Company / Privacy Policy
In accordance with the Personal Data Protection (KVKK) Law in Turkiye and the General Data Protection Regulation (GDPR) in EU and our company's information security policy, we adopt the following principles and act in line with these principles in our activities;
- Our brands T”FLL Pharma, Thinking Future Long Life, Custom Supplements and We Can’t Stop Thinking About the Future” are protected by trademark registration.
- We sign a confidentiality and competition agreement with all our staff.
- We take measures to protect the confidentiality of our own and our customers' information against unauthorized disclosures.
- We provide authorizations so that access to information is provided only to authorized persons, taking into account the business justification.
- We protect the integrity of information against unauthorized changes.
- We meet all relevant legal and regulatory requirements as well as contractual requirements.
All information provided on our website belongs to our TFLL Pharma company and cannot replace consulting a physician or pharmacist. If you have any disease, consult a physician or pharmacist for more information.
Our company may collect personal data for various purposes. Below, it is stated how and in what way the personal data collected is collected, and how and in what way this data is processed and protected.
Personal Data Protection, Storage and Destruction Policy and Information Text
TFLL Pharma İlaç LTD. Şti. (“Company”), we are sensitive about the protection and processing of personal data and the processing, protection and transfer of data in accordance with the Personal Data Protection Law No. 6698 (“Law”). The Personal Data Protection Policy and Information Text (“Information Text”), which we have created due to the fact that the www.tfllpharma.com website (“Website”), which is operated by the Company and belongs to the Company, is operated by us as the data controller; includes our declarations and explanations regarding the processed personal data, the purpose of data processing, data categories, the method and legal reason for collecting the data, to whom and for what purposes it can be transferred, our information as the data controller, the data processing period and your rights regarding your data.
1. DEFINITIONS AND ABBREVIATIONS:
I. Explicit Consent: Refers to consent based on information and expressed with free will regarding a specific subject.
II. Anonymization: Refers to rendering personal data in a way that it cannot be associated with an identified or identifiable natural person, even when matched with other data.
III. Relevant Person/Data Owner: Refers to the natural person whose personal data is processed.
IV. Law: Law No. 6698 on the Protection of Personal Data, published in the Official Gazette No. 29677, dated April 7, 2016
V. Law No. 6698 on the Protection of Personal Data (“Law”) was adopted on March 24, 2016 and published in the Official Gazette No. 29677, dated April 7, 2016. Some articles of the “Law” entered into force on October 7, 2016.
VI. Personal Data: It refers to any information related to an identified or identifiable real person.
VII. Special Data: It includes data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures of individuals, as well as biometric and genetic data.
VIII. Processing of Personal Data: It refers to any operation performed on personal data, such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing its use, through fully or partially automatic means or non-automatic means provided that it is part of any data recording system. Any transaction performed on data within the scope of the “Law” is considered as “processing of personal data” and data can only be disclosed / transferred to third parties, classified and processed in cases permitted by the “Law”.
IX. Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.
X. Data Processor: The natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.
XI. Data Recording System: The recording system in which personal data is structured and processed according to certain criteria.
XII. Application Form: The form containing the application to be made by the data owner to exercise his/her rights within the framework of the relevant legislation.
XIII. Policy: Personal Data Protection and Privacy Policy (“Policy”)
XIV. Destruction: Deletion, destruction or anonymization of personal data.
XV. Recording Medium: Any personal data processed by fully or partially automatic means or non-automatic means provided that it is part of any data recording system. environment.
2. GENERAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
I. Compliance with the law and rules of honesty: All personal data processed by the Company are processed in accordance with the law, primarily the Constitution of the Republic of Turkey and the KVKK, without being contrary to all legislation and rules of honesty.
II. Being accurate and up-to-date when necessary: The Company attaches importance to the accuracy of the personal data it processes, not containing false information, and to updating personal data in case of a change in personal data and notification of such changes.
III. Being processed for specific, clear and legitimate purposes: The Company processes personal data for clear and clearly defined legitimate purposes. It does not process data other than these purposes.
