Privacy Policy
Personal Information Protection Policy
Nitto Pharmaceutical Holdings, Ltd. and its group companies, namely Nitto Pharmaceutical Industries, Ltd. and Noster inc. (collectively, the "Group"), recognize that the protection of Personal Information is an important social responsibility and an essential element of sound corporate governance.
The Group has established the following policy and is committed to the appropriate protection and management of Personal Information in the course of its business activities.
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Compliance with Applicable Laws and Regulations
The Group shall comply with:-
the Act on the Protection of Personal Information of Japan ("APPI");
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applicable governmental guidelines issued by competent authorities;
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applicable data protection and privacy laws;
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industry standards; and
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other relevant legal and regulatory requirements governing the handling of Personal Information.
The Group shall process Personal Information in accordance with such laws, regulations, and standards.
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Collection, Use and Disclosure of Personal Information
The Group shall identify the purposes of use of Personal Information to the extent necessary for its business operations and shall acquire, use, and disclose Personal Information appropriately and lawfully.
The Group shall implement appropriate measures to prevent the use of Personal Information beyond the scope of the specified purposes of use.
Except in the following circumstances, Personal Data will not be disclosed or provided to any third party without the prior consent of the individual concerned:-
where disclosure is required or permitted by applicable law;
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where processing is entrusted to a service provider to the extent necessary to achieve the stated purposes of use;
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where Personal Information is shared pursuant to a lawful joint-use arrangement;
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where disclosure is otherwise authorized under applicable laws and regulations.
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Joint Use of Personal Information
Categories of Personal Information Subject to Joint Use
The categories of Personal Information that may be jointly used include:-
name;
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residential address;
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telephone number;
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email address;
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other contact details; and
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all other Personal Data held by the Group relating to the individual concerned.
Entity Responsible for Joint Use
For purposes of joint use within the Group, the following entity shall be responsible for the management of Personal Information:Noster inc.
35-3 Minamibiraki, Kamiueno-cho,
Muko City, Kyoto 617-0006, Japan
Representative Director: Kohey Kitao -
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Security Management Measures
The Group shall implement necessary and appropriate organizational, personnel, physical, and technical security measures to protect Personal Information against:-
unauthorized access;
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loss;
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destruction;
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alteration;
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leakage; and
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other security incidents.
Where Personal Information is disclosed or provided to a third party for outsourced processing or joint use, the Group shall exercise appropriate supervision and management over such third party.
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Continuous Improvement
The Group shall continuously review, evaluate, and improve its organizational structure, internal rules, operational procedures, and management systems relating to the protection of Personal Information in order to ensure their ongoing effectiveness.
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Inquiries, Requests for Disclosure, and Complaints
The Group shall respond sincerely, appropriately, and without undue delay to:-
inquiries concerning Personal Information;
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requests for disclosure;
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requests for correction, addition, deletion, or suspension of use; and
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complaints regarding the handling of Personal Information,
in accordance with applicable laws and regulations.
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Use of Cookies and Similar Technologies on the Group's E-Commerce Website
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Cookies
The Group's use of cookies shall be governed by the Group's Cookie Policy. Cookies may be used to support the operation, functionality, security, and performance of the Group's online services. -
Advertising Using Facebook Custom Audiences
The Group may use Meta's Facebook Custom Audiences service to display advertisements based on an individual's use of the Group's services.
For such purposes, Personal Information held by the Group and information held by third-party advertising providers may be transformed into a form that does not directly identify individuals and matched through privacy-protective processes.
Advertisements may then be delivered based on the results of such matching.
Third-party advertising providers are not permitted to use such information for purposes unrelated to advertising activities conducted on behalf of the Group.
Users may review information regarding Facebook Custom Audiences through the applicable Meta business resources and may manage personalized advertising preferences through Meta's advertising settings and opt-out tools.
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Requests for Disclosure and Other Privacy-Related Requests
Requests concerning disclosure, correction, deletion, suspension of use, or other rights relating to Personal Information should be directed to:Personal Information Handling Representative
Noster inc.
35-3 Minamibiraki, Kamiueno-cho
Muko City, Kyoto 617-0006, Japan
Telephone: +81-75-921-5303 -
Contact Point for Questions and Complaints
Questions, concerns, and complaints regarding the Group's handling of Personal Information may be directed to:Personal Information Handling Representative
Noster inc.
