Privacy Policy

1.1.    Scope of Application 
As FUJIFILM, we give utmost priority to the processing and preservation of the personal data belonging to the data subjects with whom we interact in accordance with the Law No. 6698 on the Protection of Personal Data (“PDPL” or “Law”), the secondary regulations (regulations, communiqués, etc.) issued in accordance with the Law and the binding decisions taken by the Personal Data Protection Board/Authority (“PDPB”). 

This Privacy Policy describes our commitment to protection of data privacy and how we treat the personal data that we receive from visitors of the websites (“Website(s)”) and users of software applications (“App(s)”) that (i) are managed and operated by FUJIFILM HEALTHCARE TURKEY SAĞLIK A.Ş. or one of its affiliates as indicated under the Section “Data Controller” (“FUJIFILM” or “we” or "Company")  and (ii) have a link to this Privacy Policy. In line with the Law, this Privacy Policy, aims to inform you regarding processing of your personal data while visiting the Website(s), using the App(s) and while performing the main area of company activities; for the purpose of full compliance with the principle of transparency, and within this text, the Data Protection Statement is made regarding the personal data processing activities within the scope of the Company's main activity and business operations.

As a result of our sense of responsibility, we, as the “Data Controller” process your personal data considering legal limitations and purposes mentioned below; by providing all necessary technical and administrative measures to ensure the appropriate level of security, to prevent unlawful processing of personal data and unlawful access to personal data and to ensure the protection of personal data.

In case stipulations that differ from this Privacy Policy are clearly indicated (i) on independent sub-sites on the Website(s) or (ii) in the App(s) through which personal data is provided, the relevant differing stipulations shall prevail.

1.2.    Identity of the Data Controller 
The Data Controller in relation to any personal data that is collected within the scope of this Privacy Policy is FUJIFILM HEALTHCARE TURKEY SAĞLIK A.Ş. with taxpayer identification number 5950079964, located at “Kazım Özalp Mahallesi Nene Hatun Cad. No: 75/10 Çankaya/Ankara”. For further information please see the Website imprint.

1.3.    External Links
This Privacy Policy does not apply to those websites that have published their own privacy statement and to third party sites, even if links to their websites are on our Website(s) and App(s). Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave one of our Websites and to read the privacy statements of each and every website that collects personal data.

2.1.    Personal Data Collection Methods and Legal Bases 
Your personal data is processed by the Company directly from the information transmitted by you in verbal, written or electronic media, through the website and similar applications and software used within the scope of the Company's activities; by fully or partially automated or non-automated means, provided that it is part of any data recording system. 

In this context, the general personal data classified below are processed according to the legal bases stated in Article 5/1 & 2 of the Law. While establishing the classification below, both the execution of the Company’s business processes and Website(s), App(s), and software activities have been taken into consideration and the required Data Protection Statements and/or explicit consent statements regarding each process and operation of the Company are notified process-related groups of people in the form of a layered/gradual Data Protection Statements or by various means.

In principle, you may view the Website(s) without disclosing personal data. The Website(s) and App(s) may collect certain technical information, e.g. which content you have viewed within the Website(s), or which website you have referred to access the Website(s). In the process of collecting such information, which purpose is to improve the usability of the Website(s) or App(s), information shall not be collected in a manner in which you may be identified, nor shall you be identified during the process of information analysis.

Furthermore, personal data in the category of identification, contact information, and marketing processed for sending informative commercial electronic messages for advertising, campaigns and promotions within the scope of goods and service marketing and strategic marketing activities can be processed according to the legal basis of your explicit consent stated in Article 5/1 of the Law.

2.2.    Purposes of Personal Data Processing  
The purpose of use of your personal data shall be clearly indicated in this Privacy Policy or otherwise activity-based privacy statements published on individual sites, except in cases where the purpose of use is self-evident to you. The use of personal data provided by you shall be limited to the purpose of use clearly indicated to you in advance. Your personal data shall be collected and processed by the Company within the limits specified in the Law, in a limited and measured manner in accordance with the law, in good faith and always related to the purposes. However, we reserve the right to conduct additional processing to the extent permitted or required by relevant laws and regulations.

