1.1. Scope of Application
This Privacy Policy describes our commitment to protection of data privacy and how we treat the personal information 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 DIŞ TİCARET A.Ş. or one of its affiliates as indicated under the Section “Data Controller” (“FUJIFILM” or “we”) and (ii) have a link to this Privacy Policy. In line with the Law on Protection of Personal Data numbered 6698 (“DPL”), this Privacy Policy aims to inform you regarding processing of your personal data while visiting the Website(s) or using the App(s).
In case stipulations that differ from this Privacy Policy are clearly indicated (i) on independent sub-sites in the Website(s) or (ii) in the App(s) through which personal information is provided, the relevant differing stipulations shall prevail.
1.2. Data Controller
The Data Controller in relation to any personal data that is collected within the scope of this Privacy Policy is FUJIFILM Dış Ticaret A.Ş. having its registered address at Mahmutbey Mah. Taşocağı yolu Cad. No:9 Bağcılar 34218 İstanbul, Turkey. 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 information.
2.1. Collection of Personal Information
In principle, you may view the Website(s) without disclosing personal information. 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.
You may be requested or required to provide Personal Information to access certain areas of the Website(s) or App(s). Also, we may ask for certain Personal Information when you place an order, request services, register for an account or subscription to an email newsletter or participate in marketing activities or research studies or correspond with us. Personal Information we collect may include your identity data (e.g. name, surname, date of birth), contact data (i.e. mailing address, phone number, email address); customer transaction data (i.e. order information, payment details, requests, complaints and other details you provide to us for example in a contact form), legal transaction data (i.e. litigation proceedings, warnings, notifications), professional experience data (position/ title collected in Fujifilm Professional), marketing data (i.e. cookie data, previous purchases, personal preferences, surveys, information received from campaigns/promotions/royalty programs or by means of other marketing communication) and information security data (i.e. username, web-site logs, IP addresses).
We process your Personal Information collected through our Website (s) and App (s) either (i) based on your explicit consent (Art. 5/1 DPL), and (ii) without your explicit consent in the existence of one of the legal grounds below:
- processing is explicitly provided for by the laws (Art 5/2 (a) DPL)
- processing is mandatory for the controller to fulfil its legal obligations (Art 5/2 (ç) DPL)
- processing of personal data belonging to the parties of a contract is necessary provided that it is directly related to the conclusion or fulfilment of that contract (Art 5/2 (c) DPL)
- Personal Information is made manifestly public by you (Art 5/2 (d) DPL)
- processing is mandatory for the establishment, exercise or protection of any right. (Art 5/2 (e) DPL)
- processing is mandatory for the legitimate interests of the controller, provided that such processing shall not violate the fundamental rights and freedoms of the data subjects (including customize and improve our web offerings, products and services) (Art 5/2 (f) DPL)
2.2. Purpose of Use of Personal Information
The purpose of use of your personal information 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 information provided by you shall be limited to the purpose of use clearly indicated to you in advance. 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 use 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.
The following examples illustrate possible scenarios in which we collect and use your Personal Information:
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 Information 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 analyze 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 Information 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. Email newsletters
If you subscribe to our newsletter(s), we will use the Personal Information 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 analyze 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.
2.2.6. Compliance Screening
Prior to entering into any form of relationship with Fujifilm, all prospective business partners, applicants, employees and visitors are hereby informed about potential screenings. The purpose of these screenings is to assess the suitability, credibility and integrity of prospective partners and employees, as well as the adherence to applicable law and regulations, as well as security protocols.
2.3. Data Sharing and Disclosure
We will not disclose or supply, share or otherwise distribute your personal information to third parties except as described in this Privacy Policy and/or our activity-based privacy statements. We share personal information in compliance with the DPL. As per article 8 of the DPL, personal information cannot be transferred without your explicit consent unless at least one of the legal grounds set out in article 5/2 of the DPL exists. In this respect we share your Personal Information when:
- Personal Information may be shared with the recipient groups designated in your given consent for the purposes reflected under such consent;
- Personal Information 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 Information only as necessary to provide these services.
- Personal Information 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 http://www.fujifilm.com/about/office/ to see a list of FUJIFILM Group locations we may share Personal Information 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 Information 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 Information 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 Information may be shared with authorized public institutions and organizations and other authorized real persons and private legal entities to whom personal information 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; or
- Personal Information 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 fulfil legal obligations of FUJIFILM.
2.4. International Data Transfer
We may transfer the personal information 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 information and fulfill our obligations on cross-border data transfer pursuant to article 9 of the DPL.
2.5. Data Security
As per article 12 of the DPL, FUJIFILM takes adequate technical and organizational security measures in order to protect your personal information from being misused and to prevent the loss of your information. Your personal information is saved in a secure operating environment that is not accessible to the public. All personal information 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.
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.
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).
3.1.2. 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 Information for as long as your account is active or as needed to provide you with services. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Pursuant to article 11 of the DPL, you have the right to apply to the FUJIFILM to learn whether your personal data is processed or not, to request information if your personal data is processed, to request the rectification of the incomplete or inaccurate data, if any, to request the erasure or destruction of your personal data if it is unlawful, to request notification of the operations carried out in compliance with this to the third parties to whom your personal data has been transferred and to request compensation for the damage arising from the unlawful processing of your personal data.
FUJIFILM reserves the right to change, amend, or update this Privacy Policy. If we do decide to change our Privacy Policy, we will post the revised Privacy Policy. On return visits to our site, please remember to review the Privacy Policy for any changes.