35-3 Minamibiraki, Kamiueno-cho
Muko City, Kyoto 617-0006, Japan
Telephone: +81-75-921-5303 -
Personal Information Handling Business Operator
The business operator responsible for the handling of Personal Information is:Noster inc.
35-3 Minamibiraki, Kamiueno-cho
Muko City, Kyoto 617-0006, Japan
Representative Director: Kohey Kitao
Telephone: +81-75-921-5303
PURPOSES OF PROCESSING PERSONAL INFORMATION
The Group may use Personal Information acquired or retained by the Group for the purposes described below.
Unless otherwise notified to the relevant individual or otherwise disclosed on the Group's website, Personal Information shall not be used for purposes other than those set forth in this Policy.
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Healthcare Professionals
Categories of Individuals
This section applies to:-
physicians;
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dentists;
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nurses;
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pharmacists;
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pharmacies and drugstores; and
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other healthcare professionals.
Purposes of Processing
The Group may process Personal Information and Retained Personal Data relating to healthcare professionals for the following purposes:-
Proper Use Information
To provide and collect information relating to the proper use of the Group's pharmaceutical products, quasi-drugs, health products, and related services. -
Product Quality, Safety and Efficacy
To provide, collect, assess, and maintain information relating to the quality, safety, efficacy, and performance of the Group's products. -
Medical and Pharmaceutical Research
To conduct, support, and participate in research and investigations in the fields of medicine, pharmaceuticals, healthcare, and life sciences. -
Medical and Scientific Communications
To provide, obtain, evaluate, and exchange medical information and academic or scientific information. -
Clinical Trials and Post-Marketing Activities
To request, support, conduct, and manage:-
clinical trials;
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observational studies;
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post-marketing surveillance;
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safety monitoring activities; and
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related scientific investigations.
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Product Development Activities
To support and conduct product development activities and investigations relating to the use of the Group's products. -
Regulatory Compliance
To submit notifications, reports, and other required filings to governmental authorities and regulatory agencies.
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Persons Making Inquiries and Users of Group Contact Desks
Categories of Individuals
This section applies to:-
persons making inquiries;
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users of customer support channels;
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users of consultation services; and
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other individuals using contact points operated by the Group.
Purposes of Processing
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Inquiry Management
To review, investigate, and respond to inquiries, requests, consultations, reports, and communications submitted to the Group. -
Product Quality, Safety and Efficacy
To provide, collect, assess, and maintain information relating to the quality, safety, efficacy, and performance of the Group's products. -
Communications with Relevant Parties
To communicate and provide information to:-
marketing authorization holders;
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manufacturers;
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distributors;
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healthcare professionals; and
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other relevant stakeholders.
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Regulatory Reporting
To make reports, notifications, and disclosures required by applicable laws and regulations.
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Survey Participants and Campaign Applicants
Categories of Individuals
This section applies to individuals who have participated in:-
customer surveys;
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questionnaires;
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promotional campaigns;
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contests; and
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other initiatives organized by the Group.
Purposes of Processing
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Marketing Analysis
To conduct data analysis for:-
sales activities;
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promotional activities;
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marketing strategy development;
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market research; and
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business planning.
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Information Distribution
To provide information relating to:-
survey programs;
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campaigns;
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promotional activities;
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products; and
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services offered by the Group.
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Facility Visitors and Tour Participants
Categories of Individuals
This section applies to:-
visitors seeking tours of Group facilities; and
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persons entering Group premises.
Purposes of Processing
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Visitor Administration
To provide explanations and assistance relating to visits, tours, and entry procedures and to manage access to and departure from Group facilities. -
Post-Visit Communications
To respond to inquiries or communications received following visits or tours.
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Shareholders
Categories of Individuals
This section applies to shareholders of the Group.Purposes of Processing
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Exercise of Shareholder Rights
To facilitate and respond to the exercise of rights granted to shareholders under the Companies Act and other applicable laws. -
Compliance with Legal Obligations
To fulfill obligations imposed upon the Group under:-
the Companies Act;
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securities laws; and
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other applicable laws and regulations.
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Shareholder Administration
To prepare shareholder records and conduct shareholder management activities. -
Distribution of Corporate Materials
To distribute:-
annual reports;
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business reports;
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shareholder communications; and
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other corporate materials.
