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Privacy Policy Main Article

Privacy Policy Statement ("PPS")

IMPORTANT: By accessing this website and/or any of its pages, you are agreeing to the terms of our Privacy Policy & Statement set out above.


GENERAL STATEMENT

  1. 1. Preface

    1. We, Daiichi Sankyo Hong Kong Limited (“DSHK”, “we”, “our” or “us”), respect your legal rights of privacy when collecting, storing, using, processing and transmitting Personal data and this PPS explains our privacy practices. We are legally required to comply with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) of the Laws of the Hong Kong Special Administrative Region, and other applicable laws, guidelines or requests by regulatory or authorities including the Privacy Commissioner for Personal Data of Hong Kong and The Joint Financial Intelligence Unit when collecting, holding, using and/or processing your Personal data. In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality. Please read the following carefully to understand our policy and practices regarding the types of Personal Data to be collected, how your Personal Data will be collected, treated, used and processed, and with whom we share it. In certain circumstances, DSHK is under the obligation to disclose such Personal Data to the regulated authorities.

    2. By providing your Personal data to us, you are consenting to this PPS and the collection, use, transfer, storage and processing of your Personal data as described in this PPS.

    3. It is important that you read this PPS together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Data. This PPS supplements other notices and privacy policies and is not intended to override them unless we notify you otherwise.

    4. DSHK may make changes to this PPS from time to time. Any changes will be posted on the website of DSHK or sent you via designated email or other appropriate methods, so it is deemed that you agree to such changes by visiting or accessing to the website of DSHK and/or, using DSHK’s services and/or contacting DSHK.

    5. If you are under the age of 18, you must have a legal representative such as a parent or guardian accepting this Policy on your behalf before providing any Personal Data to us.

  2. 2. Personal Data

    1. In PDPO, “Personal data” is defined as “any data relating to a living individual from which his/her identity can be directly or indirectly ascertained”.

    2. For the purpose of compliance with applicable laws, guidelines or requests by regulatory or other authorities in and outside Hong Kong, you may be requested by DSHK to provide Personal Data such as, but not limited to, the following:-

      • name;
      • address;
      • e-mail address;
      • telephone number;
      • date of birth;
      • your country of nationality or citizenship, and other identification information provided by government authorities;
      • audio recordings of your voice in client phone communications with us; and/or
      • other contact information or information stated in the paragraph below.

    3. Specifically, when you seek and/or use product(s) and/or service(s) of DSHK, contacting DSHK, use of the DSHK’s website, DSHK may collect, use, store and transfer different kinds of Personal data about you which DSHK has grouped together as follows:

      • information obtained from the entities with whom DSHK have entered into the contract for market survey, engineering, purchasing, manufacturing, construction, logistics and other business purposes;
      • information obtained from the DSHK’s Business Partners and Affiliates (such as agents, dealers or distributors with whom we have business relationships);
      • details of visits to the website using automated techniques or interactions including, but not limited to, traffic data (which may be provided by an analytics provider who may be located in Hong Kong or elsewhere), location data, weblogs and other communication data (Usage and Technical Data).

  3. 3. Purposes of Collection

    1. The purposes for which we may use your Personal Data will vary depending on the type(s) of product(s) and/or service(s) you seek from us, but generally for the following purposes:-

      • administration and management; communications; surveys, analysis, research and development; marketing and provision of services and organising activities;
      • reviewing and responding to any queries or complaints from clients or prospective clients;
      • where it is necessary for legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
      • maintenance of particulars and Personal Data in compliance with the applicable ordinances and subsidiary legislation which are enacted and effective in Hong Kong relating to the business activities of the DSHK and also in compliance with the applicable laws, rules and regulations to DSHK and other regulatory and authorities in Hong Kong and overseas; and/or
      • any other purposes as you and the DSHK separately agreed from time to time.

    2. Provision of the Personal Data is completely voluntary, however, failure to provide the Personal Data required may result in us being unable to process your request or provide the specific products / services in full to you.

    3. Please provide us with accurate, complete and up-to-date information. If the Personal Data you provide us is inaccurate or incomplete, it may adversely affect how we provide you relevant services.


