Privacy Policy

Please note that this Terms of Use and Privacy Policy presented in this app are tailored to comply with regulations specific to your home country. By continuing to use the app, you agree to the terms outlined for your respective country. If you are accessing this app from a different country, ensure that you refer to the applicable version relevant to your home country presented in a local language.

Suomi
Deutschland
United Kingdom

Introduction

Your privacy and the protection of your personal data is important to us. In this privacy policy, we inform you in particular about the type, scope and purposes of data processing as well as your rights as a data subject if you use the Application FULL ADHD - full life ("App" or "FULL ADHD").

Takeda is a globally active group of companies. Takeda includes its parent company, Takeda Pharmaceutical Company Limited, and its affiliates (collectively, "Takeda" or "We"). This Application is operated and managed by our service provider Psyon Games Oy on behalf of Takeda. For more information, please see the "How to Contact Us" section below. Contact information for your local subsidiary can be found in Takeda's worldwide corporate information.

1. Controller and Data Protection Officer

The controller for the processing of your personal data when using the FULL ADHD Application within the meaning of the UK General Data Protection Regulation ( the UK GDPR) is

Takeda UK Ltd, 1 Kingdom Street, London, W2 6BD PrivacyOffice@takeda.com

For all questions regarding data protection in connection with the use of the Application, you can also contact our Data Protection Officer at any time.

This can be reached at the e-mail address: PrivacyOffice@takeda.com. We expressly point out that when using this e-mail address, the content will not be taken note of exclusively by our Data Protection Officer. If you wish to exchange confidential information, you should therefore first ask to contact the Data Protection Officer directly via this e-mail address.

2. What the Application can be used for

The purpose of the FULL ADHD mobile Application is to encourage users to maintain their own health and that of their loved ones. The App is designed to help users identify ADHD, its symptoms, as well as the risk factors, and to support users in obtaining additional information about the treatment of ADHD. The mobile Application is not intended to diagnose a disease and it does not replace the consultation of a doctor. The App is intended for people aged 16 and over.

3. How we process the information

The personal data and information that we process about you (collectively and individually, the "Information", "Data") include:

3.1 Push Notifications

When you first open the App, you may be asked if you want to receive push notifications. This allows us to inform you about events or functionalities while the App is running in the background. You can disable or enable these features at any time using the notification options in your device settings. In order to be able to send you push notifications, we use the push notification services of Google LLC or Apple, Inc. as processors, depending on the device. Since Google LLC is certified under the Data Privacy Framework (adequacy decision), there is an adequate level of protection when transferring data to the USA. Apple Inc., on the other hand, is not certified under the Data Privacy Framework, which is based both a data processing agreement and standard contractual clauses with both Google Inc. and Apple Inc. and have taken further measures to ensure an adequate level of data protection, see also Section 7. The legal basis for the push notifications is your consent, which can be revoked at any time, in accordance with Art. 6 (1) (a) the UK GDPR.

3.2 Contacting Us

If you need user assistance or technical support, please contact us using the contact button directly in the Application. If you have questions relating to your medical condition or any health-related question, please liaise with your doctors and do not contact Takeda directly, as Takeda does not process any directly identifiable health information about you. Takeda has Appointed a Data Protection Officer which you may contact at privacyoffice@takeda.com with any questions or requests.

The legal basis for this processing is Art. 6 (1) (b) the UK GDPR, insofar as your information is required to answer your enquiry or to initiate or execute a contract, and otherwise Art. 6 (1) (f) the UK GDPR on the basis of our legitimate interest in you contacting us and for us to be able to answer your enquiry. This is a legitimate user service that originates from the user.

The data collected by us when you contact us will be stored for a period of 3 months and then deleted, unless we still need your request to fulfil contractual or legal obligations.

3.3 Data processed during the game

No registration is required to use the mobile Application, and therefore Takeda does not collect any personal information during registration.

Takeda does not attempt to identify users on the basis of the Data processed by Takeda and strives to aggregate and minimise the data so that the user cannot be identified on the basis of the data.

However, when using the Application or playing the game, the following may be processed: time of the start of the match; decisions made during the game that guide the game or determine the further game plot, game engine, duration of the game.

3.4 Surveys

User surveys can be carried out as part of the Application.

You have the opportunity to participate in one of our surveys. We use the results of these surveys to improve our service.

The legal basis for data processing when participating in the survey is Takeda's legitimate interest in accordance with Art. 6 (1) (f) the UK GDPR in order to optimize the effectiveness of the content of the App. Takeda also only receives aggregated data.