IV. Being connected, limited and proportionate to the purpose for which they are processed: Personal data processed by the Company are used in accordance with the KVKK and other legislation, limited to the purpose for which they are processed and to the extent required by the service.
V. Being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed: Personal data processed by the Company are stored for the period required for the purpose for which they are processed in the relevant legislation.
3. CONDITIONS FOR PROCESSING PERSONAL DATA
I. Personal data processed by the Company are processed in accordance with the conditions determined under the KVKK. The conditions for processing personal data are listed in Article 5 of the KVKK, and according to this, personal data can be processed if at least one of the following conditions is present:
II. The existence of the explicit consent of the relevant person,
III. It is clearly provided for in the laws,
IV. It is necessary to process personal data of the parties to a contract, provided that it is directly related to the establishment or performance of a contract,
V. It is necessary for the protection of the life or physical integrity of the person who is unable to express his consent due to a de facto impossibility or whose consent is not recognized as legally valid, or of another person,
VI. Within the scope of the Law No. 6563 on the Regulation of Electronic Commerce, the Law No. 6502 on the Protection of Consumers and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce published in the Official Gazette No. 29457 dated 26.08.2015, which was prepared based on these regulations, the Distance Contracts Regulation published in the Official Gazette No. 29188 dated 27.11.2014 and other relevant legislation, to record the identity, address and other necessary information to determine the information of the transaction owner,
VII. To organize all records and documents that will form the basis of payment systems, electronic contracts or paper-based transactions that are mandatory in the field of Banking and Electronic Payment; to comply with the information storage, reporting and information obligations stipulated by the legislation and other authorities,
VIII. To provide information to prosecutors, courts and relevant public officials upon request and in cases of legal disputes related to public security,
IX. It is mandatory for the data controller to fulfill its legal obligation,
X. It is made public by the relevant person,
XI. Data processing is mandatory for the establishment, exercise or protection of a right,
XII. Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person,
XIII. The conditions for processing personal data, i.e. cases of compliance with the law, are specified in the Law by enumeration and these conditions cannot be expanded.
4. COLLECTED PERSONAL DATA
Your personal data written below may be collected within the scope of the Company's business and activities:
I. In accordance with our quality policy, the conversations you have with our line at +90 850 377 77 01 are recorded to measure customer satisfaction.
II. Contact Information ("Contact Information"): Address information, e-mail address, contact address, registered electronic mail address (KEP), telephone number, fax number, work area social media account,
III. Identity Information (“Identity Information”): Name-surname, TR identity number,
IV. In order to quickly resolve any problems or disputes that may arise regarding the identification of system-related problems, our company records and uses the IP address of visitors. IP addresses can also be used to identify users in a general way and to collect comprehensive demographic information. Our company undertakes to keep confidential information strictly private and confidential, to consider this as a confidentiality obligation, and to take all necessary measures and show due diligence to ensure and maintain confidentiality, to prevent all or any part of the confidential information from entering the public domain or from being used unauthorized or disclosed to a third party.
V. The Company may obtain information about users visiting our website and their use of the website by using a technical communication file (Cookie). The technical communication files in question are small text files that a website sends to the user's browser to be stored in the main memory. The technical communication file facilitates the use of the Internet by storing the status and preferences about the site.
The technical communication file helps to obtain statistical information about how many people visit the site, for what purpose and how many times a person visits the site, and how long they stay on the site, and to dynamically generate advertisements and content from user pages specially designed for users. The technical communication file is not designed to receive data or any other personal information from the main memory or your e-mail. Most browsers are initially designed to accept the technical communication file, but users can change the settings so that the technical communication file does not arrive or a warning is given when the technical communication file is sent. VI. Preferences on pages logged in using the user name and password, IP records of transactions performed, cookie data collected by the browser and data containing browsing time and details, location data, internet access logs, entry and exit logs, page views
5. PERSONAL DATA OWNERS:
I. Visitor: Persons who visit the Website, persons who physically visit the Company and fill out the “Visitor Form”, persons who participate in seminars and events organized by the Company or who visit the Company stand at congresses attended by the Company and share their personal data with the interview form.