    4. STATEMENT OF PRACTICE

  4. 4. Data Protection Principles

    1. Apart from the above privacy policy, we adhere the following data protection principles of the Daiichi Sankyo Company Limited and all its affiliates in global (‘DS Group’), save otherwise appropriately agreed by you:

      • Notice and Transparency - We will notify individuals at the time of collection of, or publish, the purposes for collecting and using their Personal Data, the identity of the entity collecting the Personal Data, as well as any third parties to whom the Personal Data may be disclosed, and where required by law, the choices and means that may be offered for limiting the use and disclosure of the information.

      • Choice and Consent - Where required by law, we must obtain consent from the relevant individual or give the individual the opportunity to choose whether their Personal Data is processed, disclosed to third parties, or used for purposes other than originally intended. The type of consent or notice required will depend on the context and circumstances for the collection of Personal Data, its sensitivity, the individual’s reasonable expectations and any applicable legal requirements.

      • Limitations on Collection - We will ensure that Personal Data is collected for legitimate purposes under a lawful basis, and that collection is limited to the information necessary to carry out the stated purposes at the time of collection, or as otherwise allowed by applicable laws or regulations.

      • Specification and Limitations on Use - We will process Personal Data only in ways compatible with the purposes that are: (i) defined at the time of collection; (ii) subsequently authorized by the individual; or (iii) permitted by applicable laws or regulations.

      • Individual Access and Participation - Where required by law, we will provide individuals with an opportunity to access and, where appropriate, to correct, amend, or delete the Personal Data retained by us, or to exercise any other rights provided by applicable laws or regulations.

      • Data Quality - We will take reasonable steps to ensure that Personal Data should be accurate, and if necessary, kept up to date so as to be accurate, complete and as current as necessary for the stated purposes of its use.

      • Retention and Disposal - We will retain Personal Data only for as long as necessary to fulfill the purposes identified at the time of collection, unless retention is required by law or the individual has consented. Once the Personal Data is no longer needed, it should be deleted according to applicable retention schedules and legal/regulatory requirements.

      • Security Safeguards – We will take all reasonable technical, managerial, administrative and physical security measures to ensure that Personal Data is protected against the risk of loss or unauthorized access, destruction, use, modification or disclosure.

      • Transfer or Processing by Third Parties - We will transfer Personal Data to a third party only if the relevant individual consents to such transfer or otherwise permitted by applicable laws or regulations. Where required by law, appropriate contractual safeguards must be in place before the transfer of Personal Data to ensure an adequate level of protection. If we are required by law to disclose Personal Data for legal or regulatory purposes, it will take reasonable steps to make such disclosures in a secure manner as permissible by law and to whom it is needed.

  5. 5. Passive information collection on DSHK website

    1. When you visit this website www.daiichisankyo.com.hk, as you navigate through any other websites, certain information can be passively collected using various technologies and means, such as Internet Protocol address, cookies, Internet tags, and navigational data collection. Such data is generally considered to be non-personally identifiable information, and DSHK uses such data in order to help your navigational experience, to help determine areas of the website visitors find most valuable, thereby helping to improve the contents of this site, and to gather usage statistics from a country level and never on a user IP level.

    2. Unless consent is otherwise given, DSHK will not combing any actively collected information on this website.

  6. 6. Cookies

    1. DSHK’s website uses cookies and stores information on how you use the website. Cookies are small data structures sent to your computer to record your visit to our website and to identify you during your future visits. The information is anonymous and will not be linked back to you as an individual. These cookies may be saved permanently in your computer. You can reject and block cookies in browser settings, but this may affect your browsing of our website.

    2. This information collected from you may will only be used to compile general statistics in relation to the number of visitors to our website and also the usage of our website.

    3. Please be reminded that, by continuing to use our website without notifying us of your refusal to use cookies or withdrawing your consent, you are agreeing to our use of cookies.

  7. 7. Disclosure and Transfer of Personal Data

    1. DSHK will not sell, share, or otherwise distribute your Personal Data to third parties outside the DS Group and/or DSHK. However, Personal Data may occasionally be transferred to third parties who act for or on behalf of any DS Group and/or DSHK, or in connection with the operations of, for further processing in accordance with the purpose(s) stated in above Data Protection Principle (a) - Notice and Transparency. We will strictly adhere the requirement under above Data Protection Principle (i) – Transfer of Processing by Third Parties for disclosure of Personal Data to a third party.

    2. Any cross-border Personal Data transfer within DS Group is not regarded as supply to third parties, while we will adhere the respective laws and regulations of different legal jurisdictions.

