INTRODUCTION

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

This Privacy Statement tells you how we use the information we collect about you through this Alsanza Medikal Estetik ve İlaç Tic. A.Ş (“Alsanza”) website operated by Alsanza Medikal Estetik ve İlaç Tic. A.Ş based in Turkey as well as any mobile sites, applications ( “apps”), widgets, conferences, events, electronic newsletters, communications, or other services (collectively the “Services”) that link to this Privacy Statement. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies, nor does it apply to other Alsanza Medikal Estetik ve İlaç Tic. A.Ş websites, including websites operated by other Alsanza Medikal Estetik ve İlaç Tic. A.Ş affiliates.

This Privacy Statement also does not apply to data processing activities specifically relating to current or former Alsanza Medikal Estetik ve İlaç Tic. A.Ş employees or applicants. The relevant Employee Privacy Statement or Applicant Privacy Statement may be requested by contacting career@Alsanza.com.

You should review the privacy statement posted on other Alsanza websites when you visit them. This website and this Privacy Statement are intended for global audiences.

We intend to deal with your information in a manner that is fair and in line with your expectations and encourage you to read and consider the information provided in this Privacy Statement to confirm that this is the case.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The information we receive and how we use it depends on what you do when visiting our website or using our Services. We collect and use non-personal information (information that does not identify you personally) differently to your personal information.

YOUR PERSONAL INFORMATION

Personal information is information that can specifically identify you, such as your:

  • first and last name
  • address, telephone number, e-mail address, or other contact information
  • medical device serial number
  • personal health information
  • date of birth or age
  • social media username or profile
  • interests and qualifications
  • IP (Internet Protocol) address when such address is associated with a specific user

We collect personal information about our users in two ways:

  1. When you directly provide information to us, e.g., by entering personal information on certain website pages. For example, you may fill out a registration form for a particular service, participate in a survey, or complete a contact form.
  2. Using automated means, specifically through cookies. Cookies are small text files placed on your computer by websites you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the website. For more information about the cookie policy, please read below:

CookIes and Other Tools

Alsanza Medikal Estetik ve İlaç Tic. A.Ş and its Providers collect information about you by using cookies, tracking pixels, and other technologies (collectively, “Tools”). We use this information to understand better, customize and improve user experience with our websites, services, and offerings, and manage our advertising. For example, we use web analytics services that leverage these Tools to help us understand how visitors engage with and navigate our Site, e.g., how and when pages in a site are visited and by how many visitors. We can also offer our visitors a more customized, relevant experience on our sites using these Tools by delivering content and functionality based on your preferences and interests. If we have collected your personal data, e.g., through a registration or a request for certain materials, we may associate this personal data with information gathered through the Tools. This allows us to offer increased personalization and functionality on the Site.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, cookie-enabled websites will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the services function properly.

Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses to calculate usage levels, diagnose server problems, and administer the Site. We may also derive your approximate location from your IP address.

We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Site and report on activities and trends. This service may also collect information regarding other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We may use Flash Local Shared Objects (“Flash LSOs”) and other technologies to collect and store information about your use of the Site, among other things. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used in connection with the Site.

HOW DOES ALSANZA  USE PERSONAL INFORMATION?

We may use the information that you have shared with us through this website and relevant Services (other than sensitive information, which is discussed separately below) for the following purposes:

  • to respond to your requests
  • to provide the services or information you request
  • to allow you to register certain products or services or enhance their functionality
  • to resolve and track the status of any consumer and/or product or service issues
  • to manage our relationship with you and facilitate any necessary follow-up (e.g., by storing relevant information and preferences for a reasonable amount of time)
  • to enter into or perform a contract with you (e.g., in case you wish to order products or services from us)
  • to enable you to participate in our online communities, including social media and blogs
  • to enable you to participate and join online meetings/webcasts in this website
  • to contact you with information that might be of interest to you – see further the Marketing and Education section below
  • In other ways to which you consent

Alsanza Medikal Estetik ve İlaç Tic. A.Ş may also use your personal information to the extent necessary to achieve the following legitimate interests, so long as compatible with your rights and expectations of privacy:

  • for analytical purposes to research, develop, and improve programs, products, services, and content
  • to anonymize your information by removing any personal identifiers (your name, e-mail address, etc.) so that it may be used for other purposes. In this case, the anonymized information would no longer identify you and may be treated like other non-personal information. For more details, please see the relevant section below.
  • to enforce this Privacy Statement and other rules about your use of this website
  • to protect our rights or property

Alsanza Medikal Estetik ve İlaç Tic. A.Ş also has legal grounds to use your personal information:

  • as necessary to protect someone’s health, safety, or welfare; and
  • to comply with a law or regulation, court order, or other legal process

Where required by law, we will ask you to “opt-in” or affirmatively consent to processing your personal data for a particular purpose. For example, where the law requires, we will only send you newsletters if you have subscribed to them.

