OAPI PRIVACY STATEMENT

Introduction

Thank you for visiting the Otsuka America Pharmaceutical, Inc. (“OAPI”) website. OAPI and its parent company, subsidiaries, and affiliates (collectively, “Otsuka”) operate a variety of websites designed to provide you with information and services, including but not limited to health resources, corporate news, patient assistance programs, and product information. Some of Otsuka’s websites also enable healthcare professionals to receive product information and samples. Whether you are a patient, healthcare provider, investor, customer, employee, worker or job applicant, respect for the privacy of your Personal Information (i.e., any information related to an identified or identifiable individual) is very important to us. This Privacy Statement describes how we collect, use, protect, and disclose the Personal Information that you share with us online and offline, unless otherwise provided pursuant to an informed consent signed by you. Otsuka websites that display this Privacy Statement are committed to collecting, maintaining, and securing your Personal Information in accordance with the terms of this statement. We encourage you to read this Privacy Statement in its entirety before submitting any information. By using this website, submitting or requesting information, you acknowledge that you understand and agree with the provisions of this Privacy Statement.

U.S.-EU Privacy Shield Framework for Clinical and Pharmacovigilance Data

With respect to the collection, use and retention of Personal Information related to clinical and pharmacovigilance from European Union (“EU”) Member States and European Economic Area (“EEA”) member countries, Otsuka complies with the requirements of the EU-U.S. Privacy Shield Framework (“Privacy Shield”), as set forth by the U.S. Department of Commerce (“DoC”) and the Federal Trade Commission (“FTC”), including the seven (7) privacy principles as well as the supplemental principles and the associated guidance agreed to by the DoC and the European Commission (collectively, the “Privacy Shield Principles”). If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Otsuka’s certification, please visit https:// www.privacyshield.gov. Additionally, Otsuka may endeavor to protect your data through other legally-valid methods, including international data transfer agreements.

Limitation on Scope of Privacy Shield Principles

Adherence to the Privacy Shield Principles for clinical and pharmacovigilance data may be limited (i) to the extent required or allowed by applicable law, rule or regulation; (ii) to the extent necessary to respond to lawful requests by public authorities, including to meet national security, law enforcement, legal or governmental requirements; and/or (iii) to protect the health or safety of an individual.

Notice & Choice – What information do we gather and how do we use it?

Otsuka will not collect Personal Information about you unless you provide it voluntarily. You can use many of our websites without telling us who you are or providing us with any Personal Information. Depending on which website you visit, you may not be able to receive certain information unless you agree to provide us with Personal Information. For example, we may collect information from physicians and other healthcare providers who register on our websites in order to verify their licensure status and identity. The type of information collected from you will be based on the specific program that you register for, as indicated at the time of your registration. The information that we may ask you to provide may include your first and last name, mailing address, age, birth date, email address, and information about your medical conditions. We may also provide opportunities to contact us to ask questions or provide comments, ideas and/or suggestions. When you communicate with us or request a response, we may request additional contact information; in such cases, we will notify you as to why we are asking for that information and how it will be used. It is completely up to you as to whether you want to provide such information. We may also collect Personal Information to analyze visits to our website and learn about the interests of our visitors in the aggregate and also on a personal level. We may personalize and customize this website with references to products, services, or educational information that we believe may be of interest to you based on your previous interactions, information you have provided to us, or information about you that we have collected from third-party sources. Your interests could come from several sources, including your browsing activity and your response to online advertisements. In such circumstances, third parties collect and store data about your interests and online activity. Otsuka endeavors to limit the collection and processing of Personal Information to what is necessary to fulfill the purposes for which it is to be used. Otsuka will also endeavors to request your consent to collect your Personal Information when you register for a program or service. We will also offer you the option to opt out of receiving further communications from Otsuka (“opting out” or “unsubscribing”) if you later decide that you no longer want to participate in that program or receive additional information from us.

Use of Cookies and Other Tags

Where permitted by law, non-Personal Information and data may be automatically collected through the standard operation of Otsuka’s Internet service or through the use of “cookies” or “internet tags” and other similar techniques. This type of anonymous information allows Otsuka to evaluate customer interest in its websites and perform other market research activities. Cookies are small text files a website can use to recognize repeated usage, facilitate the user's access to and use of the site, and allow a site to track usage behavior and compile aggregate data that will allow content improvement and targeted advertising. Cookies are programs that come into a user's system but do not damage files. Generally cookies work by assigning a unique number to the user that has no meaning outside the assigning site. If a user does not want information to be collected through the use of cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature; however, users should note that cookies may be necessary to provide the user with certain features (e.g., customized delivery of information) available on Otsuka’s websites. Otsuka also may collect and store the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our website; the Internet address of the website from which you linked directly to our website.

Do-Not-Track Signals

Some web browsers that you use may transmit "do-not-track" signals to websites with which the browser communicates. As of the Effective Date of this Privacy Statement, an industry standard on how to respond to these signals has not yet been established. Since industry standards are still evolving, Otsuka will not separately respond to or take any action with respect to “do-not-track” configurations in your internet browser. Otsuka will reassess its approach once a standard is established. For information about “do-not-track”, visit http://www.allaboutdnt.org.

Data Integrity/Purpose Limitation and Security

Otsuka endeavors to take reasonable steps to ensure that Personal Information collected is relevant for the intended purposes of processing and reliable for its intended use, accurate, complete, and current. We use commercially appropriate technical, administrative, and physical safeguards intended to protect data that pertains to you from loss, misuse, or alteration. In addition, we take steps designed to ensure that our safeguards take into account new known threats. However, no organization can guarantee the absolute security of Personal Information. You should keep in mind that Internet transmissions, particularly email transmissions, are never 100 percent secure or free of errors. Accordingly, we caution you to guard your own computer and password against unauthorized access by others.