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Business Partners and Industry Stakeholders
Categories of Individuals
This section applies to:-
officers and employees of marketing authorization holders;
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manufacturers;
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distributors;
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suppliers;
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service providers;
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government officials;
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officers and employees of corporations;
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incorporated administrative agencies;
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foundations;
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associations;
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academic societies;
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research institutions; and
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other organizations having business, operational, or industry-related relationships with the Group.
Purposes of Processing
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Business Communications
To communicate regarding:-
commercial transactions;
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business operations;
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partnerships; and
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industry activities.
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Proper Use Information
To provide and collect information concerning the proper use of pharmaceuticals, quasi-drugs, and related products. -
Quality, Safety and Efficacy Information
To provide, collect, and evaluate information regarding product quality, safety, and efficacy. -
Medical and Scientific Information
To provide, collect, review, and exchange medical and scientific information. -
Communication with Industry Participants
To communicate with:-
healthcare professionals;
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manufacturers;
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distributors; and
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other relevant stakeholders.
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Regulatory Compliance
To submit notifications and regulatory reports to governmental authorities.
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Job Applicants
Categories of Individuals
This section applies to individuals applying for employment with the Group.Purposes of Processing
Personal Information may be processed for:-
recruitment screening;
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applicant evaluation;
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hiring decisions;
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interview administration; and
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communications relating to employment opportunities.
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E-Commerce Customers
Categories of Individuals
This section applies to customers using the Group's mail-order and e-commerce services.Purposes of Processing
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Order Fulfillment
To process and deliver purchased products and services. -
Payment Processing
To process payments and manage billing-related matters. -
Product and Service Information
To provide information relating to products, services, promotions, and related offerings. -
Customer Support
To respond to inquiries and provide customer support services. -
Surveys and Research
To request participation in surveys and other research activities. -
Marketing and Business Analytics
To conduct information analysis for:-
promotional activities;
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customer insights;
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product development; and
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marketing strategy formulation.
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Regulatory Compliance
To meet reporting and compliance obligations required by law.
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Employees, Former Employees and Family Members
Categories of Individuals
This section applies to:-
current employees;
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former employees; and
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family members and dependents of employees.
Purposes of Processing
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Human Resources Planning
To plan and implement strategies relating to:-
organizational management;
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personnel administration;
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employee welfare;
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occupational health and safety; and
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training and education.
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Business Communications
To facilitate business-related communications within the Group. -
Employment Administration
To administer:-
recruitment;
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evaluation;
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compensation;
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benefits;
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promotions;
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disciplinary measures;
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attendance management;
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occupational health and safety;
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disaster preparedness; and
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employee training programs.
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Audits and Compliance Monitoring
To conduct reviews, inspections, confirmations, and audits necessary for the proper operation of the Group's business activities. -
Regulatory Reporting
To make legally required reports and submissions to governmental authorities. -
External Communications
To communicate with:-
business partners;
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industry organizations; and
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other stakeholders involved in the Group's business operations and industry activities.
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GDPR PRIVACY NOTICE
This GDPR Privacy Notice applies to the processing of Personal Data through the website operated by Nitto Pharmaceutical Holdings, Ltd., Nitto Pharmaceutical Industries, Ltd., and Noster inc. (collectively, the "Group").
This Notice is intended to satisfy the transparency requirements of Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR").
Before using the Group's website, users are encouraged to read this GDPR Privacy Notice carefully.
Article 1. Scope of this Privacy Notice
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Scope
This GDPR Privacy Notice applies to individual users of the Group's website and to the processing of Personal Data conducted through the website where GDPR or other applicable privacy laws are applicable. The Group acts as the Data Controller with respect to such processing activities unless otherwise specified. -
Third-Party Content and Websites
The website may contain information, services, banners, hyperlinks, or other content provided by third parties.
The Group does not control such third-party websites or services and is not responsible for the privacy practices, policies, or legal compliance of any third party.
Users are encouraged to review the privacy policies of any third-party website before providing Personal Data or otherwise interacting with such website.
Article 2. Personal Data Collected
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Categories of Personal Data
The Group may collect and process the following categories of Personal Data from users of the website:-
Full name;
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Address and location information;
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Order-related information;
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Customer service information;
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Email address;
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Username and password;
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IP address;
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Payment details;
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Employment-related information;
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Curriculum vitae (CV) or resume information;
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Cookie-related information; and
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Other information voluntarily submitted through the website.