WHAT IS SENSITIVE INFORMATION?

Some types of personal information are sensitive information. Sensitive information is personal information revealing or relating to your health (such as your device serial number or the date of a surgery or injection), genetic or biometric data, your racial or ethnic origin, religious or philosophical beliefs, sex life, or sexual orientation, political opinions or trade union membership.

WILL ALSANZA TREAT SENSITIVE INFORMATION DIFFERENTLY TO OTHER PERSONAL INFORMATION?

Alsanza Medikal Estetik ve İlaç Tic. A.Ş will only collect and process your sensitive information:

  • in ways for which you have given your explicit consent
  • to protect the vital interests of you or another person in cases where your explicit consent cannot be given or reasonably requested
  • according to applicable laws, which include suitable and specific measures to safeguard your fundamental rights and interests
  • where the processing is necessary for medical purposes, and we are, under the circumstances, under a duty of confidentiality equivalent to the duty of confidentiality of a health professional
  • to establish, exercise, or defend a legal claim

For example:

  • We may collect sensitive information directly from you when you voluntarily provide it to us for a particular purpose (e.g. when you contact us with a question or suggestion about our products and services);
  • We may also collect sensitive information about patients through healthcare professionals whom we work with to provide therapy or technical support for our products or services to you;
  • We may collect sensitive information as required by the U.S. Food and Drug Administration, European, and other governmental authorities to assure safe and effective use of our products and services;
  • We may collect sensitive information about participants who have explicitly consented to participate in clinical trials, studies, and other research initiatives.

NON-PERSONAL INFORMATION

Non-personal information is information that cannot identify you or be tied to you in any way. Therefore the non-personal information we collect through this website does not identify you as an individual person, and will not be linked to you. It may include information such as the following:

  • the type of web browser software you use (for example, Internet Explorer)
  • the name of the domain from which you access the Internet
  • the Internet address of the website from which you linked directly to our website
  • the date and time you access our website
  • which pages you have visited on our website
  • the search terms you use
  • the links on which you click

If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information from your computer. This information is collected from your computer’s web browser. If you only read or click to download information on our website, we do not collect or learn your name, e-mail address, home address, or any other personal information about you. For more information about how we use cookies to collect information about visitors to our website, please click here.

WHAT DOES ALSANZA DO WITH NON-PERSONAL INFORMATION?

We are always looking for ways to serve you better and improve our products, services, and website experience. We will use your non-personal information to make this website more useful to visitors. We may also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:

  • create reports for internal use to develop programs, products, services, or content
  • adapt or improve the information or services provided
  • share or sell information to third parties
  • provide information on how our site is used, such as “traffic statistics” and “response rates” to third parties

DIRECT MARKETING AND EDUCATIONAL MATERIALS

Alsanza Medikal Estetik ve İlaç Tic. A.Ş may wish to provide you with educational materials or other information about our products and services, as well as information about clinical trials or the products and services of others that might be of interest to you based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of Alsanza Medikal Estetik ve İlaç Tic. A.Ş websites, social media, and blogs. Please click here for more information on how we use cookies and your choices.

We will ask you to “opt-in” or affirmatively consent to using your personal information for such communications per applicable laws.

If at any time you decide not to receive any educational, commercial, or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at the contact details listed below and mention “OPT-OUT” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any relevant message you receive from us.

Please note that if you opt not to receive promotional messages from us, we may continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that Alsanza Medikal Estetik ve İlaç Tic. A.Ş is required by law to provide, e.g., regarding product recalls.

SURVEYS

From time to time, we may invite you to participate in a survey to determine customer satisfaction levels, identify potential improvement areas, or carry out market research. We may send you a specific invite to participate in such a survey based on our legitimate interests in conducting the survey or based on your prior “opt-in” consent to receive such communications in accordance with applicable laws. You may opt out of receiving any such future communications in the manner detailed in the section above.

The personal data collected for the survey may include your email address, phone number, survey results, and any free-text message you may have written in the survey.

We process your personal information as part of the survey for carefully considered and specific business purposes that are in our legitimate interests and which we believe also often benefit you, based on our assessment that our legitimate interests do not override your freedom and data protection rights.

The business purpose of collecting your data is to reply to survey feedback you may have provided, specifically:

  • Should you have indicated an issue that we need to take action to resolve
  • To gain further insight into the experience you have described
  • To inform you of any action we might take internally to resolve your issue or enhance your experience

DOES ALSANZA EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

Alsanza Medikal Estetik ve İlaç Tic. A.Ş will not share your personal information with a third party except as described in this Privacy Statement.

In the ordinary course of business, we may share some personal information with Alsanza Medikal Estetik ve İlaç Tic. A.Ş affiliates or third-party companies we hire to perform services or functions on our behalf.

