1. Scope of application of the General Privacy Policy
   The General Privacy Policy applies to users’ personal information (names, addresses, organization or company names, profession or organization types, telephone numbers, E-mail addresses, etc.) provided through this Website (hereinafter referred to as the “Website”) that Alfresa Pharma Corporation (hereinafter referred to as briefly “Alfresa Pharma” or “we”) manages and operates.
2. Handling of personal information
   1. Collection of personal information
      Alfresa Pharma will acquire personal information by legal and fair means and not by unauthorized means against the users’ will.
      As a general rule, users can browse the Website without revealing any of their personal information. However, when we receives inquiries, etc., we will ask users to provide personal information.
      In addition, the Website may collect information such as users’ browsing histories and access analyses on the Website. Information will not be collected in a way that identifies individual users in its process as described above to improve the convenience of the Website, nor will individual users be identified in the process of analyzing information.
   2. Purposes of use of personal information
      Alfresa Pharma will take sufficient care not to damage the rights of the usern who has provided personal information to the extent necessary to achieve the purposes of use. The purposes of using personal information in us are as follows:

      To respond to various inquiries from users,
      To communicate with users for business negotiations and meetings,
      To send information on seminars, new products, etc.,
      To request participation in questionnaires and surveys about our products,
      To analyze in order to improve products and services based on questionnaires,
      To verify the identity of individuals,
      To operate the Website,
      To provide personal data to distributors in the area where users live in order to respond to inquiries and other requests from users, and/or
      To achieve other purposes agreed to in advance by users.

   3. Management of personal information
      Alfresa Pharma will take appropriate safety management measures to prevent leakage, loss, or damage of the collected personal information, etc.
   4. Disclosure, correction, deletion, suspension of use, etc. of personal information
      Alfresa Pharma will respond to requests for notification of the purposes of use, disclosure, correction, deletion, or suspension of use, etc. of personal information as soon as reasonably possible after identifying the user making the request.
   5. Provision to third parties
      Alfresa Pharma may provide the collected personal data to its distributors in the areas where users live, to the extent necessary to achieve the purposes specified in the Privacy Policy, with prior consent. We will not disclose, provide, share, or distribute the collected personal data to third parties, except as described above. However, we may disclose, provide, or share the data to third parties per laws and regulations to ensure product safety or other purposes.
3. Use of cookies
   Cookies are text files sent to and stored in users’ browsers when users visit the Website but are not intended to infringe on users’ privacy or cause any damage to users’ computers. The Website may use cookies for the purposes mentioned below. Cookies can be managed by changing the settings in the browser used or clicking the Cookie Settings in our website footer at any time.

   To improve the operability of the Website, and/or
   To study the usage of the Website and improve marketing and services.

   In addition, Google Analytics may be used on the Website to understand the usage of the Website. Please visit the Google Analytics website for an explanation of the Google Analytics Terms of Service.
4. Handling of websites linked from the Website
   The Website may contain links to other websites for users’ convenience and information only. The Privacy Policy does not apply to any other websites linked from the Website, and Alfresa Pharma assumes no responsibility for them and its contents. Please refer to the privacy policies, etc. of these websites.
5. Revision of the Privacy Policy
   The Privacy Policy may be revised as necessary to improve and enhance its contents.
6. Name and address of the controller and its contact information
   Name: Alfresa Pharma Corporation
   Address: 2-2-9 Kokumachi, Chuo-ku, Osaka, Japan
   Phone: +81-6-6941-0291
   If you have any questions regarding the Privacy Policy, please contact us using the inquiry form.

* The Privacy Policy for Europe applies to users in European countries where the General Data Protection Regulations (GDPR) apply, in addition to the above Privacy Policy.

1. Scope of application of the Privacy Policy for Europe
   The Privacy Policy for Europe applies to the joint or individual processing of personal data of data subjects in the European Economic Area and the United Kingdom (hereinafter collectively referred to as “European countries” in the Privacy Policy for Europe). With respect to personal data of data subjects in European countries, the Privacy Policy for Europe applies in conjunction with the above Privacy Policy. However, in the event of any inconsistency between the two, the Privacy Policy for Europe prevails.
2. Definition
   Terms used in the Privacy Policy for Europe are defined as follows, in addition to those defined separately.
   The term “data subject” refers to an identified or identifiable natural person.
   The term “personal data” refers to information about a data subject.
   The term “controller” refers to a natural person, legal entity, government authority or agency, or other person determining the purposes and means of processing personal data alone or jointly with others. In the Privacy Policy for Europe, the controller refers to Alfresa Pharma.
   The term “processing” refers to all operations performed on personal data, such as collecting, recording, organizing, structuring, storing, modifying or changing, searching, referencing, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, and deleting or discarding.
   The term “European countries” refers to the European Economic Area and the United Kingdom.
3. Purposes and legal basis for the processing of personal data
   1. Types of personal data to be acquired
      Alfresa Pharma will acquire personal data by legal and fair means and not by unauthorized means against the users’ will.
      As a general rule, users can browse the Website without revealing any of their personal data.
      However, the Website may collect information such as users’ browsing histories and access analyses on the Website. Information will not be collected in a way that identifies individual users in its process as described above to improve the convenience of the Website, nor will individual users be identified in the process of analyzing information.
      When Alfresa Pharma receives inquiries from users, the following personal data of users shall be provided:
      1. Name,
      2. Address,
      3. Name of the organization or company,
      4. Profession or organization type,
      5. E-mail address, and
      6. Telephone number (optional)
   2. Purposes of use of personal data
      Upon receiving inquiries from users, Alfresa Pharma will process the personal data provided per the preceding paragraph only for the following purposes of use:

