Takeda UK Limited ('Takeda', 'we') is strongly committed to protecting your privacy and will make efforts to protect your personal data in accordance with the following privacy notice (“Notice”) which applies to the personal data that Takeda collects and processes in relation to users of the Chatbot.
Personal data collected
The type of personal data we collect may include:
Lawful basis of processing
Our processing of your personal data may take place where you have given us your consent to do so, such as when you have signed up to received emails, and is necessary: (i) in order to comply with a legal obligation to which we are subject; (ii) for the purposes of legitimate interests pursued by us, namely: (a) to provide guidance, support and experience to healthcare professionals that administer Takeda products (b) [to ensure patient safety; and (iii) in order to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Purpose for collecting personal data
Personal data collected by Takeda will be encrypted and stored by a third party service provider in a dedicated database and will only be accessed to send emails about the IBD Empower programme if you have consented to them, or to follow up either in Facebook Messenger or through another communication channel for the specific purpose of: (i) provide guidance, support and experience responding to or otherwise resolving an adverse event; or (ii) product complaint which is necessary for mandatory reporting to regulatory agencies.
Sharing of personal data
Takeda uses third party service providers to store personal data in a database. If you submit any manually inputted text, that text may be forwarded to appropriate Takeda third party contacts, who may be required, by law, to follow up either in Facebook Messenger or through another communication channel, such as email (if provided) if the text contains an adverse event or a product complaint. In these instances, additional information about you must be stored until all appropriate communication has occurred, which may include mandatory reporting to regulatory agencies. Takeda will not share your information with anyone who is not directly connected with this purpose.
Takeda will not directly access your personal data and only receive aggregated and anonymized information from third party service providers acting on its behalf, unless Takeda is required to do so because of applicable law, court order or governmental regulation.
Transfer of personal data outside of the EEA
Takeda has adopted Binding Corporate Rules, a system of principles, rules and tools, provided by EU law, in an effort to ensure effective levels of data protection for sharing personal data within Takeda, in particular relating to transfers of personal data outside the EEA.
Your personal data will be processed by third parties as described above. These third parties may be located in countries or territories outside the EEA or do not otherwise offer the same level of data protection as the country in which you reside. In instances where a lesser level of protection is provided by a receiving country, Takeda undertakes to enter into contractual agreements (e.g., European Union Standard Contractual Clauses), or relies on other available data transfer mechanisms that aim to provide adequate protections.
Retention of personal data
Personal data is retained by Takeda for a period of 1 year after which it is destroyed automatically. The period is defined as being one year following your last recorded interaction with the bot for your given Facebook ID. There may be cases when your personal data or part of it may be stored for a longer time period if Takeda is required to do so because of an applicable law, court order or governmental regulation or if such retention is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.
Protection of your personal data
Takeda has implemented appropriate technical and organizational measures to provide an adequate level of security and confidentiality to your personal data, taking into account the nature of the data and the risk of processing such data. The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing. Moreover, when handling your personal data, Takeda complies with the following obligations:
Exercise of access rights and contact details
You may exercise the following rights under the conditions and within the limits set forth in the law:
If you wish to query the data that is held on you at any time, you can do so by selecting the menu item in the Facebook Messenger that is labelled “Manage my data”. This will present you with options to:
If you have a question, if you are not satisfied how Takeda processes your personal data or if you want to exercise the above rights, you may send an email to firstname.lastname@example.org. When contacting Takeda, please add a description of your relationship and/or your interactions with us. If you wish to receive information related to your personal data, please also add a scan of your identity card for identification purpose, it being understood that we shall only use such data to verify your identity. When sending such a scan, please make sure to redact your picture and national registry number or equivalent on the scan. In addition, you also have the right to complain to the Information Commissioners Office https://ico.org.uk/global/contact-us/.
Date of Preparation: May 2020