II. Talent/Talent Candidate: Real persons who have applied to join the Company or have opened their CV and related information to the Company’s review. In accordance with Article 4/2 ç of the KVKK, “data must be related, limited and proportionate to the purpose for which they are processed”, the personal information of candidates who apply to our company from job search portals and whose applications are printed, downloaded and shared with third parties are destroyed and not stored after the recruitment process is completed. The records of candidates who withdraw their applications during the recruitment process are also destroyed and not stored in accordance with the same article.
III. Customer: Person who purchases products or services from the Company.
IV. According to our quality policy, the conversations you have with our +90 850 377 77 01 line are recorded to measure customer satisfaction.
V. Company Shareholders: Real persons who are shareholders of the Company.
VI. Company Officials: Company board members and other authorized real persons.
VII. Employees, Shareholders and Authorities of Cooperating Institutions/Customers: Real persons who work for institutions/companies (such as business partners, suppliers, but not limited to these) and Customers with whom the Company has any kind of business relationship, including shareholders and authorities of these institutions.
6. COLLECTION METHOD AND LEGAL REASONS OF PERSONAL DATA
Your personal data will be collected physically and/or electronically through the website, mobile application, marketplaces, user agreement, written forms and declarations and e-mail, and may be stored for the period required for the purpose for which they are processed in the KVKK and relevant legislation. You can review the Storage and Destruction Periods within the scope of the periods for which your personal data will be stored in Article 13.
Your personal data may be collected, processed and transferred by the Company in accordance with the basic principles stipulated by the KVKK in line with the realization of the purposes explained above, and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK, for the purposes specified in this Disclosure Text.
In this context; your personal data may be collected, processed and transferred within the scope of Article 5 of the KVKK, based on the legal grounds that (i) it is mandatory for the data controller to fulfill its legal obligation, (ii) the processing of personal data belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or execution of a contract, (iii) the processing of data is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person, or (iv) your explicit consent.
7. PURPOSES OF PROCESSING AND USE OF PERSONAL DATA
The Company processes personal data within the framework permitted by the Law and for the purposes and reasons listed below.
o Conducting Information Security Processes: Measures taken for the safe use of our Site,
o Fulfilling the Requirements of User Agreements: Evaluating and matching applicants to the Site and conducting the processes in case of initiating usership on the Platform,
o Conducting Activities in Accordance with the Legislation and Fulfilling our legal obligations regarding the operation of the Site, fulfilling the requirements of tax obligations,
o Conducting Finance and Accounting Affairs,
o Conducting / Supervising Business Activities,
o Conducting User Relations Management Processes,
o Conducting Activities Aimed at User Satisfaction,
o Conducting Marketing Analysis Studies,
o Monitoring Requests / Complaints,
o Providing Information to Authorized Persons, Institutions and Organizations,
o Monitoring the Security of Data Controller Operations,
o Processing of Personal Data Being Necessary for Performance and Data Processing Being Mandatory for the Establishment, Use or Protection of a Right,
o Becoming a Party to a Contract,
o Communication Activities Execution
o Execution of Storage and Archive Activities
o Informing the Public and Users and Providing Additional Benefits to Users
o Data Processing is Mandatory for the Legitimate Interests of the Company, Provided that Fundamental Rights and Freedoms are Not Harmed
o Persons and organizations related to the services provided such as suppliers, cargo companies, including the Company's e-commerce infrastructure provider, program partner organizations that we cooperate with, domestic / international organizations and other 3rd parties from whom we receive services in order to carry out our activities and/or as Data Processors.
Accordingly, the Company processes your personal data within the framework of the Website Terms of Use, which you have approved by accepting our general terms of use when you registered on the site.
If you have entered your personal information to benefit from the Company's services, we will use your data to provide you with access to these services and to monitor access to the services. The consent you have given for the use of your personal data on the Website will also be valid for the Website managed by the Company for the purposes and scope specified in this Disclosure Text on the Protection and Processing of Personal Data, and the Company will be able to use your personal data on the website.
Your personal data may be processed in the presence of your explicit consent to be obtained in accordance with Articles 5 and 8 of the KVKK for the purposes listed above, in order to fulfill the requirements arising from the contract and the law.