Onward Transfers – Sharing Your Information With Third Parties

Otsuka endeavors not to share your Personal Information with third parties for their own separate use unless we have obtained your opt-in consent to do so. When you provide Personal Information to Otsuka, it will be accessible to some of Otsuka’s business partners, such as companies we retain to fulfill requests for information, answer telephone calls, or provide assistance to us on specific programs or projects. In addition, Otsuka may enter into business relationships with other companies and, in those cases, such other companies may also have access to your Personal Information. Otsuka endeavors to require third parties to whom it discloses Personal Information to protect Personal Information using substantially-similar standards to those required by Otsuka and at least the same level of privacy protection as is required by the Privacy Shield Principles for clinical and pharmacovigilance data and this Privacy Statement, and to notify Otsuka if they make a determination they can no longer meet this obligation. We also require that they do not use your Personal Information for any separate use that is not specifically authorized by Otsuka. With respect to onward transfers to third-party agents, Privacy Shield requires that, to the extent it is responsible for the event, Otsuka shall remain liable should such agents process Personal Information in a manner inconsistent with the Privacy Shield Principles for clinical and pharmacovigilance data. There may also be instances where Otsuka may be required to share your information with third parties who have not been retained by Otsuka, such as with health authorities to report possible adverse drug experiences, during inspections or audits, or as ordered or directed by courts or other governmental agencies. Many entities receiving Personal Information under these conditions have privacy requirements that apply to their handling of your information.

Onward Transfers – Sharing Your Information Within the Otsuka Group of Companies

The information that you provide to Otsuka may sometimes be shared with other departments within Otsuka, as well as Otsuka subsidiaries and affiliates within the Otsuka global group. This may mean that your Personal Information may be transferred outside of the U.S. to Otsuka affiliates or companies in other countries. Other departments within the Otsuka group, and other Otsuka companies that may receive your information, will abide by substantially-similar privacy requirements relating to your Personal Information.

Access – Correcting and Accessing Your Information

We encourage you to update the information you provide to us, such as providing us with a new mailing or email address, a name change, or a change in the medical conditions that you have notified us about. This will help us continue to provide information to you that best meets your needs. Otsuka complies with laws and regulations applicable to the right to amend your data in our files. Under Privacy Shield, for clinical and pharmacovigilance data, you may seek confirmation regarding whether Otsuka is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete that information where it is inaccurate or has been processed in violation of the Privacy Shield Principles. Although Otsuka makes good faith efforts to comply with such requests, these rights are limited in some ways, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If Otsuka determines that access should be restricted in any particular instance, we will seek to provide you with an explanation of why that determination has been made and a contact point for any further inquiries. In addition, in order to protect your data from unauthorized access or alteration by third parties, all requests to update or access your information may be subject to commercially reasonable efforts to verify of your identity.

Recourse, Enforcement and Liability

Otsuka has implemented mechanisms to verify its ongoing compliance with the Privacy Shield Principles for clinical and pharmacovigilance data and this Privacy Statement. Any party that violates the Privacy Shield Principles for clinical and pharmacovigilance data and/or this Statement will be subject to disciplinary procedures in accordance with Otsuka’s disciplinary procedures. In the event of a dispute, EEA citizens are able to seek resolution of their questions or complaints regarding Otsuka’s use and disclosure of their Personal Information related to clinical and pharmacovigilance in accordance with the Privacy Shield Principles contained in this Privacy Statement. If you feel that Otsuka is not abiding by the terms of this Privacy Statement, or is not in compliance with the Privacy Shield Principles for clinical and pharmacovigilance data, please contact Otsuka at the contact information provided below. In addition, Otsuka has agreed to cooperate with the JAMS Arbitration and Dispute Resolution Program with respect to complaints. For more information and to submit a complaint to JAMS, a dispute resolution provider which has locations in the United States and the EU, visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. Such independent dispute resolution mechanisms are available to EEA citizens free of charge. If any request remains unresolved, you may have a right, under certain circumstances, to invoke binding arbitration under Privacy Shield for clinical and pharmacovigilance data; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Otsuka’s compliance with the Privacy Shield for clinical and pharmacovigilance data.

Children's Online Privacy

Otsuka’s websites are not directed at children. The services offered on our websites are designed for individuals who are 18 years of age or older. If your child has submitted Personal Information and you would like to request that such information be removed, please contact privacyofficer@otsuka-us.com.For more information about protecting the privacy of children online in the United States under the Children's Online Privacy Protection Act, please see http://www.ftc.gov/ogc/coppa1.htm (last accessed January 2013). Many of Otsuka’s websites contain links or references to third-party websites as a convenience to you. This Privacy Statement does not cover the practices of these websites. Accessing these sources requires that you leave Otsuka’s websites. Otsuka does not control the content of these third-party websites and is not responsible for the privacy practices of these websites. Please review the privacy policies on each website that you visit.

Updates to Privacy Statement

The foregoing terms are effective as of September 29, 2016. Otsuka may update this Privacy Statement from time to time based on, among other things, changes in applicable laws, development of new websites, and advances in technology. Otsuka reserves the right to modify, add, or remove portions of this Privacy Statement at any time at our sole discretion. If we decide to revise this Privacy Statement, we will post the revised Privacy Statement at this site. We encourage you to review the Privacy Statement each time you visit our site. This Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

How to Contact Us

If you have any questions about our Privacy Statement, its implementation, our compliance with Privacy Shield for clinical and pharmacovigilance data, the accuracy of your Personal Information, or the use of the information collected, please contact us at:privacyofficer@otsuka-us.com. You can also mail us at: Privacy Officer Otsuka Pharmaceutical Development & Commercialization, Inc. 508 Carnegie Center, 2nd Floor Princeton, New Jersey 08540