Astellas Social Media Privacy Notice

Last updated: November 2023

Astellas Pharma Inc. (2-5-1, Nihonbashi-Honcho, Chuo-Ku, Tokyo 103-8411, Japan) and its affiliates (“Astellas”) respect 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, X (formerly Twitter), LinkedIn and YouTube 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 further 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: Unless there is a relationship of joint controllership (for which see below), 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. When you use social media, your personal information will be processed by the social media platform providers for purposes not related to Astellas. We ask you to visit those social media platform providers and carefully read their Privacy Policies or Notices and set up your privacy preferences 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 recommend you not to include any direct personal identifiers about you or any other person such as any email addresses, home or business addresses or phone numbers 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. For more information about Astellas, including information about our focus therapeutic areas, please see the "About" and the “Therapy Areas” sections of our Website at https://www.astellas.com/en/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 that you have made publicly available on public social media platforms or elsewhere on the internet (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 also process your personal information as part of campaigns on our social media accounts that involve targeting of individuals and measuring the overall response to such campaigns using mechanisms offered by the social media providers.

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

What is the source of my personal information that Astellas processes?

In case you interact with any of our social media accounts, the sources of the personal information processed are the relevant social media platform providers. Astellas’ ownership of social media accounts is typically indicated in the header of such accounts (e.g., in the “About” tab in LinkedIn or Facebook).

Where Astellas conducts social media monitoring activities, the sources of personal information processed can be any publicly available information on social media platforms as well as any publicly available information on the internet (e.g., in blogs, forums etc.). Please note that many of the social media monitoring activities only focus on assessing aggregate trends related to our topics of interest where the personal information processing is typically very limited and incidental.

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. The most prevalent categories of third-party service providers and partners include marketing and advertisement agencies, information systems providers and backend support providers, analytics service providers and third parties involved in the processing of adverse events. 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 and UK visitors only)

If you are a visitor from the European Economic Area or the UK, our legal basis for collecting and using the personal information described above is our legitimate interests to operate our social media accounts, respond to your queries, measure the success of our campaigns, monitor the reputation of our brands and the evolution of market trends and public opinion in the relevant therapeutic areas where Astellas operates or is interested in and to identify relevant stakeholders we may interact with, 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. For any special categories of personal information processed for the purpose of social media monitoring activities, these are processed based on and to the extent that they were manifestly made public by you.

In some cases, we may also have a legal obligation to collect personal information from you as in the case you use our social media channels to exercise your privacy rights.

We may also need to process your personal information to support the interests of public health as in the case of collecting and processing information about potential adverse events that may have been notified by you in various social media accounts or identified by us when conducting social media monitoring activities in publicly available posts. Lastly, we 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 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, as well as ensuring that access to personal information is granted on a limited basis to those who need to know.

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. 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 (e.g., for as long as required by law, defined by the social media platform, or as long as needed to fulfil our business objectives (e.g. conduct analyses of perception of our brand).

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.

Joint Controllers

Depending on the type and nature of our online activities, Astellas and social media providers or other online marketing vendors may have a role of joint controllers which means that we determine the key elements of personal information processing jointly. This applies when Astellas uses Meta’s Page Insights or LinkedIn’s Page Insights services which provide Astellas access to aggregate statistical information about its pages and when Astellas runs a campaign utilizing advanced analytical and targeting tools such as Conversions API or Pixels. More detailed information about the identity of our joint controllers and about the division of roles between Astellas and them is available in the table below:

Please note that those third parties are responsible for enabling data subjects' rights with regard to the personal data stored by them after the joint processing. Those third parties are solely responsible for any use and handling of your personal information for other purposes beyond the above-mentioned ones regarding the joint use of targeting cookies with your prior explicit consent.

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:

The data controller of this activity is

Astellas Pharma Europe Ltd
300 Dashwood Lang Road,
Bourne Business Park, Addlestone,
United Kingdom,
KT15 2NX

MAT-GB-NON-2023-00341 December 2023