Legitimate interest: In addition, we process some of your data for management purposes on the basis of our legitimate interest. In this context, there are requirements for ensuring secure access to the Website, taking precautions against fraud, and accounting.
Explicit consent: Your personal data may be processed in the presence of your explicit consent to be obtained in accordance with Articles 5 and 8 of the KVKK for the purposes listed above, in order to fulfill the requirements arising from the contract and the law. For example, in cases where your profile photo is reused by our services or you have not created an account on the platform but would like to receive information about our commercial offers / newsletter, we process your Personal Data based on your explicit consent.
Legal obligations: Your personal data is processed due to the legal obligations imposed on us in connection with the management of payments made through the platform and, in particular, the fight against terrorism and money laundering.
Other Reasons for Processing Data: Your personal data may also be processed on the grounds that data processing is expressly provided for by law, has been made public by the person concerned, and data processing is mandatory for the establishment, exercise or protection of a right.
Your Sensitive Data: We specifically avoid processing your private data. In this context, in the context of your membership, we strongly recommend that you refrain from providing any personal information that is not directly related to your competencies and especially your special (sensitive) data (race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, biometric and genetic data of the individuals) and that you black out the relevant parts in your CV and documents that you provide in writing and provide them to us.
If you provide your personal data for a purpose other than purchasing products and services, we may use your data in accordance with the purpose you have specified. For example, if you have reached us via e-mail, we may use the data you have provided to respond to you or solve your problem.
The person you have provided to the company or its affiliates or business partners
8. CASES WHERE PERSONAL DATA MAY BE PROCESSED WITHOUT EXPRESS CONSENT
The Company has the right to process general and special data with the explicit consent of the Relevant Person and without explicit consent in the cases stipulated in Articles 5 and 6 of the Law.
Cases where data can be processed without explicit consent:
Explicitly provided for in the laws; It is mandatory for the protection of the life or physical integrity of the person who is unable to give his consent due to actual impossibility or whose consent is not legally valid or of another person; It is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract; It is mandatory for the data controller to fulfill its legal obligation; It is made public by the relevant person himself; Data processing is mandatory for the establishment, exercise or protection of a right; Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.
For example, contact and identification information such as name-surname, telephone, e-mail, etc., company information, answers to survey questions, entries made to forms, documents uploaded to the system, information regarding your educational status and CV, work history and bank account information/credit card payment records are included in the scope. The Site will not allow this data to be transferred to the Company records unless you, as the user, read and approve the Disclosure Text and Cookie Policy regarding the Protection, processing and transfer of Personal Data.
9. YOUR PERSONAL DATA THAT MAY BE TRANSFERRED
Your personal data specified below may be transferred within the scope of the Company's business and activities.
a. Contact Information: Your contact information such as address information, e-mail address, contact address, registered electronic mail address (KEP), telephone number, fax number, etc. may be transferred to the business partner, sponsor, supplier, real person or legal entity from which service is purchased, and its officials and employees, if necessary, in order to ensure communication between users, to the Company's authorities, employees and officers, and in the event that service is received for the fulfillment of these transactions.
b. Identity Information: Name-Surname data may be shared with Company employees, real or legal persons from whom services are received, and their employees and officers within the scope of communication between Talents and Customers.
c. Transaction Information: E-mail information sent via the Company website, call center records, website navigation and click information, internet access logs, login and logout logs, cookie usage information, internet protocol (IP) address, device ID, web page views and statistics regarding mobile and other digital applications, in order to ensure website security and efficiency, Company employees, officers, shareholders and third parties from whom services are received for these purposes, and their employees and officers; and also, if requested for reasons arising from the Law, this data may be shared with authorized public institutions and organizations.
d. Survey/Question Answers: Periodic survey information and answers to surveys conducted by the Company via telephone, e-mail and/or within the Platform, and answers to surveys conducted by real and legal persons with whom the Company cooperates may be shared with the public through the Company's Talents and Customers, real and legal persons with whom the Company cooperates, and employees and officers, and the Company's social media accounts, digital communication platforms, e-bulletins, and websites.
e. Visual Data: Photos shared by data owners with the Company, photos taken at seminars, congresses and events with the explicit consent of the data owner, may be shared with the public through the Company's social media accounts, digital communication platforms, e-bulletins, and websites.
f. Personal Information: Candidates or employees applying for a job at the Company; Educational status, certificate and diploma information, foreign language information, CV, courses attended, work experiences, references, performance information, work preferences, working hours, education and skills, information on which training on which date, e-mail, signed participation form, target achievement status, payment preferences and information may be shared with Customers for the purposes of matching between Talent and Customers and realizing relevant projects.
