Privacy Policy

1. Collection (acquisition), use, and provision of personal information

• The Company clearly defines the purpose of use and collects (acquires) personal information by lawful and fair means.
• The Company uses collected (acquired) personal information only within the scope necessary for achieving the purpose of use that has been clarified to the individual concerned or made public (specified in “Details Part 1: Purpose of use of personal information” below), and does not use such information beyond the scope necessary for achieving the purpose of use (unintended use). The Company takes measures not to use such information for any unintended use.
• In principle, the Company does not provide personal information to third parties without the prior consent of the individual concerned.
• The Company maintains personal information in an accurate and up-to-date state within the scope necessary for achieving the purpose of use.

2. Compliance with laws, regulations, and other rules on the protection of personal information

The Company handles personal information in compliance with the laws and regulations on the handling of personal information, the guidelines established by the government, the “Marketing Research Code of Conduct” and the “Marketing Research Industry Guidelines for Protection of Personal Information” set forth by the Japan Marketing Research Association (JMRA), of which the Company is a member, the “Guidelines for Proper Handling of Personal Information by Pharmaceutical Companies” established by the Federation of Pharmaceutical Manufacturers’ Associations of JAPAN (FPMAJ), and other rules.

3. Safety management of personal information

The Company implements systematic, personnel, physical, and technical safety management measures to prevent and correct leakage, loss, or damage of personal information.

4. Response to complaints and consultation

For inquiries and complaints about the Company’s handling of personal information, please contact us by telephone or other means described in Details Part 7 (Inquiries and Complaints Desk).
The Company will, without delay, respond to requests from an individual whose personal data is retained or the individual’s representative for notification of the purpose of use, disclosure, correction, etc. (correction, addition, or deletion of content), and termination of use, etc. (termination of use, erasure, and termination of provision to a third party).

5. Continuous improvement of the personal information protection management system

In order to implement the Privacy Policy, the Company has established and is operating the personal information protection management system, including regulations and rules. In addition, in order to increase effectiveness, the Company will regularly provide education to all employees, conduct system operation audits, etc., and will continuously review and improve the personal information protection management system.

Details Part 1: Purpose of use of personal information

1. The Company is mainly engaged in marketing research specialized in the field of healthcare, aiming to conduct surveys and collect (acquire) information on the awareness of medical doctors, healthcare providers, and consumers, and the actual conditions concerning products and services, and statistically process this information to provide it to companies, organizations, etc. In principle, the personal information collected (acquired) is aggregated into statistical data and is not used in a format in which individuals are identified. Even in the case of receiving cooperation from overseas for surveys conducted on residents in Japan, the Company acquires and uses personal information in accordance with the laws of Japan.
2. In order to target the individuals (survey respondents) to whom the Company makes requests for cooperation in its marketing research, the Company may collect (acquire) personal information, such as names, addresses, etc., in advance. The methods used are based on the appropriate and legitimate use of a variety of information sources, e.g. extraction from websites, etc., extraction from publications, such as telephone books and commercially available name lists, and deposits from marketing research clients.
3. The Company may broadly recruit people to cooperate in its research and select survey respondents from among the applicants. In this regard, however, at the time of their application, the Company notifies them of the purpose of use of their collected (acquired) personal information. In addition, the Company may request the survey respondents who cooperated for the first time in the research to register as monitors for PLAMED Inc., a subsidiary of the Company, which manages research monitor data, and to cooperate in subsequent research.
4. The Company may conduct marketing research without specifying the individuals to whom the Company makes requests for cooperation in its marketing research (survey respondents) and collect (acquire) personal information, such as names, addresses, etc., of the survey respondents at that time. In such a case, the Company notifies them, either orally or in writing, of the purpose of use in advance.
5. The Company may acquire personal information such as names, departments/divisions, qualification of medical specialists certified by societies, and experiences of disease treatment by browsing websites, publications, and social media to use it for the purpose of supporting the marketing of business partners. In principle, the collected (acquired) personal information is aggregated into statistical data, and is not provided to third parties in a format in which individuals are identified.
6. Personal information obtained directly from the individuals through business cards, received e-mails, inquiries, applications, etc., is used for performing contracts in transactions, responding to inquiries, operating seminars, explanatory meetings, providing information on products and services handled by the Company, providing information on seminars and briefings sponsored by the Company, communication/sales activities and accounting processing necessary for the Company’s businesses, sending greeting cards and New Year’s cards, sending e-mail magazines, sending survey sheets of customer satisfaction or safety evaluation sheets of entrusted entities and providing feedback on the results thereof, etc.
   * If the purpose of use is indicated separately in an inquiry or application form, it will be given priority.
   * Within the scope of the aforementioned purpose, the Company will use the information jointly within the Group only when necessary for smooth handling. For details on the shared use, please refer to “Details Part 5: Shared use of personal information.”
   * Even in the case of receiving an inquiry or application from overseas, the Company acquires and uses personal information in accordance with the laws of Japan.
7. Personal information of employees is used for employment management, business communication, assessment of their performance, etc. Personal information of employees’ family members is used for social insurance, tax procedures, etc. Personal information of applicants is used for recruitment procedures such as contacting, handling an inquiry, and acceptance preparation. Personal information of retirees is used to respond to inquiries from them.