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Special Categories of Personal Data
The Group does not intentionally collect special categories of Personal Data, such as passport information, health data, or other sensitive personal information, through the website. -
Sources of Data Collection
Personal Data may be collected when users:-
create an account;
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place an order;
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apply for employment through the website;
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communicate with the Group;
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subscribe to services; or
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otherwise use the website.
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Lawful Processing
The Group processes Personal Data only in accordance with applicable privacy laws and only for the purposes described in this GDPR Privacy Notice.
Article 3. Purposes of Processing and Legal Bases
The Group collects and processes Personal Data solely for legitimate and specified purposes.
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Performance of a Contract
Where users place orders or otherwise enter into contractual relationships with the Group, Personal Data may be processed as necessary to:-
administer contracts;
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fulfill orders;
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provide products and services;
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process transactions; and
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perform pre-contractual activities requested by users.
The Group will not process Personal Data beyond what is reasonably necessary for contract performance.
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Communications
The Group may process Personal Data in order to:-
communicate regarding products and services;
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manage customer accounts;
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provide important service notices;
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maintain account functionality;
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respond to inquiries; and
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address complaints.
Where a user creates an online account, Personal Data may be retained to facilitate future access and reduce repetitive data entry.
The Group's legitimate interests include the effective administration of its business operations and customer relations. -
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Marketing
The Group may communicate with users regarding products, services, promotions, and related offerings.
Except where permitted under applicable law in connection with products or services similar to those previously purchased by a user, the Group will obtain prior consent before sending marketing communications.
Users may unsubscribe from marketing communications at any time.
The Group's legitimate interests include maintaining business relationships and informing users about products and services that may be relevant to them. -
Customer Service
Where users contact customer support, the Group may process Personal Data in order to:-
investigate reported issues;
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provide support services;
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administer customer relationships; and
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improve service quality.
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Recruitment Activities
Where an individual applies for employment through the website, the Group may process Personal Data to:-
evaluate applications;
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conduct recruitment reviews;
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communicate with candidates; and
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make hiring decisions.
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Additional Processing Activities
If the Group intends to process Personal Data for purposes other than those for which it was originally collected, the Group shall provide information regarding such additional purposes and any related information required by applicable law before commencing the additional processing.
Article 4. Transfer of Personal Data to Third Parties
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Processors and Service Providers
The Group may disclose Personal Data to third-party vendors, contractors, and service providers that process Personal Data on behalf of the Group where such processing is necessary to achieve the purposes described in this Notice.
Such processors shall be selected in accordance with the Group's internal standards and shall be subject to appropriate contractual, organizational, and supervisory measures. -
Joint Use with Group Companies
The Group jointly uses certain e-commerce customer information with Noster inc. in connection with online sales activities.Categories of Data
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Name
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Date of birth
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Contact details
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Purchased product information
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Quantity purchased
Purpose
Provision of after-sales support and customer service.Responsible Entity
Noster inc. -
Article 5. Security
The Group implements appropriate technical and organizational measures designed to protect Personal Data against unauthorized processing, loss, destruction, disclosure, or alteration.
Access to Personal Data is limited to employees, representatives, contractors, and service providers who have a legitimate need to access such data.
All such recipients are subject to confidentiality obligations arising under employment agreements, processing agreements, or applicable law.
Article 6. Retention of Personal Data
The Group shall retain Personal Data only for as long as necessary to fulfill the purposes for which the data were collected and processed.
Users may request deletion of Personal Data at any time.
Where Personal Data is no longer necessary for the purpose for which it was collected or processed, the Group will delete or otherwise remove such Personal Data, subject to applicable legal requirements.
Article 7. Cookies
The Group's use of cookies and similar technologies is governed by the Group's Cookie Policy.
Additional information regarding cookies is available in the section of COOKIE POLICY of this Privacy Framework.
Article 8. Rights of Data Subjects
Subject to applicable law, users may exercise the following rights.
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Right to Withdraw Consent
Where processing is based upon consent, users may withdraw consent at any time. Withdrawal shall not affect the lawfulness of processing conducted before withdrawal. -
Right of Access
Users have the right to request access to Personal Data concerning them and to obtain a copy of such Personal Data. -
Right to Rectification
Users may request correction of inaccurate Personal Data and completion of incomplete Personal Data. -
Right to Erasure
Users may request deletion of Personal Data where permitted by applicable law, including where the Group lacks a continuing legal basis for processing. -
Right to Object
Users may object to processing based upon the Group's legitimate interests.