Furthermore, we may be required to use and retain personal data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or to combat fraud. We may also process personal data to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce terms and conditions; and (d) to protect our rights, privacy, safety, or property, or those of other persons and with our general commercial purposes as follows:

• Executing the necessary business by the Company's business units in order to fulfill the commercial activities carried out by the Company in accordance with the legislation and Company policies and executing activities in this direction,
• Determining, planning, and implementing the Company's short, medium and long term commercial policies,
• Managing customer relations, corporate communication and information security processes,
• Ensuring the commercial and legal security of natural and legal persons with whom the Company has business relations,
• Execution of service sales processes and after-sales support services,
• Determination of service marketing and marketing analysis,
• Execution of business and business continuity activities and service, production & operation processes,
• Executing the processes of risk management and ensuring the security of data controller operations.

In line with your demand, the purpose of processing each personal data category and data type will be detailed and communicated to you through the personal data inventory kept within the Company. Furthermore, Data Protection Statements regarding each process and operation of the Company are notified to the data subjects within the matching of the categories of personal data processed, legal bases and purposes of personal data processing. 

The following examples illustrate possible scenarios in which we collect and use your Personal Data:

2.2.1.    User Accounts
When you register for a customer account, we usually collect name, e-mail address and password. In addition, you can provide your address, including billing and delivery address in your customer account. When placing an order, we collect data on the goods you have selected, corresponding pricing information, any vouchers you might use, your billing and delivery address, and the selected method of payment and shipping. In connection with the fulfilment of orders we collect in particular information regarding payment, delivery and returns.

Our FUJIFILM Professionals Platforms are exclusive platforms for professional users specifically interested in receiving information on certain FUJIFILM products and services. When you register for a user account at one of our FUJIFILM Professionals Platforms, we usually collect your name, company name, department and job title as well as your business-related contact information.

We may use your Personal Data to maintain your user account, to verify that you are a legitimate user, to provide you with the requested information on FUJIFILM products and services, including any newsletters you may subscribe to and to respond to support and other enquiries you might have. In connection with your user account, we may analyse your use of our website and our newsletter to better understand your preferences and to improve our web services. We store such information in connection with your user account. If you have given your marketing consent, we might also contact you under your business contact details for marketing purposes in relation to our products and services that may be of interest for you.

If you have created a user account, we store your data for as long as you maintain your user account. In the event of deletion of your user account, we store the relevant data only to the extent permitted or required by law.

Through your user account, you can administer and update your contact data and your preferences. Please treat your access data as confidential and do not share your password with any third parties. If you become aware of, or if you suspect that a third party has obtained unauthorized access to your access data or uses your account, please change your password without undue delay.

2.2.2.    Personalized Services
In connection with the personalized services, we may process and use your information for advertising and market research purposes or for personalized provision of services if you have given your consent. If you give your consent the information accessed by you whilst visiting the Website(s) and Apps(s) may be stored in a user profile in order to be able to offer you information specifically personalized for you (e.g. in the form of a newsletter). You may withdraw your consent at any time with effect for the future. If you use personalized services we will use your Personal Data required for the provision of the services for the duration of your registration and thereafter for as long as required or permitted under applicable laws. We may share your information with affiliated FUJIFILM companies if this is necessary to respond to your inquiries or if necessary for the provision of the services. We may forward inquiries regarding our products and services also to a distributor that is responsible for the relevant product or service category and region.

2.2.3.    Blog / Forums
Some of our Websites offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

2.2.4.    E-mail Newsletters
If you subscribe to our newsletter(s), we will use the Personal Data necessary or separately provided by you to send you our email newsletter(s) as agreed based on your consent. Newsletter emails may contain web beacons, tracking pixels or links that allow us to analyse your use of the newsletter, including information on whether you received and opened our newsletter. You may withdraw your consent and unsubscribe from the newsletter at any time either by sending a message to us or via a dedicated unsubscribe link in the newsletter or by means of other ways available under applicable laws.

2.2.5.    Other Communications
If we receive your email address in connection with the sale of goods or services, we may communicate with you to inform you on any adjustment, modifications, amendments on such products / services, or to provide you with user manuals / after sales service information with regard to such products / services. We may further communicate with you to fulfill our obligations to inform you in line with applicable legislation. We may also communicate with you for solely informative purposes on unpaid debts, ongoing memberships, invoices.