10. PURPOSES OF TRANSFERRING YOUR PERSONAL DATA
As explained in detail above, personal data processed by the Company in accordance with Articles 5 and 6 of the law and limited to the purposes mentioned in this disclosure text;
o It may be transferred for the purposes of carrying out and executing business activities and ensuring users register on the site, establishing communication between Talents and Customers, providing communication with Talents and Customers, being required within the scope of legislation or fulfilling activities, fulfilling the requirements within the scope of analyses and efficiency regarding user opinions and expectations.
o In the event of a commercial enterprise transfer, if the Company is transferred to another company through a merger or transfer, establishing a partnership or merging its business with another company, personal data may also be transferred as an asset of the Company. In this case, the data of the persons who apply for membership and become members in the system may be viewed by the relevant Company as a part of the system.
o It may be transferred to registration companies and representatives that we have authorized and that operate on behalf of our Company,
o Regulatory and supervisory institutions and public institutions or organizations that are explicitly authorized to request personal data by law,
o Business partnerships, supplier and contractor companies, banks, credit risk and financial institutions and other real or legal persons within the scope of the specified purposes,
o Tax and similar consultants, mandatory persons related to legal follow-up processes, public institutions and organizations and third parties from whom we receive consultancy, including auditors, and, without limitation, business partners, third parties from whom we receive service, authorized persons and organizations for the purposes specified above.
o Your personal data is not transferred abroad by the Company in any way, and if necessary, your explicit consent for the transfer will be obtained separately.
o Your personal data collected by any of the methods listed above, to be processed in Turkey or to be processed and stored outside Turkey, may also be transferred to service intermediaries located abroad (to countries accredited by the Personal Data Board and with sufficient protection in terms of the protection of personal data) in accordance with the contractual purposes, provided that they remain within the scope of the KVKK.
o Your personal data may be transferred in the presence of your explicit consent, to be obtained in accordance with Article 8 of the KVKK, for the purposes listed above, including the fulfillment of the requirements arising from the Individual and Customer User agreements and other purposes arising from the law.
11. CASES WHERE YOUR PERSONAL DATA MAY BE TRANSFERRED WITHOUT REQUESTING EXPRESS CONSENT
Confidential information and personal information requested from our company by legal authorities in an official letter are shared with legal authorities.
Your personal data is clearly provided for in the Laws in accordance with the second paragraph of Article 8 of the KVKK; If it is necessary for the protection of the life or physical integrity of the person who is unable to express his/her consent due to a de facto impossibility or whose consent is not recognized as legally valid; If it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or execution of a contract; If it is necessary for the data controller to fulfill its legal obligation; If it is made public by the relevant person; If data processing is necessary for the establishment, exercise or protection of a right; If data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person,
Personal data other than health and sexual life listed in the first paragraph of Article 6 of the KVKK, regulated in the third paragraph of Article 6, may be transferred without the explicit consent of the relevant person in the cases foreseen by the laws; Personal data related to health and sexual life may only be transferred without the explicit consent of the relevant person in accordance with the obligation of confidentiality for the purposes of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing. 12. TRANSFERRED PERSONS AND TRANSFER METHODS
We share your personal data with legally authorized public and private institutions and organizations, Company officials, employees, officers and shareholders, domestic business partners, Customers and users, suppliers and sponsors, group companies, affiliates and subsidiaries, independent audit companies, real and legal persons within the limits required by the procurement of services for the purpose of performing the activities, and with the relevant real and legal persons through secure electronic or other communication channels according to the characteristics of the data and activity, within the framework of the purposes, requirements and limits specified in the legislation described above.