Where processing is conducted for direct marketing purposes, the Group shall honor such objections without exception.
For all other processing activities, the Group may continue processing only where compelling legitimate grounds outweigh the interests, rights, and freedoms of the individual or where processing is necessary for legal proceedings. -
Right to Lodge a Complaint
Users may lodge a complaint with a competent supervisory authority, including the supervisory authority located in:-
their habitual residence;
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their place of work; or
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the location of the alleged GDPR infringement.
The Group welcomes the opportunity to address concerns directly before a complaint is submitted to a supervisory authority.
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Minors
Individuals under sixteen (16) years of age must obtain parental or guardian authorization where required by applicable law before exercising rights or using services requiring consent.
Article 9. Contact Information
Questions, complaints, or requests to exercise rights under Article 8 may be directed to:
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Noster inc.
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Telephone:
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+81-75-921-5303
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Business Hours:
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Monday to Friday, 9:00 a.m. to 5:00 p.m. (excluding public holidays and company holidays).
Article 10. Data Protection Authorities
In addition to the rights described above, individuals residing in the European Union, working within the European Union, or otherwise protected by GDPR may submit complaints to the competent supervisory authority.
The Group respectfully requests that users contact the Group before escalating concerns to a supervisory authority so that the matter may be reviewed and addressed promptly.
Article 11. General Provisions
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Account Removal
The Group reserves the right to remove or deactivate website accounts at any time without prior notice where permitted by applicable law.
The Group shall not be liable for losses arising from such removal except to the extent required by law. -
Amendments
The Group reserves the right to revise this GDPR Privacy Notice periodically.
Users are encouraged to review this Notice regularly. According to the Japanese source document, the notice was last revised in September 2022. -
Severability
If any provision of this Notice is determined to be invalid, unlawful, or unenforceable, such provision shall be replaced to the extent possible by a valid provision reflecting the original intent, and the remaining provisions shall remain in full force and effect.
COOKIE POLICY
This Cookie Policy applies to the website operated by Nitto Pharmaceutical Holdings, Ltd., Nitto Pharmaceutical Industries, Ltd., and Noster inc. (collectively, the "Group"). This Cookie Policy should be read together with the Group's Privacy Policy and GDPR Privacy Notice.
Introduction
Before accessing or using the Group's website (the "Website"), please carefully read this Cookie Policy. By continuing to browse or use the Website, you acknowledge and agree to the use of cookies and similar technologies as described herein.
If you do not agree to the use of cookies, you may disable cookies through your browser settings. Please note that disabling cookies may adversely affect the availability and functionality of certain features of the Website.
What Are Cookies?
When you visit the Website, information relating to your visit and browsing activities may be collected through cookies and similar technologies. A cookie is a small text file consisting of letters, numbers, and other characters that is stored on your computer, smartphone, tablet, or other device.
Cookies help websites recognize devices, remember user preferences, improve functionality, and collect analytics information regarding website usage.
Cookies may either be:
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Session Cookies, which expire when the browser session ends; or
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Persistent Cookies, which remain on the device until deleted or expired.
Purposes of Cookie Use
The Group uses cookies primarily to:
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improve user convenience;
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maintain and enhance website quality and performance;
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support website functionality;
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improve security;
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analyze website usage patterns;
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support marketing and advertising activities; and
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improve the overall user experience.
The Group does not use cookies for the purpose of directly obtaining personal information. Furthermore, information collected solely through cookies generally does not enable the Group to identify a specific individual.
Types of Cookies Used
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Strictly Necessary Cookies
Strictly Necessary Cookies are essential for the operation of the Website and the provision of its core functionality. These cookies enable users to navigate the Website and access secure areas and functions.
Without these cookies, certain Website services may not function correctly.
Typical purposes include:-
session management;
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security functions;
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user authentication;
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website stability; and
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operational functionality.
These cookies are generally temporary session cookies and are deleted automatically when the browser is closed.
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Analytics and Performance Cookies
Analytics and Performance Cookies collect information regarding how visitors interact with the Website, including information such as:-
frequently visited pages;
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navigation patterns;
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time spent on pages;
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technical performance metrics; and
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website traffic statistics.
The information collected through these cookies is used for the purpose of evaluating and improving the performance, usability, and effectiveness of the Website.