We process the information in order to provide you with the above-mentioned functions and to provide you with optimal functionality and operation. We also process the Information to administer and improve the Application.

4. Protection of your Data

Takeda uses reasonable and Appropriate physical, administrative, and technical safeguards to protect the Information it processes from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Although Takeda does its best to protect the Data it processes, Takeda cannot guarantee that the Data will not be lost, misused or altered. The transmission of the Data is at the user's risk and it must be borne in mind that the security of data transmitted over the internet cannot be guaranteed.

5. Use of cookies, analysis tools and payment service providers and, if Applicable, comparable technologies

This Application uses cookies and similar technologies (collectively, "Tools") offered either by us or by third parties.

A cookie is a small text file that is stored on your device through the settings. Cookies are not used to run programs or to download viruses to your computer. Comparable technologies are in particular web storage (local / session storage), fingerprints, tags or pixels. Most devices are set to accept cookies and similar technologies by default. However, you can usually adjust your settings so that cookies are rejected or stored only after prior consent. If you reject cookies, not all of our services may work smoothly for you.

In the following, the tools we use are listed by category, whereby we inform you in particular about the providers of the tools, the storage period of the cookies and the transfer of the data to third parties. It also explains in which cases we obtain your voluntary consent to use the tools and how you can withdraw it.

Legal basis and revocation

We use tools necessary for the operation of the Application on the basis of our legitimate interest in accordance with Art. 6 (1) (f) the UK GDPR in order to enable you to use the Application conveniently and individually and to make the use as time-saving as possible. In certain cases, these tools may also be necessary for the performance of a contract or for the implementation of pre-contractual measures, in which case the processing is carried out in accordance with Art. 6 (1) (b) the UK GDPR.

We use all other tools, in particular those for marketing purposes, on the basis of your consent in accordance with Art. 6 (1) (a) the UK GDPR. In these cases, access to and storage of information in the terminal device is subject to consent and is based on the Privacy and Electronic Communications Regulations (PECR). Data processing with the help of these tools only takes place if we have received your prior consent for this.

If personal data is transferred to third countries, we refer to Section 7 ("Where we store your data"), also with regard to the risks that may be associated with it. There are standard contractual clauses or other guarantees in place with the providers of certain tools. If you have given your consent to, we will (also) transfer the data processed during the use of the tools to third countries on the basis of this consent.

You can revoke your consent for certain tools at any time with effect for the future via the settings in the Application. There you can also change the selection of tools you want to agree to use.

In order to improve our Application, we use tools for the statistical recording and analysis of general usage behavior based on access data ("analysis tools"). We also use analytics services to evaluate the use of our various marketing channels.

Unless otherwise stated, the legal basis for the analysis tools is your consent in accordance with Art. 6 (1) (a) the UK GDPR. In the event that personal data is transferred to the USA or other third countries, your consent expressly extends to the data transfer (Art. 49 para. 1 lit. a the UK GDPR). The associated risks can be found in Section 7. You can revoke your consent at any time with effect for the future.

Singular

Singular is a Mobile Measurement Partner service which we use to measure the effectiveness of our user acquisition. Based on the user’s consent, the following information is processed: the user's ID and advertiser ID; App install details; Device information (manufacturer, model and brand, CPU, display, type of device, system language, operating system version, type of internet connection and mobile carrier, device time); App details (App ID, version number, time of last update); Singular SDK details (version number, language).

The service is provided by Singular Labs, Inc., 181 South Park Street, Unit 2, San Francisco, CA 94107, USA. Further information on the processing of personal data by Singular can be found here: https://www.singular.net/privacy-policy/.

Google Services

The App uses Google services provided in the Europe, Middle East and Africa (EMEA) region by Google Ireland Limited, located at Gordon House, Barrow Street, Dublin 4, Ireland.

Google Firebase

We use Google Firebase to monitor the quality of the App by tracking any events that could degrade the usability of the App.

In particular, the following Information is processed: device information (device IP address, language, screen resolution, operating system version); App exceptions and errors (error messages, App crashes); App install events (initial installation, reinstallation, update, uninstallation); App session start time; User activity within the App; Screen view name and class.

Please find more information about the meanings of the listed data categories on the Google Firebase website under:

https://support.google.com/analytics/answer/9234069?visit_id=638309094992112493-2105112310&rd=2

Google Firebase is linked to Google Analytics 4 (see below), where the Data collected by Firebase may be combined with other personal data held by Google, but only if the user has given explicit permission for the sharing of their personal data directly with Google. We use the aggregated Data to understand the patterns of users using the App in order to improve the development and user acquisition of the App. The service is not used for remarketing. The purpose for collecting and processing the above data is product optimization and marketing activities. The above-mentioned data collection takes place only if the player gives explicit consent to the processing of the data for product optimization and marketing activities in this game.

