatives and advisers, in connection with any proposed or actual purchase, merger, acquisition, reorganization, or sale of all or part of our business, provided that such recipient uses your Personal Data only for the purposes permitted under this Privacy Notice and applicable law.
Some of the recipients described above may be located in Japan or in other countries outside the UK, the European Economic Area (EEA), or your country of residence. Where such transfers take place, we will implement appropriate safeguards in accordance with applicable data protection laws. Please see the section on “International Data Transfer” for further details.
５．Retention Period of Personal Data
We will retain the Customer’s Personal Data that we collect only for as long as it is necessary to achieve the purposes of use set out above. The specific period of retention will be determined by taking into account the purpose for which the Personal Data is to be used, the nature of the Personal Data, and the legal or business necessity to retain the Personal Data.
The retention periods applicable to each category of processing are set out in the table below.
| Purpose of processing | Categories of Personal Data | Retention period |
| Transaction and payment processing | Company name, department name and title, name, e-mail address, country/region, address, telephone number, order information/order history, payment information | For the duration of the contractual relationship, and for 20 years thereafter, or such longer period as required by applicable tax, commercial, or other laws |
| Response to inquiries | Company name, department name and title, name, e-mail address, country/region, address, telephone number, order information/order history, payment information | 1 year from the date of completion of the response to the inquiry |
| Analysis of website usage and improvement | IP address, cookie identifiers and other online identifiers, browser and device information, browsing behavior | 6 months |
Notwithstanding the above, we may retain Personal Data for longer periods where necessary to comply with applicable legal obligations (including tax and accounting requirements), to resolve disputes, or to enforce our contractual rights. Where Personal Data is no longer required for any of the above purposes, we will securely delete or anonymize such data.
６．Legal Rights of Data Subjects
You have the following rights with respect to the Personal Data that we collect and process. If you wish to exercise any of the following rights, please contact us by using the contact details set forth under Section 8 of this Privacy Notice. Additionally, without prejudice to any other administrative or judicial remedy, you have a right to lodge a complaint with a supervisory authority of the member state where you reside, work, or where the alleged infringement took place. If you are located in the United Kingdom, you may also lodge a complaint with us using the contact details set forth under Section 8 of this Privacy Notice, or with the Information Commissioner’s Office (ICO).
(1) Access to Personal Data
You have the right to receive confirmation from us as to whether or not your Personal Data has been processed, and if so, you have the right to access such Personal Data and certain related information.
(2) Correction/Deletion of Personal Data
You have the right to have inaccurate Personal Data relating to you corrected without undue delay or to have incomplete Personal Data made complete. You also have the right to have Personal Data relating to you erased without undue delay if certain requirements are met.
(3) Restrictions on processing of Personal Data
You have the right to have the processing of your Personal Data restricted if certain requirements are met.
(4) Data portability of Personal Data
You have the right to receive your Personal Data in a structured, commonly used, machine-readable format, and to transfer such data to another controller without hindrance from us, provided that certain requirements are met.
(5) Not to be subject to automated decision making
You have the right not to be subject to decisions (including profiling) based solely on automated data processing that have legal effects or similarly significant effects on you if certain requirements are met.
７．Right to Object to processing of Personal Data
You have the right to object, on grounds relating to your particular situation, to the processing of your Personal Data which is based on our legitimate interests (Article 6(1)(f) GDPR). We will cease processing unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims (Article 21(1) GDPR).
Where your Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of your Personal Data for such marketing. This is an absolute right that does not require any justification (Article 21(2) GDPR).
８．Contact Details
If you have any questions about this Privacy Notice or would like to make inquiries or requests regarding your rights as set forth in Section 6 of this Privacy Notice, please contact us at one of the following addresses:
(1) Otsuka Electronics Co., Ltd.
Address: 3-26-3, Shodai-Tajika, Hirakata City, Osaka, 573-1132, Japan
E-mail: OELJP-privacy@otsuka.jp
(2) EU representative
LCA Studio Legale
Address: Via della Moscova 18, 20121 Milano, Italy
Phone: +39 027788751
Email: milano@lcalex.it
(3) UK representative
Giambrone & Partners LLP
Salvatore Fasciana
Address:98 North Road, Brighton BN11YE, UK
Email: salvatore.fasciana@giambronelaw.com
９．Updates to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our processing activities, applicable laws, or regulatory guidance.
Where we make substantive or material changes to this Privacy Notice — such as changes to the purposes of processing, the categories of Personal Data processed, the identity of the controller, the recipients of Personal Data, or the manner in which you may exercise your rights — we will notify you of such changes prior to the changes taking effect by:
(a) posting the revised Privacy Notice on our Website, with a clear indication of the date of the most recent update and a summary of the key changes; and
(b) where we hold your e-mail address, sending you an e-mail notification informing you of the changes.
For changes that are not substantive or material (such as corrections of typographical errors, or minor stylistic amendments), we will update the Privacy Notice on our Website without separate notification to you.
Enacted on June 1, 2026.
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