Within the scope of the Company's activities, electronic communication
13. STORAGE AND DESTRUCTION OF PERSONAL DATA
The Company will store personal data kept in accordance with all relevant legislation, primarily the KVKK, for the purpose of carrying out its commercial activities and for the period required by the processing purposes specified in this disclosure text, and confidentially, taking into account the statute of limitations as required by Article 12 of the KVKK and other legislation; it will not be shared with third parties in any way except for legal obligations and the regulations specified in this document.
The Company will store the personal data it obtains within the framework of the conditions specified in this Disclosure Text and the Website Terms of Use, so that Users can benefit from the site services in the best way possible, and for the period necessary for the purpose for which they are processed in order to fulfill the obligations arising from the nature of these Agreements.
In addition, the Company may store personal data for the duration of the limitation periods determined in accordance with the relevant legislation and limited to the purpose of establishing the necessary defenses within the scope of the dispute in the event of any dispute that may arise from the Website Terms of Use and the Individual/Corporate User Agreement or the Information Text and Cookie Policy.
Within the framework of the general principles regarding the processing of personal data, the Company bases all administrative and technical protection measures sought by the legislation in all its transactions and activities in order to ensure the preservation of personal data within the framework of the purposes specified in this Policy and periodically renews them.
In the event that the purpose of processing personal data is eliminated, the data will be deleted, destroyed or anonymized by our institution ex officio or upon the request of the relevant person. In the event that the data is deleted as we have stated, the data will not be reused or restored in any way.
In the event that the periods or services expire, the data in question is deleted or destroyed in accordance with the Law.
Your personal data will be kept confidentially in the database and systems of the Company in accordance with Article 12 of the KVKK; it will not be shared with third parties in any way except for legal obligations and the regulations specified in this document. The Company is obliged to prevent the unlawful processing of personal data in accordance with Article 12 of the KVKK, to prevent unauthorized persons from accessing the systems and databases where your personal data is stored, to take software measures such as access management and physical security measures. In the event that it is learned that personal data has been obtained by others through illegal means, the situation will be reported immediately, in accordance with the legal regulation and in writing to the Personal Data Protection Board.
14. YOUR PERSONAL DATA OBTAINED BEFORE THE KVKK ENTERS INTO EFFECT
Your personal data obtained in accordance with the law through membership, electronic message permission, product/service purchase and other means before the effective date of the KVKK, April 7, 2016, is also processed and stored in accordance with the terms and conditions set forth in this document.
15. MEASURES TAKEN REGARDING THE PROTECTION OF PERSONAL DATA
The Company undertakes to securely protect your personal data.
The Company; under the conditions set forth in the Law and this Disclosure Text; undertakes to take all necessary technical and administrative measures and to have all necessary inspections carried out in a timely and complete manner in order to ensure the preservation of personal data, to ensure that personal data is not processed unlawfully, to ensure that personal data is not accessed unlawfully and to prevent data leaks.
Your personal data will be processed by taking all necessary information security measures, provided that it is not used for purposes other than those notified to you and within the scope, and will be stored and processed for the legal retention period or, if no such period is foreseen, for the period required by the purpose of processing. When this period expires, your personal data will be removed from the Company's data flows by means of deletion, destruction or anonymization.
16. YOUR RIGHTS AS A RELATED PERSON
According to Article 4 of the KVKK, the "Company" is obliged to keep your personal data accurate and up-to-date. In this context, in order for the "Company" to fulfill its obligations arising from the current legislation, our Customers must share their accurate and up-to-date data or update it via the website / mobile application.
Article 11 of the KVKK numbered 6698 entered into force on October 07, 2016 and, in accordance with the relevant article, the rights of the Personal Data Owner after this date are as follows: The Personal Data Owner may apply to the "Company Data Controller" and request; You can always contact us to get information about the following issues within the scope of the law;
a) Learning whether personal data has been processed,
b) Requesting information about personal data if it has been processed,
c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
ç) To know the third parties to whom personal data is transferred, domestically or abroad,
d) To request correction of personal data if it is processed incompletely or incorrectly,
e) To request deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
f) To request notification of the transactions made pursuant to subparagraphs (d) and (e) above to third parties to whom it is transferred,
g) To object to the emergence of a result against you due to analysis exclusively by automated systems,
ğ) To request compensation for damages in the event that you suffer damages due to processing in violation of the law.