2.3.    Data Sharing and Disclosure 
We will not disclose or supply, share or otherwise distribute your personal data to third parties except as described in this Privacy Policy and/or our activity-based data protection statements. We share personal data in compliance with the PDPL. In order to fulfill the above-mentioned purposes and to ensure the uninterrupted execution of the Company’s commercial operations and business processes, your personal data may be transferred to both domestically or globally to the specified below, by taking all necessary technical and administrative measures for data security; in accordance with the legal basis of your explicit consent in Article 8/1 of the Law domestically  if deemed necessary and in accordance with the legal basis of your explicit consent in Article 9/1 of the Law globally if deemed necessary, and in compliance with the legal bases specified in Article 8/2/a of the Law domestically, which indicates processing of your personal data if it is expressly provided for by the laws, if it is necessary for compliance with a legal obligation to which the data controller is subject, if data processing is necessary for the establishment, exercise or protection of any right and for legitimate interests of data controller without violating fundamental rights and freedoms of data subject.

In this respect we share your personal data when:

• Personal Data may be shared with the recipient groups designated in your given consent for the purposes reflected under such consent;
   
• Personal Data may be shared with our service providers; if it is necessary to provide you with our services, including in particular, providing customer service, supporting our marketing and product distribution, or operating our systems or applications. These companies are authorized to use your Personal Data only as necessary to provide these services.
   
• Personal Data may be shared with the FUJIFILM Group if needed to provide services or fulfill product orders, for account administration, to facilitate sales and marketing, for customer and technical support, and to promote business and product development. Please click here https://global.fujifilm.com/en/ to see a list of FUJIFILM Group locations we may share Personal Data with. We may also forward inquiries regarding our products and services to a third-party distributor that is responsible for the relevant product or service category and region;
   
• Personal Data may be shared with financial institutions or other parties for payment settlement when you order products or use other services which require a fee, your name, address, credit card number, and other information;
   
• Personal Data may be shared with related and authorized real persons or private legal entities or authorized public institutions and organizations involving in such transactions when our business is assigned or transferred either by operation in law or otherwise including mergers, consolidations and dissolution or transfer of operations;
   
• Personal Data may be shared with authorized public institutions and organizations and other authorized natural persons and private legal entities to whom personal data disclosure is required by applicable laws and regulations or such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding conducted by relevant authorities;
   
• Personal Data may be shared with authorized public institutions and organizations and other authorized real persons and private legal entities when there is an immediate need for disclosure to protect human life or human rights or to fulfill legal obligations of FUJIFILM.
   
• Personal data may be transferred to the Company’s suppliers and representatives, to the business partners from whom services are provided or with whom the Company corporates in order to execute and develop Company’s activities only if necessary; in order to ensure purpose of processing, execute FUJIFILM’s commercial processes and operations, and ensure business continuity. 
   
• In cases where your explicit consent is obtained for personal data transfer within FUJIFILM for both domestic and international data transfers. You can withdraw your explicit consent for the transfer at any time and consult with the Company's officials.

Except for the explanations contained in this Privacy Policy, Data Protection Statements and/or explicit consent statements regarding each process and operation of the Company are notified to the relevant groups of people in the form of a layered/gradual Data Protection Statements or separately through various means.

2.4.    International Data Transfer
We may transfer the personal data we collect to, and store such information in, other countries which may have different privacy or data protection laws than the country in which the information was provided. In such case, we will take appropriate measures to protect your personal data and fulfill our obligations on cross-border data transfer pursuant to article 9 of the PDPL.

2.5.    Data Security 
As per article 12 of the PDPL, FUJIFILM takes adequate technical and organizational security measures in order to protect your personal data from being misused and to prevent the loss of your information. Your personal data is saved in a secure operating environment that is not accessible to the public. All personal data provided by you in the course of registration or use of personalized services will be transferred in encrypted form in order to prevent misuse of the information by any third party.

All employees of FUJIFILM are equipped with awareness educations on the Law, periodically informed and have gained the notion of confidentiality. FUJIFILM acts with awareness and sensitivity in all activities carried out by the Company and throughout the life cycle of personal data within the Company.

3.1.    Use of Cookies and Tracking Technology 
Our Website(s) and App(s) may use “Cookies” or similar technologies (analysis programs and social media services). Cookies are text files that are sent by a Website(s) to the user's browser in order to store information on the user's devices. Whenever the Website(s) is accessed, the information contained in the Cookie is read by the Website(s).

3.1.1.    Your consent to the use of cookies
We distinguish between strictly necessary cookies, which are required for the proper functioning of our Website(s), and other cookies. Strictly necessary cookies do not require your consent. For other cookies we request your consent before placing them on your device. You can use our website only after confirming your cookie settings.