These cookies do not ordinarily identify an individual visitor. Information is generally aggregated and anonymized before analysis. -
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Functionality Cookies
Functionality Cookies allow the Website to remember information previously provided by users and enhance personalized features.
Examples include:-
preferred language settings;
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regional preferences;
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consent settings; and
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other website customization choices.
Functionality Cookies may also be used to record whether users have previously viewed notices, disclaimers, consent banners, or policy statements in order to avoid repeatedly displaying the same information.
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Third-Party Cookies
The Website may include services, technologies, tools, applications, or content provided by third parties. Such third parties may use cookies and similar technologies independently of the Group.
Examples include:
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website analytics providers;
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advertising and marketing platforms;
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social media platforms;
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traffic analysis services; and
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external content providers.
Some cookies used on the Website may therefore originate from third-party providers rather than directly from the Group.
The Group does not control the operation of third-party cookies and accepts no responsibility for the privacy practices of such third parties. Users should consult the applicable privacy policy or cookie policy of the relevant service provider for additional information.
Certain third-party providers may also track browsing behavior across websites and online services in accordance with their own privacy policies.
By using the Website, users acknowledge that third parties may process data in accordance with their own privacy notices and applicable laws.
Advertising Delivered Through Cookies and Similar Technologies
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Facebook Custom Audiences
The Group may use Meta's Facebook Custom Audiences service to provide advertisements tailored to users who have interacted with the Group's products, services, or websites.
For these purposes:-
Personal Information held by the Group and information held by third-party advertising providers may be transformed using privacy-protective methods designed to prevent direct identification of individuals;
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matching may be performed by advertising providers; and
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advertisements may be delivered based on the results of such audience matching.
The Group does not authorize participating advertising providers to use such information for purposes unrelated to the advertising activities requested by the Group.
Additional information regarding Facebook Custom Audiences can be obtained through Meta's business resources and privacy documentation. Users may opt out of personalized advertising through Meta's advertising settings and available preference management tools. -
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Online Behavioral Advertising
The Group partners with multiple advertising providers, including providers operated by Yahoo and Google, to display advertisements across the internet.
Advertising providers may use:-
cookies;
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access data;
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Group identifiers;
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browsing information; and
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demographic or interest-based information
for the purpose of delivering advertisements that may be relevant to users' interests and preferences.
Where users permit cookies through browser settings, advertising providers may collect information regarding visits to the Website and may use such information for advertising activities on third-party websites and platforms.
Information collected by advertising providers is governed by the privacy policies and terms of those providers. -
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Yahoo Advertising Services
The Group may participate in advertising services operated by Yahoo Japan and related partners.
Users may manage advertising preferences and available opt-out settings through Yahoo's designated advertising preference tools. -
Google Advertising Services
The Group may participate in advertising services operated by Google and its affiliated advertising networks.
Google may use cookies, advertising identifiers, and related technologies to display advertisements based on users' browsing activities and interests.
Users may manage advertising settings and opt-out choices through Google's advertising preference controls. -
Opt-Out Rights
Users may be able to stop the use of cookies and advertising-related data by advertising providers by visiting the relevant provider's opt-out page and following the instructions provided by that provider.
Please note that opting out may:-
reduce the relevance of advertisements displayed;
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result in repeated display of the same advertisements; or
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otherwise affect the personalization of advertising content.
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Managing Cookies
Users may control, disable, delete, or block cookies through browser settings.
Most browsers allow users to:
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reject all cookies;
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reject certain categories of cookies;
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delete previously stored cookies;
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receive notifications when cookies are placed; and
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configure site-specific cookie preferences.
If all cookies, including Strictly Necessary Cookies, are blocked, some portions of the Website may become inaccessible or may not function properly.
Additional Information Regarding Cookies
Further information regarding cookies and cookie management may be available through independent educational resources concerning internet privacy and browser technology.
Users are encouraged to consult their browser provider's instructions to understand how cookie controls operate on their device.
Amendments to this Cookie Policy
The Group reserves the right to revise, amend, update, or modify this Cookie Policy at any time.
Any changes shall become effective immediately upon publication on the Website unless otherwise specified. Users are encouraged to review this Cookie Policy periodically.
Contact Information
Questions or concerns regarding this Cookie Policy may be directed to:
Personal Information Handling Representative
Noster inc.
35-3 Minamibiraki, Kamiueno-cho
Muko City, Kyoto 617-0006, Japan
Telephone: +81-75-921-5303