Details Part 2: Personal information subject to disclosure

“Retained personal data” is defined as follows in accordance with Article 2, paragraph 7 of the Act on the Protection of Personal Information.
“personal data which a personal information handling business operator has the authority to disclose, correct, add or delete the contents of, cease the utilization of, erase, and cease the third-party provision of, and which shall be neither those prescribed by cabinet order as likely to harm the public or other interests if their presence or absence is made known nor those set to be deleted within a period of no longer than one year that is prescribed by cabinet order”

1. Relevant personal information handling business operator
   INTAGE Healthcare Inc.
   Keita Murai, President and Representative Director
   Ochanomizu Sola City 13F, 4-6, Kandasurugadai, Chiyoda-ku, Tokyo
2. Purpose of use of retained personal data

   Type of retained personal data (personal information subject to disclosure)	Purpose of use
   Personal information of survey respondents newly recruited for specific research or such information obtained from a publicly available list, etc.	When conducting a survey, the Company uses such information to extract the persons to be surveyed, and to make requests to participate in the survey.
   Personal information obtained directly from the individuals through business cards, received e-mails, inquiries, applications, etc.	For the purpose of use, please refer to “Details Part 1: Purpose of use of personal information (6).”
   Personal information of employees Personal information of employees’ family members Personal information of applicants Personal information of retirees	For the purpose of use, please refer to “Details Part 1: Purpose of use of personal information (7).”

3. Measures taken for safety management of retained personal data
   1. Establishment of basic policy

      To ensure the proper handling of personal information, the Company has set a policy in the “Privacy Policy and Handling of Personal Information” with respect to compliance with relevant laws, regulations and guidelines, the Inquiries and Complaints Desk, and other matters.

   2. Development of regulations regarding handling of personal information

      Regarding the handling of personal information, the “Regulations on Protection of Personal Information” and the “Manual for Protection of Personal Information” prescribe the handling methods and the roles of persons responsible and persons in charge for each life cycle, including the acquisition, use, storage, provision, deletion and disposal of such information.

   3. Systematic safety management measures

      In addition to clarification of the roles of persons in charge of and persons responsible for handling personal information, and the scope of such handling, the Company has developed procedures and systems for reporting and communicating compliance violations and other matters.
      Organizations that handle personal information also conduct voluntary inspections on handling situations, and periodically have third-party audits.

   4. Personnel safety management measures

      The Company has specified confidentiality of personal information, etc. in the “Working Rules” and made it known, and has also regularly provided education with respect to relevant laws, regulations, and guidelines.

   5. Physical safety management measures

      The Company has established rules for workplaces to handle personal information in order to prevent illicit viewing and taking out of such information by unauthorized persons.
      Further, rules for the utilization of devices to handle personal information and mobile storage media have been established in order to prevent illicit access by unauthorized persons.

