CONSUMER HEALTH DATA PRIVACY POLICY

EFFECTIVE DATE:

Introduction

Thank you for your interest in Otsuka Precision Health, Inc., (“OPH”) and its subsidiaries and affiliates (“OPH”, “us”, “we”). OPH values your privacy and the security of your personal information. This Consumer Health Data Privacy Policy applies only in limited circumstances when we may handle health information subject to the Washington My Health My Data Act (“MHMDA”), the Nevada Health Data Privacy Act (“NHDPA”), or other applicable state consumer health privacy laws (“Consumer Health Data”). This Consumer Health Data Privacy Policy does not apply to data about our own employees, contractors, agents, or job applicants, and does not apply to data that we handle as a “processor” on behalf of our customers (in which case, our business customers (not OPH) control how your personal information is handled).

Sources of Consumer Data

As described further in the How Otsuka Collects Personal Information, Information from External Sources, and Research/Survey Solicitations sections of the OPH Privacy Policy, we collect Personal Information (which may include Consumer Health Data) directly from you, from your interactions with our products and services, from third parties, and from publicly available sources.

Types of Consumer Health Data We Collect

The data we collect depends on the context of your interactions with OPH and the choices you make (including your privacy settings), the products and services you use, your location, and applicable law. Because Consumer Health Data is defined very broadly, many of the categories of data we collect could also be considered Consumer Health Data.

This may include:

Individual health conditions, treatment, diseases, or diagnosis;
Social, psychological, behavioral, and medical interventions;
Health-related surgeries or procedures;
Use or purchase of prescribed medication;
Bodily functions, vital signs, symptoms, or measurements of health information;
Diagnoses or diagnostic testing, treatment, or medication;
Genetic data;
Precise location information that could reasonably indicate a resident’s attempt to acquire or receive health services or supplies;
Data that identifies a resident seeking health care services; and
Any inferences of the above categories of health data derived or extrapolated from non-health information.

We limit third-party collection of health data over time and across different websites or online services when these state residents use our websites or online services. We do this by ensuring strict contractual restrictions with entities whose cookies, pixels, and other online trackers we use on our websites and online services in accordance with applicable U.S. privacy laws including Consumer Health Data laws. Nonetheless, please note that non-affiliated parties may still be able to collect health data from you over time and across different websites depending on your browser, browser add-ons, and associated permissions you set on your device, which is unrelated to Otsuka’s collection of health data from you, and we encourage you to view those non-affiliated parties’ privacy notices for more information about their processing of health data and the methods they provide to allow you to opt out of such processing.

How We Use Consumer Health Data

We may collect and use Consumer Health Data for the purposes described in How Otsuka Uses Your Personal Information of the Privacy Policy. Consumer Health Data may specifically be used to:

To provide products and services you request (and related business functions), such as making our websites and services available to you; providing customer service and communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); maintaining and otherwise facilitating your relationship with us; and evaluating and improving the products and services you request.
For legal, compliance, and safety purposes, such as complying with our policies; legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise, or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property, or rights; detecting, preventing, and responding to security incidents and health and safety issues; and protecting against malicious, deceptive, fraudulent, or illegal activity.
For our internal business purposes, such as day-to-day operation of our business; managing your tests; maintaining internal business records, such as accounting, document management and similar activities; administration and billing; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
For our internal analysis and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; internal analyses; safety reporting; improving the quality or safety of our products or services; designing new products and services; developing and improving algorithms, artificial intelligence or machine learning tools and models; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
For research and study-related purposes, such as conducting studies, trials, and medical testing; reusing your personal information collected from testing; conducting research-related analysis on prior projects; using stored samples for future research projects; researching the cause of disease; and developing new therapies.
In connection with a corporate transaction, this includes circumstances where we acquire assets of another business or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
For marketing purposes, such as marketing our products or services. For example, we may use Consumer Health Data we collect to personalize advertising to you or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

How We Disclose Consumer Health Data

We may disclose Consumer Health Data to the following categories of third parties as described in the Onward Transfer section of the Privacy Policy with additional details below:

Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, local distributors, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Service and other agreements or policies, and to protect our, our customers’, or third parties’ safety, property, or rights.
Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Consumer Health Data in comments, reviews, or other content that you share in public areas may be read, collected, or used by other users or the public.
Research collaborators, such as academic researchers, universities, hospitals, laboratories, and life science, pharmaceutical, and other companies for the purposes of research, where you have provided us with consent to do so.
Entities or individual to which you have consented to the disclosure.

Data Subject Rights

Washington consumers may have certain rights regarding your Consumer Health Data:

Right to Access. You may have the right to confirm whether we process your Consumer Health Data and to obtain information about how we process such data. You also may request access to the Consumer Health Data we hold about you.
Right to Delete. You may have the right to request that we delete your Consumer Health Data.
Right to Withdraw Consent. If you provided consent to process Consumer Health Data, you may have the right to withdraw such consent.
Appeal. If we deny your rights request, you may have the right to appeal. To submit an appeal, email us at PrivacyOfficer@Otsuka-OPH.com.

You may exercise the rights available to you by emailing us at PrivacyOfficer@Otsuka-OPH.com or submitting a request through our Online Form. You may also change your consent preferences regardingour use of tracking technologies in the “Cookie Settings” menu linked in the footer of our websites. We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy.

If you have questions regarding this Consumer Health Privacy Policy, please contact us at PrivacyOfficer@Otsuka-OPH.com.