      To respond to various inquiries from users,
      To communicate with users for business negotiations and meetings,
      To send information on seminars, new products, etc.,
      To request participation in questionnaires and surveys about our products,
      To analyze to improve products and services based on questionnaires.
      To verify the identity of individuals,
      To operate the Website,
      To provide personal data to distributors (only distributors in European countries) in the area where users live to respond to inquiries and other requests from the users, and/or
      To achieve other purposes agreed to in advance by users.

   3. Management of personal data
      Alfresa Pharma will take appropriate safety management measures to prevent leakage, loss, or damage of the collected personal data, etc.
   4. Disclosure, correction, deletion, suspension of use, etc. of personal data
      Alfresa Pharma will respond to requests for notification of the purposes of use, disclosure, correction, deletion, suspension of use, etc. of personal data as soon as reasonably possible after identifying the user making the request.
   5. Provision to third parties
      Alfresa Pharma may provide the collected personal data to its distributors in the areas where users live, to the extent necessary to achieve the purposes specified in the Privacy Policy, with prior consent. We will not disclose, provide, share, or distribute the collected personal data to third parties, except as described above. However, we may disclose, provide, or share the data to third parties per laws and regulations to ensure product safety or other purposes.
   6. Legal basis for processing
      Alfresa Pharma will process personal data based on any of the following legitimate grounds:
      1. In a case where we have acquired the consents of users for the processing of their personal data by us,
      2. In a case where we fulfill a contract entered into by us and users, or practices procedures in response to users’ requests prior to entering into a contract, or
      3. In a case where processing is required for a legitimate interest pursued by us or a third party (excluding cases where the fundamental rights and freedoms of users override such interest).
4. Use of cookies
   Cookies are text files sent to and stored in users’ browsers when users visit the Website but are not intended to infringe on users’ privacy or cause any damage to users’ computers. The Website may use cookies for the purposes mentioned below. Cookies can be managed by changing the settings in the browser used or clicking the Cookie Settings in our website footer at any time.

   To improve the operability of the Website, and/or
   To study the usage of the Website and improve marketing and services.

   In addition, Google Analytics may be used on the Website to understand the usage of the Website. Please visit the Google Analytics website for an explanation of the Google Analytics Terms of Service.
5. Customer rights
   Users have the following rights regarding their personal data.
   1. Rights of access, correction, deletion, and restriction of processing
      Users have the right, in certain cases, to request the controller to access, correct, or delete their personal data, or to restrict processing of the data of the data subjects.
   2. Right of objection
      Users have the right to object to the processing of their personal data by Alfresa Pharma.
   3. Right of consent withdrawal
      Users have the right to withdraw at any time the consent users have given to us for the processing of their personal data.
   4. Right of filing complaints
      Users have the right to file complaints about the handling of their personal data with the data protection authority in each country where it has jurisdiction.
   5. Right of data portability
      Users have the right to receive their personal data in a structured, commonly used, and machine-readable format. In addition, users have the right to transfer such personal data to another controller without any interference from the controller.
   6. Right of profiling
      Users have the right not to be subject to automated decision-making (including profiling) based on the processing of their personal information that has legal or similar effects on them.
6. Retention period for personal data
   Alfresa Pharma will retain users’ personal data only for as long as is necessary to achieve the purposes specified in the Privacy Policy for Europe. Provided, however, that this will not apply to cases where applicable laws and regulations require a longer period of data retention.
7. Handling of websites linked from the Website
   The Website may contain links to other websites for users’ convenience and information only. The Privacy Policy for Europe does not apply to any other websites linked from the Website, and Alfresa Pharma assumes no responsibility for them and its contents. Please refer to the privacy policies, etc. of these websites.
8. Revision of the Privacy Policy for Europe
   The Privacy Policy for Europe may be revised as necessary to improve and enhance its contents.
9. Name and address of the controller and its contact information
   Name: Alfresa Pharma Corporation
   Address: 2-2-9 Kokumachi, Chuo-ku, Osaka, Japan
   Phone: +81-6-6941-0291
   If you have any questions regarding the Privacy Policy for Europe, please contact us using the inquiry form.