   6. Technical safety management measures

      The right to access a personal information database, etc. is supposed to be the minimal right, which is reviewed on a regular basis.
      In principle, the database has been set in a safe environment, which cannot be externally accessed. For a system that requires external access by individuals, etc., the Company makes effort to secure safety by controlling and monitoring communications and making regular vulnerability diagnoses, etc.

   7. Comprehension of external environment

      In the case of storing personal information overseas, the Company will develop handling rules that include compliance with relevant laws, regulations, and guidelines in Japan and local legislation, and take safety management measures after understanding the system for the protection of personal information in the relevant country.

Details Part 3: Procedures, etc. for responding to request for disclosure, etc. of personal information subject to disclosure

The Company responds to requests from the individual concerned or the individual’s representative for notification, disclosure, correction/addition/deletion, termination of use, deletion, and prohibition of provision to a third party regarding the purpose of use of personal information subject to disclosure (hereinafter referred to as “Disclosure, etc.”), and requests for disclosure of the “Record of Third-Party Provision” and the “Record of Receiving Third-Party Provision” created by the Company (hereinafter referred to as the “Third-Party Provision Record”) (hereinafter referred to as “Request for Disclosure, etc.”).

1. Response conditions

   The Company will respond a request in the case where personal information held by the Company or the Third-Party Provision Record does not fall under (8).
   A request for the disclosure of the Third-Party Provision Record will be responded to on the premise that information required to identify the Provision Record,* such as the point of time, is provided. (* See details in the Application Form for Request for Disclosure of the Third Party Provision Record.)

2. Application destination

   Ochanomizu Sola City 13F, 4-6, Kandasurugadai, Chiyoda-ku, Tokyo 101-0062
   Personal Information Protection Manager, INTAGE Healthcare Inc.
   ihc-kojinjoho@intage.com

3. Application process

   You can request Disclosure, etc. by one of the following two methods:

   1. Application by e-mail

      Please fill in the subject as “Request for Disclosure, etc.” and send an empty e-mail to the e-mail address provided in (2).
      A secure file box dedicated to applicants will be set, and you will receive an e-mail with a URL, to which you must upload the Application Form specified in (3) and necessary documents.
      * Please refrain from including personal information in an e-mail, or directly sending the Application Form and necessary documents as attachments, for security reasons. When you upload the Application Form and necessary documents to the file box dedicated to applicants, your application will officially be accepted.

   2. Application by postal mail

      Please send the Application Form specified in (3) and necessary documents to the Desk prescribed in (2).
      In addition, please write in red on the envelope, “Application Form for Disclosure, etc. enclosed.”

4. Application Form for Request for Disclosure, etc. and necessary documents

   Necessary documents differ between application by the individual concerned and that by the individual’s representative.

   1. Application by the individual concerned

      A. Application Form prescribed by the Company
      In the case of request for disclosure, etc. of personal information subject to disclosure: Application Form for request for disclosure, etc. of personal information subject to disclosure
      In case of request for disclosure of Third-Party Provision Record of personal data: Application Form for request for disclosure of Third-Party Provision Record

      B. Documents to identify the individual whose personal data is retained
      Two (2) official document copies such as a driver’s license and passport
      * Please take a moment to hide your domicile or origin for submission.

   2. Application by the individual’s representative

      In the case where the applicant is a legal representative of a minor or an adult ward, or a representative commissioned by the individual concerned, the following documents are required.
      Only if these documents are submitted, you will be recognized as a representative and your request for disclosure, etc. will be accepted:

      A. Application Form prescribed by the Company
      Same with A in the “(i) Application by the individual concerned”

      B. Documents to identify the individual whose personal data is retained
      Same with B in the “(i) Application by the individual concerned”

      C. Documents to identify the representative
      Two (2) official document copies of the representative such as a driver’s license and passport
      * Please take a moment to hide your domicile or origin for submission

      D. Document to confirm that you have legal power of authority

      a. In the case of a legal representative:
      One (1) document to confirm that you have legal power of authority (a public document that identifies a parent–child relationship, etc. such as an abstract of residence certification in the case of a person who has parental authority, a certificate of the registered matters prescribed in Article 10 of the Act on Guardianship Registration, etc., or a certified copy of family register).

      b. In the case of a commissioned representative:
      ・ One (1) copy of a power of attorney affixed with the registered seal of the individual concerned; and
      ・ One (1) copy of the registered seal certificate of the individual concerned.

