Kowa United States

Consumer Health Data Privacy Notice

Effective (last updated) Date: March 10, 2025

The Kowa U.S. Privacy Policy describes how we handle personal information generally. This supplemental KCL Consumer Health Data Privacy Notice (“CHD Notice”) explains the information practices of Kowa Company, Ltd. (“KCL,” “we,” “us,” or “our”) as to personal data that qualifies as “Consumer Health Data” or “Regulated Health Information” or similar terms (collectively, “CHD”) as such terms are defined under Washington’s My Health My Data Act and substantially similar consumer health data laws that may hereafter be applicable to us, and all laws implementing, supplementing, or amending the foregoing, including regulations promulgated thereunder (“CHD Laws”).

  1. What Categories of Consumer Health Data Do We Collect?

    The categories of CHD that we collect may include the following categories:

    • Individual health conditions, treatment, diseases, or diagnosis
    • Social, psychological, behavioral, and medical interventions
    • Health-related surgeries or procedures
    • Use or purchase of prescribed medication
    • Bodily functions, vital signs, symptoms, or measurements indicating CHD
    • Diagnoses or diagnostic testing, treatment, or medication
    • Gender-affirming care information
    • Reproductive or sexual health information
    • Information that identifies that you are seeking health care services
    • CHD that we or our processors infer, derive, or extrapolate based on other CHD, or on personal information generally
  2. Why Do We Collect CHD and Who Do We Collect CHD From?

    We collect CHD through your health care provider (“HCP”) when your HCP submits an adverse event report and supporting materials to a Kowa Pharmaceuticals America, Inc. employee to report a reaction you had to a KCL pharmaceutical product that was prescribed to you.

  3. How Do We Share Your Consumer Health Data?

    We share Consumer Health Data with third parties in limited circumstances, as follows:

    • Vendors that are classified as “processors” under CHD Laws who process CHD to assist with the purposes described in this CHD Notice.
    • Our other agents and contractors who assist us with the processing purposes described in this CHD Notice, such as legal representatives who assist us with complaints involving CHD.
    • If the adverse event report relates to or implicates pharmaceutical products provided or sold by our affiliated or related entities, we may share your CHD with such affiliates or related entities.
    • Assignees or potential assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business.
    • Other parties with your consent.
  4. The categories of Consumer Health Data that we share may include the following categories:
    • Individual health conditions, treatment, diseases, or diagnosis
    • Social, psychological, behavioral, and medical interventions
    • Health-related surgeries or procedures
    • Use or purchase of prescribed medication
    • Bodily functions, vital signs, symptoms, or measurements indicating CHD
    • Diagnoses or diagnostic testing, treatment, or medication
    • Gender-affirming care information
    • Reproductive or sexual health information
    • Information that identifies that you are seeking health care services
    • CHD that we or our processors infer, derive, or extrapolate based on other CHD, or on personal information generally
  5. What Rights Do You Have Concerning Your Health Data?

    KCL provides individuals residing in states with applicable CHD Laws (as of the Effective Date, Washington) to which we are subject the privacy rights described in this CHD Notice:

    • Right to confirm processing of your CHD and access to such data
    • Right to correct/amend your CHD
    • Right to delete your CHD
    • Right to withdraw consent to processing of your CHD (from processing which requires your consent)
    • Right to appeal our refusal to act on a request within a reasonable time after you receive our decision. You may appeal our decision regarding your request by following the instructions in our response to your request. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.

    We may limit your request as necessary for us to complete requested services or as otherwise permitted by law.

    You may request to exercise your CHD privacy rights by completing this Rights Request Form and submitting it to us by emailing it to contact@kowa.com. Please note, as required by the CHD Laws, we take commercially reasonable efforts to authenticate your request before we process your request. If we believe we need additional information to authenticate your request, we may ask you to provide additional information to us.

    Depending on your state of residence, you may have additional privacy rights. These rights may include rights to access and control sensitive personal information, which may include CHD. Please refer to the State Privacy Rights section (Section B) of the Kowa U.S. Privacy Policy for more information.

  6. Changes to this Consumer Health Data Privacy Notice

    If we change this CHD Notice, we will post the revised version here and change the last updated date (the date it applies from) and/or contact you directly, as appropriate and required under applicable law. You should check here regularly for the most up-to-date version of the CHD Notice. If you have any questions about this CHD Notice or practices described in it, you may contact us by email at contact@kowa.com.