You can always change your communication preferences and exercise your right to be forgotten.
Channels through which you can reach us for your requests:
As the data controller that will process your personal data, you can submit your requests within the scope of Article 11 of the KVKK, which regulates the rights of the relevant person, under the heading “The Company is the Data Controller within the scope of the KVKK. The Data Controller Representative to be appointed by the Company will be announced in the Data Controllers Registry and on the internet address where this document is located when the legal infrastructure is provided. Personal Data Owners can send their questions, opinions or requests to any of the following communication channels, via a notary or other methods determined by the Personal Data Protection Board. Your request will be responded to as soon as possible and within thirty (30) days at the latest in accordance with the law. However, if the transaction requires an additional cost, the Company reserves the right to charge a fee in accordance with the Law based on the tariff determined by the Personal Data Protection Board.
Company Information in Türkiye
Company Title
TFLL İlaç, Gıda Takviyeleri ve Kozmetik Ürünleri Sanayi Dış Ticaret Ltd. Şti.
Address
Barbaros Mah. Kardelen Sok. Palladium Tower No:2/10-33 Ataşehir İSTANBUL
Email
info@tfllpharma.com
Phone
+90 850 377 77 01
Company Information in Belgium
Company Title
TFLL Pharma Beigium BV
Address
Life Sciences Incubator BioVille Agoralaan Building Abis 3590
Diepenbeek / Belgium
Email
info@tfllpharma.com
Phone
+32 11 286 900
17. ENFORCEMENT
The effective date of this Policy is 02.09.2024. The Company reserves the right to make changes to the Policy in line with legal regulations. You can access the current version of the Policy on our website. If the provisions of the Privacy Policy change, they will come into force on the date they are published on the website.
We recommend that you read this Disclosure Text prepared for you before approving it, and thank you in advance for reading it.
In accordance with the Personal Data Protection (KVKK) Law in Turkiye and the General Data Protection Regulation (GDPR) in EU and our company's information security policy, we adopt the following principles and act in line with these principles in our activities;
- Our brands T”FLL Pharma, Thinking Future Long Life, Custom Supplements and We Can’t Stop Thinking About the Future” are protected by trademark registration.
- We sign a confidentiality and competition agreement with all our staff.
- We take measures to protect the confidentiality of our own and our customers' information against unauthorized disclosures.
- We provide authorizations so that access to information is provided only to authorized persons, taking into account the business justification.
- We protect the integrity of information against unauthorized changes.
- We meet all relevant legal and regulatory requirements as well as contractual requirements.
All information provided on our website belongs to our TFLL Pharma company and cannot replace consulting a physician or pharmacist. If you have any disease, consult a physician or pharmacist for more information.
Our company may collect personal data for various purposes. Below, it is stated how and in what way the personal data collected is collected, and how and in what way this data is processed and protected.
Personal Data Protection, Storage and Destruction Policy and Information Text
TFLL Pharma İlaç LTD. Şti. (“Company”), we are sensitive about the protection and processing of personal data and the processing, protection and transfer of data in accordance with the Personal Data Protection Law No. 6698 (“Law”). The Personal Data Protection Policy and Information Text (“Information Text”), which we have created due to the fact that the www.tfllpharma.com website (“Website”), which is operated by the Company and belongs to the Company, is operated by us as the data controller; includes our declarations and explanations regarding the processed personal data, the purpose of data processing, data categories, the method and legal reason for collecting the data, to whom and for what purposes it can be transferred, our information as the data controller, the data processing period and your rights regarding your data.
1. DEFINITIONS AND ABBREVIATIONS:
I. Explicit Consent: Refers to consent based on information and expressed with free will regarding a specific subject.
II. Anonymization: Refers to rendering personal data in a way that it cannot be associated with an identified or identifiable natural person, even when matched with other data.