5. Fee

   An amount of 500 yen will be charged as a fee.

6. Method of responding to a request for disclosure, etc.

   The Company will send its reply by either of the following methods:

   1. In the case of application by e-mail
      A secure file box dedicated to applicants will be set to send a reply.
   2. In the case of application by postal mail
      A reply will be sent by postal mail.
7. Purpose of use of personal information acquired in association with a request for disclosure, etc.

   Personal information acquired in association with a request for disclosure, etc. will only be used within the scope necessary for responding to the request for disclosure, etc. The documents submitted will be stored for a period of two (2) years after the completion of the response to the request for disclosure, etc. and will be disposed of upon the expiration of such period.

8. Grounds for non-disclosure

   Information will not be disclosed in the case of any of the following items. If a decision of non-disclosure is made, the Company will provide notice with reasons:

   a. If the individual’s identity cannot be verified, for example, if the address stated on the application form or the address stated on the identification documents does not match the address registered with the Company;

   
   b. In the case where the application is made by a representative, if the power of authority cannot be verified;
   c. If the object of the request for disclosure, etc. does not correspond to the personal information subject to disclosure;
   d. If the object of the request for disclosure of the Third-Party Provision Record is third-party provision that is excluded from confirmation/record obligations;
   e. In the case of a request for disclosure of the Third-Party Provision Record, if sufficient information that identifies the intended record is not provided;
   f. If such disclosure, etc. may harm the life, limb, property, or other rights and interests of the individual concerned or a third party;
   g. If such disclosure, etc. may significantly interfere with the proper execution of the Company’s business operations; or
   h. In the case of violation of other laws and regulations.

Details Part 4: Provision of personal information to third parties

The Company properly manages the personal information collected (acquired) and never provides it to a third party without the prior consent of the individual concerned, except in the following cases:

1. In those cases based on laws and regulations;
2. In the case where there is a need to protect human life, limb, or property, if it is difficult to obtain the consent of the individual concerned;
3. In the case where there is a special need to improve public health or promote the sound development of children, if it is difficult to obtain the consent of the individual concerned; and
4. In the case where there is a need to cooperate with national or local public organizations or a person or entity entrusted by them in executing the operations prescribed by laws and regulations, if obtaining the consent of the individual concerned may impede the execution of said operations.

Details Part 5: Shared use of personal information

1. Shared use of monitor information with PLAMED Inc.
   1. Purpose of use

      When conducting a survey, the Company uses such information to extract the persons to be surveyed, make requests to participate in the survey, improve the quality of services, etc.

   2. Items of personal data
      • Names;
      • Qualifications;
      • Sex;
      • Date of birth;
      • E-mail addresses;
      • Information on place of work;
      • Information on treatment department;
      • Addresses to send rewards;
      • Contents of inquiries;
      • Survey cooperation history.
      • Survey response data (from July 2022)
      • Log data (from July 2022), such as IP address, browser type, access date and time, and duration of stay, obtained when responding to the survey
   3. Scope of companies sharing information

      INTAGE Healthcare Inc. shares monitor (including members; hereinafter referred to as “monitor(s)”) information with its group company, PLAMED Inc.

   4. Name of person, business, or representative responsible for the management of the applicable personal data

      If you are in charge of shared use, please check the website “Article 6. Joint Utilization (2): Joint utilization of monitor information with INTAGE Healthcare Inc.” of PLAMED Inc.

   5. Method of acquisition
      • Direct acquisition from the monitors themselves in writing (including by e-mail and on the Web).
      • Direct acquisition from the monitors themselves by means other than in writing (such as orally, and by video and sound recording) after contacting them.
   6. Restrictions on shared use

      If a monitor himself/herself provides notice of refusal for the shared use, he or she is excluded from those monitors whose information is subject to shared use.