When you first visit our Website(s) a pop-up window is shown with our Cookie Consent Manager. If you click on the button “Cookie Settings” you will be directed to the Privacy Preference Center. The Privacy Preference Center also displays a cookie list where you can find details about the cookies and the purposes they are used for. In the Privacy Preference Center you can enable or disable the use of cookies with the toggle switch. Please note that if you do not accept cookies, you may not be able to use certain features of our website as intended.

3.1.2.    Changing your cookie preferences / withdrawing your consent
You may change your cookie preferences anytime in the Cookie Settings.

Cookie Settings

You can also deactivate the use of / delete cookies via your browser settings at any time. Please note that in this case you may not be able to make full use of the complete range of functions offered by the Website(s).

3.1.3.    Cookie List

3.2.    Social Network Plug-ins
Our Website(s) and App(s) may offer plug-ins for social networks (“Networks”). Social network plugins are easy ways of sharing content with other people via Networks. When you access the Website(s), these plug-ins can potentially create a direct connection between your browser and the respective Networks. If you interact with the plug-ins, for example in the case of Twitter by clicking on “Tweet This” or with Facebook by clicking the ‘I like' button or making a comment, the corresponding information will be transmitted directly from your browser to the Network. In some cases, information is already exchanged with a Network when you visit the Website(s), regardless whether you interact with the plug-ins or not.

You can prevent information from being shared with a Network by not allowing the corresponding Cookies and/or logging off from the Network before using the Website(s).

We will retain your Personal Data for as long as your account is active or as needed to provide you with services. We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You may apply to FUJIFILM at any time and request to exercise your rights arising from the Article 11 of the PDPL: a) to learn whether your personal data has been processed, b) to demand for information if your personal data have been processed, c) to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose, ç) to know the third parties to whom your personal data are transferred in country or abroad, d) to request the rectification of the incomplete or inaccurate data e) to request the erasure or destruction of your personal data under the conditions referred to in Article 7, f) to request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) to third parties to whom your personal data have been transferred, g) to object to the occurrence of a result against the person himself/herself by analysing the data processed solely through automated systems, ğ) to claim compensation for the damage arising from the unlawful processing of your personal data”.

You may submit your requests regarding your rights and the enforcement of the Law by filling and signing out the application form that you can obtain from us or from FUJIFILM Website(s) and;

1. Send it with wet-ink signature to “Kazım Özalp Mahallesi Nene Hatun Cad. No: 75/10 Çankaya/Ankara” via notary public, by registered mail with return receipt requested at your discretion for ease of proof or by your personal application,
2. By sending your application via e-mail to fujifilmhealthcare@hs03.kep.tr using the registered electronic mail (KEP) address assigned to your name,
3. By sending an e-mail to kvkk_hctr@fujifilm.com.tr using the e-mail address notified to the Company by you and registered in the company system.

FUJIFILM will respond to the requests within this scope within thirty (30) days without charging a fee for up to ten pages if a written response is to be given, and by charging a transaction fee of 1 Turkish lira for each page over ten pages. If the response to the application is given in a recording media such as CD, flash memory, the fee that may be requested by the Company shall not exceed the cost of the recording media.

As the personal data owner, in the application you will make to exercise your rights mentioned above and which contains the explanations regarding the right you have request to exercise; the requested matter needs to be clear and understandable, the subject needs to be related to yourself and in case you are acting on behalf of someone else, you will need to submit your special power of attorney certified by the notary in this regard.

In accordance with the "Communiqué on The Principles and Procedures for the Request to Data Controller", it is mandatory to include name-surname, signature, Turkish Identification (“ID”) number (for foreigners, nationality, passport number or ID number if any), residential or workplace address for notice, e-mail address, telephone and fax number and the subject of the request in your applications. Applications that do not fulfill such elements will be rejected by FUJIFILM or directed to the valid application channels.

FUJIFILM reserves the right to make changes in this Privacy Policy due to the Law, secondary legislations and committee resolutions. In the event that, we decide to change our Privacy Policy, we will publish the updated Privacy Policy. No notification is required prior to the updates to be made from time to time due to operational requirements and includes all services and products, pages, information and visual elements. Any changes to be made in Privacy Policy and the updated text will take effect immediately as of the date of notification. On return visits to our site, please remember to review the Privacy Policy for any changes.

FUJIFILM reserves the right to change all products and services, pages, information, visual elements on the Website(s) without prior notice.