Further information on the processing of the Data by Google Firebase can be found here: https://firebase.google.com/support/privacy?authuser=0

Google Analytics 4

Our App uses the Google Analytics 4 ("Google Analytics") service.

Google Analytics uses cookies and similar technologies to analyze and improve our App based on your user behavior. Google will process the information obtained in order to evaluate your use of the App, to compile reports on activities and to provide other services related to App use and internet usage. The data generated in this context may be transmitted by Google to a server in the USA for evaluation and stored there. The following data is processed by Google Analytics: IP address, User ID, Google ID (Google Signals) and/or Device ID, Number of users and sessions, Duration of the session, Operating system, Geolocation, Device model, First app launch, App openings (App open), App updates.

Of these, only the App-specific data (see Google Firebase above) is sent to Google Analytics via Google Firebase. Other data points result from combining users' game data with their Google data (e.g., web and App browsing history associated with their Google Account) from other Google services, if users have consented to sharing.

For more information about Google Analytics 4 cookies, please visit: https://support.google.com/analytics/answer/11397207?hl=de

For more information, please refer to Google's privacy policy: https://support.google.com/analytics/answer/6004245

Google Ads services

Google Analytics 4 is also connected to Google Ads, which we use to generate and manage App ads for FULL ADHD. Customer actions defined by us (such as clicking on an advertisement, page views, downloads) are recorded and analyzed by means of "Google Ads Conversion Tracking". We use "Google Analytics 4 Advertising Functionality" to have access to demographic and interest-based data in our analytics reports. Both services use cookies, JavaScript, pixels and other technologies for this purpose. Google also processes the data to improve and further develop its own products and services, for the aggregated statistical evaluation of conversions and to improve the quality and accuracy of conversions. The data generated in this context may be transmitted by Google to a server in the USA for evaluation and stored there.

If you use a Google Account, Google may link your web and App browsing history to your Google Account and use information from your Google Account to personalize ads, depending on the settings you have in your Google Account. If you do not want this assignment to your Google account, it is necessary that you log out of Google before accessing our website.

The game does not contain any ads. Even if explicit consent is given to the use of personal data for marketing activities, we do not target users with personalized ads, nor do we use the audience data for remarketing.

If you have not consented to the use of Google Ads, Google will only show general advertising that has not been selected based on the information collected about you on this website. In addition to revoking your consent, you also have the option of deactivating personalized advertising in the settings for advertising on Google: https://adssettings.google.com/notarget

For more information, see:

in the information on data use: https://policies.google.com/technologies/ads
in Google's privacy policy: https://policies.google.com/privacy

Google Play services

We use Google Play services to allow users to download our Apps. When you download an App from Google Play, Google collects device information, such as version numbers and error reports, from your Android device in accordance with the agreement between you and Google.

Google Play services are provided by Google Commerce Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

For more information about personal information in relation to Google Play, visit this link: https://policies.google.com/privacy

Game Analytics

We use GameAnalytics to analyse App usage patterns, and to improve the App's functionality and user experience. Based on the user's consent, the following information is processed: Device information (manufacturer, model, version, operating system type and version, type of network connection); the User ID; the user's advertiser ID; App events (menu usage, progress, responses to in-App surveys, external link clicks); App session ID and sequence number; App version number.

The GameAnalytics service is provided by GameAnalytics ApS, Pilestræde 58, 2, 1112 Copenhagen K, Denmark.

More information about the GameAnalytics service: https://docs.gameanalytics.com/integrations/api/event-types/#default-annotations-shared

More information on the use of personal data in relation to GameAnalytics: https://gameanalytics.com/legal/privacy-notice

Apple services

Apple App Store

When you download an App from the Apple App Store, Apple collects device and version information and bug reports from your iOS device in accordance with the agreement between you and Apple, Inc. Apple, Inc. contact information: One Apple Park Way, Cupertino, CA 95014, USA.

Apple Search Ads

We use Apple Search Ads for user acquisition of the App in Apple's marketing channels and to measure the effectiveness of this user acquisition. If the App was installed through an advertisement in Apple's marketing channels and based on the user’s consent, the App will collect the following data: the ad through which the App was installed; whether this was a first install or reinstall, the country or region of the ad campaign.