2. Shared use of personal information acquired from business partners by the INTAGE Group companies and the Company
   1. Purpose of use

      To improve the efficiency of sharing and management of information on customers and business partners (including potential customers and business partners) within the scope of the purpose of use of personal information disclosed on the website by each INTAGE Group company;

   2. Items of personal data

      Name of business, department, title, or person, address, telephone number, and mail address

   3. Scope of companies sharing information

      For information on the scope of companies that share information, please refer to the “4. Shared use of personal information” website of INTAGE HOLDINGS.

   4. Name of person or business responsible for the management of the applicable personal data

      Personal information protection manager of the management company (the company to which the person originally provided the personal information)
      *Personal information protection managers have been appointed for group companies that share personal information.

   5. Name of representative

      Keita Murai, President and Representative Director of INTAGE Healthcare Inc.
      For the name of the representative of each company that shares information, please check the respective company’s website.

      A list of domestic Group companies posted on the website of INTAGE HOLDINGS contains links to each company’s website.

   6. Method of acquisition

      Acquired by Group companies directly from individuals in writing by exchanging business cards, receiving e-mails, making inquiries, applying, etc.

3. Shared use of personal information of sole proprietors as business partners retained by the Group companies.

   The Company shares the personal information of sole proprietors as business partners’ information retained by the INTAGE Group companies. In the future, the way in which shared use is handled may be revised as necessary. In such a case, an announcement will be made in advance.

   1. Purpose of use

      To improve efficiency of sharing and management of information on business partners within the scope of the purpose of use of personal information disclosed on the website by each INTAGE Group company and in the integrated management information system.

   2. Items of personal data

      Name of corporation/organization, or name, address, and telephone number of sole proprietor

   3. Scope of companies sharing information

      For information on the scope of companies that share information, please refer to the “4. Shared use of personal information” website of INTAGE HOLDINGS.

   4. Name of person or business responsible for the management of the applicable personal data

      Personal information protection manager of the management company (the company to which the person originally provided the personal information)
      *Personal information protection managers have been appointed for group companies that share personal information.
      *Each group company sharing personal information has entrusted its business partner management operations to INTAGE ASSOCIATES Inc., INTAGE Group’s shared services company.

   5. Name of representative

      Keita Murai, President and Representative Director of INTAGE Healthcare Inc.
      For the name of the representative of each company that shares information, please check the respective company’s website.

      A list of domestic Group companies posted on the website of INTAGE HOLDINGS contains links to each company’s website.

   6. Method of acquisition

      Acquired by Group companies when starting transactions by exchanging business cards or directly from individuals in writing (including e-mails)

Details Part 6: Handling of personal data of persons in foreign countries

The Company may handle the personal data of persons in foreign countries as follows:

1. In connection with conducting interview surveys, Internet surveys, etc., the Company may by itself acquire personal data on-site or transfer the acquired personal data to Japan;
2. The Company may, when providing its products and services, acquire personal data from the users of the products and services;
3. The Company may, when entrusted with the handling of personal data by business partners, transfer such personal data to Japan; and
4. In any of the above cases, the Company ensures that the personal data is properly acquired, transferred, and disposed of in compliance with the laws of the relevant countries and regions and the Act on the Protection of Personal Information of Japan.

Details Part 7: Inquiries and Complaints Desk

For inquiries and complaints concerning the Company’s handling of personal information, please contact the following:

Please note that if you come to the office directly, the Company cannot accept your inquiry.

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User Information

The Company may collect the following non-personal information about users of this website:

• Browser information;
• Operating system type; and
• Internet service provider’s domain name.

Such information is used to improve the design and contents of this website to be more suitable for the users’ Internet environment, as well as to analyze the usage of the whole website.

Revision of the Privacy Policy

Please note that the Company may, without notice, revise this Privacy Policy due to a change in the content of the services of this website or a change in relevant technology, etc. In such a case, the Company will publish the revised Privacy Policy on this page.

December 2023
INTAGE Healthcare Inc.