    3. We will take all practicable steps to keep your Personal Data confidential, but the following are the parties we may disclose, transfer and/or assign such data:

      1. any employee, officer, consultant, intern, director, agent, advisor (including lawyers, notary public, corporate secretary, accountants, tax and financial advisors, auditor), contractor or third-party service provider who provides administrative, telecommunications, computer, payment, fraud prevention, insurance, data processing and/or other services to us in connection with the operation of our business and/or the relevant product(s) and/or service(s) that you seek from us, and/or who otherwise processes Personal Data for and on our behalf;
      2. financial institutions including banks, insurers, brokers and dealers, and advisors in the finance industry;
      3. co-branding partners or business partners of DSHK; and
      4. any person (including without limitation government authorities, regulatory or administrative bodies or law enforcement agencies) to whom DSHK is under an obligation to make disclosure under the requirement of any law binding on DSHK, court order or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which DSHK is expected to comply, or such parties who are authorized by law to request information from DSHK.

    4. We may also disclose and/or transfer your Personal Data in the manner as stated in any terms and conditions relevant to the product(s) and/or service(s) you seek from us.

    5. The parties to whom we disclose and/or transfer your Personal Data may be situated outside of Hong Kong where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Personal Data (Privacy) Ordinance.

  8. 8. Request for Access, Correction and Deletion of Personal Data

    1. DSHK fully complies with the “Right of Access and Correction” obligations of the the applicable laws including the PDPO. In accordance with the terms of the PDPO, you may request access to the Personal Data supplied by you to ascertain whether the DSHK holds any Personal Data and, if so, obtain such Personal Data and may request DSHK to correct any inaccurate Personal Data for the purpose for which it is being used.

    2. You can ask DSHK to Delete or Remove Personal Data where there is no good reason for DSHK continuing to process it. You also have the right to ask DSHK to delete or remove Personal Data where you have successfully exercised the right to object to processing (see below), where DSHK may have processed the user’s information unlawfully or where DSHK is required to erase Personal Data to comply with local law. Note, however, that DSHK may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of the request.

    3. Where DSHK is relying on a legitimate interest (or those of a third party) and there is something about situation which makes you want to Object to Processing on this ground as the user feels it impacts on your fundamental rights and freedoms. You also have the right to object where DSHK is processing Personal Data for direct marketing purposes. In some cases, DSHK may demonstrate that DSHK has compelling legitimate grounds to process the information which overrides your rights and freedoms.

    4. You have the right to withdraw consent at any time by contacting DSHK where DSHK is relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw the consent. If you withdraw the consent, DSHK may not be able to provide certain products or services to you. DSHK will advise you if this is the case at the time you withdraw the consent.

    5. You also have the right to ascertain DSHK’s policies and practice in relation to the Personal Data.

    6. DSHK will, upon satisfying itself of the authenticity and validity of the access request from you, make every endeavour to comply with and respond to the request within the period set by the Ordinance (i.e. within 40 days after receiving the request).

  9. 9. E-mail, spamming and mail-list

    1. DSHK does not tolerate or engage with spamming. Spamming is defined as sending of unsolicited e-mails, in large numbers and repeatedly to individuals who have declined to receive such information. In contrast, where DSHK believes that certain information is of interest or importance to you, it reserves the right to inform you by e-mail, or by regular post, whilst providing you the choice of opting out of such communication method.

  10. 10. Linked Websites

    1. If you use our websites, there may be hyperlinks linking to another website(s). If you click on any of these hyperlinks, you will leave our websites for another location. At any other website, the protection of your privacy, Personal Data and your exposure to cookies are not our responsibility, i.e. at your own risk, and you are advised to refer to the privacy policy of that other location (if any).

  11. 11. Use of Personal Data in legal proceedings

    1. If it becomes necessary that we have to take action against you for any reason whatsoever including recovering from you any money you owe us, you expressly agree that the Personal Data provided by you can be relied upon in identifying and taking legal action against you.

  12. 12. Contact

    1. If you have any questions concerning this policy, comments, recommendations, complaints, and/or requests concerning your personal data, please contact our Data Privacy Officer in writing at the following address:

      Data Privacy Officer
      Daiichi Sankyo Hong Kong Limited
      Suites 3207-11, 32/F, Tower One, Times Square,
      1 Matheson Street, Causeway Bay,
      Hong Kong

    2. DSHK reserves the right to revise the details of the above policy as necessary. You should therefore periodically visit this page to review the latest policy details.


Daiichi Sankyo Hong Kong Limited
January 2025