More information on the use of personal data in relation to Apple: https://www.Apple.com/legal/privacy/

6. Disclosure of your data

We will share your data with business partners, suppliers and processors who provide services on behalf of Takeda, including the software company Psyon Games Oy, which manages the mobile Application; Analytics and search engine service providers who support Takeda in the development and optimization of the mobile Application. We will also share your information with Takeda's affiliates and subsidiaries.

7. Where we store your data

Your data is stored on your mobile phone or pad. As explained in this privacy policy, we use services whose providers are partly located in so-called third countries (outside the UK, European Union or the European Economic Area) or process the Data there, i.e. countries whose level of data protection does not correspond to that of the UK and European Union. To the extent that this is the case and there is not an adequacy decision (Art. 45 the UK GDPR) for these countries, we have taken Appropriate precautions to ensure an adequate level of data protection for any data transfers. There is an adequacy decision for the USA; in cases where the providers are not registered in the EU-U.S. Data Privacy Framework, we have also taken Appropriate precautions. These include, among others, the standard contractual clauses or binding internal data protection regulations.

Where this is not possible, we base the data transfer on exceptions to Art. 49 the UK GDPR, in particular your express consent or the necessity of the transfer for the performance of the contract or for the implementation of pre-contractual measures.

If a transfer to a third country is provided for and there is no adequacy decision or suitable safeguards, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) can gain access to the transmitted data in order to collect and analyse it, and that the enforceability of your rights as a data subject cannot be guaranteed.

8. How long we keep your data

We store your personal data for a period of three months when you contact our customer service. In addition, we only receive aggregated data from the service providers we use. Please find more information on the exact storage period of your personal data processed by the service providers under point 5 of this privacy policy.

9. Your rights as a data subject

You are entitled to the rights of data subjects below.

If you would like to make a request to exercise any of these rights, please contact us at privacyoffice@takeda.com or by accessing our Individual Rights webform.

You are entitled at all times to the rights of data subjects formulated in Art. 15 – 21, Art. 77 the UK GDPR:

Right to revoke your consent at any time with effect for the future;
Right to object to the processing of your personal data (Art. 21 the UK GDPR);
Right to information about your personal data processed by us (Art. 15 the UK GDPR);
Right to rectification of your personal data that has been incorrectly stored by us (Art. 16 the UK GDPR);
Right to erasure of your personal data (Art. 17 the UK GDPR);
Right to restriction of processing of your personal data (Art. 18 the UK GDPR);
Right to data portability of your personal data (Art. 20 the UK GDPR);
Right to lodge a complaint with a supervisory authority (Art. 77 the UK GDPR).

To assert your rights described here, you can contact us at any time using the contact details provided. This also Applies if you wish to receive copies of guarantees to demonstrate an adequate level of data protection. If the respective legal requirements are met, we will comply with your data protection request.

Your requests to assert data protection rights and our responses to them will be retained for documentation purposes for a period of up to three years and, in individual cases, for the assertion, exercise or defense of legal claims. The legal basis is Art. 6 (1) (f) the UK GDPR, based on our interest in defending against any civil law claims under Art. 82 the UK GDPR, avoiding fines under Art. 83 the UK GDPR and fulfilling our accountability obligations under Art. 5 (2) the UK GDPR.

You have the right to revoke your consent to us at any time. As a result, we will no longer continue the data processing that was based on this consent for the future. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent before the revocation.

To the extent that we process your data on the basis of legitimate interests, you have the right to object to the processing of your data at any time on grounds relating to your particular situation. If it is a matter of objecting to data processing for direct marketing purposes, you have a general right to object, which we will implement even without giving reasons.

If you would like to make use of your right of revocation or objection, an informal message to the above contact details is sufficient.

After all, you have the right to complain to a data protection supervisory authority. You can exercise this right with a supervisory authority in the Member State of your residence, place of work or place of the alleged infringement. The responsible supervisory authority for us is the Information Commissioner's Office (ICO).

10. How to reach us

If you have a complaint about the way your personal data is processed, you also have the right to contact the data protection supervisory authority in your home country, if there is one.

Takeda has Appointed a Data Protection Officer who you can contact if you have any questions or requests at privacyoffice@takeda.com

For more detailed information on how Takeda processes your personal data and your privacy rights, please see http://www.takeda.com/privacy-notice/

11. Acknowledgement/Consent

By using this Application, which is dependent on clicking on "I accept", you confirm that you have read and understood this statement and consent to the processing of your data for the purposes and scope explained in this privacy policy.