For example, we may:

  • use a service provider to administer certain newsletters or informational mailings you have signed up for and provide access to your email address.
  • use a third-party application or platform to allow us to manage and keep track of our communications with you.
  • use a third-party application or platform like Zoom or Microsoft Teams to conduct live video training events (webcast) to manage and keep track of our communications with you.
  • use our company affiliates to provide services relating to your personal information, e.g., we may store your information on a secure server based at our affiliate’s site in Europe or the United States. For more information on the circumstances in which we may transfer your information to other countries, please see the relevant section below.
  • use a third-party application or platform to conduct surveys, which can include storage of the survey feedback.

In all cases we will only share information necessary, and we will only authorize third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above.

Please note that subject to applicable laws, we may disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that a third party acquires all or part of our business, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.

In addition, we may use and disclose your personal information to third parties if necessary to:

  • enforce this Privacy Statement and the other rules about your use of this website
  • protect our rights or property
  • protect someone’s health, safety, or welfare
  • comply with a law or regulation, court order, or other legal process
  • investigate or take action in cases of suspected fraud or illegal activities

In addition, please keep in mind that certain areas of our website may be interactive, and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those website sections.

DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

In certain cases Alsanza Medikal Estetik ve İlaç Tic. A.Ş may transmit personal information collected on this website to our affiliates or third-party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Statement. In cases where personal information is transmitted from Europe to other Countries, we will ensure that safeguards equivalent to those provided by European data protection laws are in place, for more information on the safeguards implemented by Alsanza Medikal Estetik ve İlaç Tic. A.Ş please contact dataprivacy@Alsanza.com.

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only keep your personal information for as long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Statement. For example, if you tell us that you no longer wish to receive a newsletter from us, we will immediately delete your email address from our mailing list. In case you participate in a program via our website, we will delete the personal information provided as part of that program within a reasonable time after its completion (e.g., six months after completion will normally be considered reasonable unless we have lawful grounds to retain some of the information for longer (e.g., if necessary for validation or to comply with recordkeeping obligations)).

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

This Privacy Statement was created on xx June 2021. We may change this Privacy Statement at any time and for any reason. If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this Privacy Statement each time you visit the website. You can view the previous version of our Privacy Statement here.

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

This website may contain links to other websites. Some of those websites may be operated by Alsanza Medikal Estetik ve İlaç Tic. A.Ş and its affiliates, and some may be operated by third parties. This Privacy Statement does not apply to other websites, even Alsanza Medikal Estetik ve İlaç Tic. A.Ş websites. Therefore whenever you leave this website we recommend you review the privacy practices that apply to information you provide on other websites. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. We are not responsible for websites operated by third parties or your business dealings with them.

ARE THERE SPECIAL RULES ABOUT CHILDREN’S PRIVACY?

We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child’s name or e-mail address) from children under 16 without the consent of someone holding parental responsibility. If you think that we have otherwise collected personal information from someone under the age of 16, please get in touch with us.

WHAT ABOUT WEBSITE SECURITY?

Security is very important to us. We also understand that security is important to you. We use industry-standard measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, no website or email transmission is 100% secure, and we encourage you to therefore take special care in deciding what information you send or request via email, and take appropriate precautions such as keeping any usernames and passwords you use confidential.

YOUR RIGHTS

At any time, you may exercise your right to access, rectify, and, as the case may be, erase any personal information relating to you or restrict the processing of your personal information in compliance with applicable laws.

You also have the right at any time to object, based on your particular situation, to any use or processing of your personal information, which we have based on our legitimate interests.

In case we are processing your personal information in an automated manner as part of a service to you or based on your consent, then you also have the right to request a copy of your information in a structured, commonly used, and machine-readable format (known as the right to “data portability”).

Such requests can be sent to dataprivacy@Alsanza.com or in writing to

Alsanza Medikal Estetik ve İlaç Tic. A.Ş
Esentepe Mah. Kırgülü Sok. Metrocity İş Merkezi D. Blok No:4 İç Kapı No: 27 Şişli /İstanbul
Phone: ……………
E-Mail: info@alsanza.com

Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can comply with your request.

If we have based our collection or use of your personal information on your consent, then you also have the right to withdraw your consent at any time in the same way as it was given or by sending a request in the above manner.

You may also at any time, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and request to no longer receive any promotional material as described above.

Our Data Protection Officer may be contacted by email at dataprivacy@Alsanza.com

HOW TO CONTACT ALSANZA MEDİKAL ESTETİK VE İLAÇ TİC. A.Ş

If you have questions or comments about this Privacy Statement, please Contact Us through our website or via the contact details listed in the Your Rights section above.

We will occasionally update this privacy notice to reflect changes in our practices and services. When we post changes to this privacy notice, we will revise the “last updated” date at the top of this privacy notice. If we make any material changes in the way we collect, use, and share personal data, we will notify you by prominently posting notice of the changes on the website. We recommend that you check this page from time to time to inform yourself of any changes in this privacy notice.