III. Relevant Person/Data Owner: Refers to the natural person whose personal data is processed.
IV. Law: Law No. 6698 on the Protection of Personal Data, published in the Official Gazette No. 29677, dated April 7, 2016
V. Law No. 6698 on the Protection of Personal Data (“Law”) was adopted on March 24, 2016 and published in the Official Gazette No. 29677, dated April 7, 2016. Some articles of the “Law” entered into force on October 7, 2016.
VI. Personal Data: It refers to any information related to an identified or identifiable real person.
VII. Special Data: It includes data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures of individuals, as well as biometric and genetic data.
VIII. Processing of Personal Data: It refers to any operation performed on personal data, such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing its use, through fully or partially automatic means or non-automatic means provided that it is part of any data recording system. Any transaction performed on data within the scope of the “Law” is considered as “processing of personal data” and data can only be disclosed / transferred to third parties, classified and processed in cases permitted by the “Law”.
IX. Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.
X. Data Processor: The natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.
XI. Data Recording System: The recording system in which personal data is structured and processed according to certain criteria.
XII. Application Form: The form containing the application to be made by the data owner to exercise his/her rights within the framework of the relevant legislation.
XIII. Policy: Personal Data Protection and Privacy Policy (“Policy”)
XIV. Destruction: Deletion, destruction or anonymization of personal data.
XV. Recording Medium: Any personal data processed by fully or partially automatic means or non-automatic means provided that it is part of any data recording system. environment.
2. GENERAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
I. Compliance with the law and rules of honesty: All personal data processed by the Company are processed in accordance with the law, primarily the Constitution of the Republic of Turkey and the KVKK, without being contrary to all legislation and rules of honesty.
II. Being accurate and up-to-date when necessary: The Company attaches importance to the accuracy of the personal data it processes, not containing false information, and to updating personal data in case of a change in personal data and notification of such changes.
III. Being processed for specific, clear and legitimate purposes: The Company processes personal data for clear and clearly defined legitimate purposes. It does not process data other than these purposes.
IV. Being connected, limited and proportionate to the purpose for which they are processed: Personal data processed by the Company are used in accordance with the KVKK and other legislation, limited to the purpose for which they are processed and to the extent required by the service.
V. Being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed: Personal data processed by the Company are stored for the period required for the purpose for which they are processed in the relevant legislation.
3. CONDITIONS FOR PROCESSING PERSONAL DATA
I. Personal data processed by the Company are processed in accordance with the conditions determined under the KVKK. The conditions for processing personal data are listed in Article 5 of the KVKK, and according to this, personal data can be processed if at least one of the following conditions is present:
II. The existence of the explicit consent of the relevant person,
III. It is clearly provided for in the laws,
IV. It is necessary to process personal data of the parties to a contract, provided that it is directly related to the establishment or performance of a contract,
V. It is necessary for the protection of the life or physical integrity of the person who is unable to express his consent due to a de facto impossibility or whose consent is not recognized as legally valid, or of another person,
VI. Within the scope of the Law No. 6563 on the Regulation of Electronic Commerce, the Law No. 6502 on the Protection of Consumers and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce published in the Official Gazette No. 29457 dated 26.08.2015, which was prepared based on these regulations, the Distance Contracts Regulation published in the Official Gazette No. 29188 dated 27.11.2014 and other relevant legislation, to record the identity, address and other necessary information to determine the information of the transaction owner,
VII. To organize all records and documents that will form the basis of payment systems, electronic contracts or paper-based transactions that are mandatory in the field of Banking and Electronic Payment; to comply with the information storage, reporting and information obligations stipulated by the legislation and other authorities,
VIII. To provide information to prosecutors, courts and relevant public officials upon request and in cases of legal disputes related to public security,
IX. It is mandatory for the data controller to fulfill its legal obligation,
X. It is made public by the relevant person,
XI. Data processing is mandatory for the establishment, exercise or protection of a right,
XII. Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person,
XIII. The conditions for processing personal data, i.e. cases of compliance with the law, are specified in the Law by enumeration and these conditions cannot be expanded.
4. COLLECTED PERSONAL DATA
Your personal data written below may be collected within the scope of the Company's business and activities:
I. In accordance with our quality policy, the conversations you have with our line at +90 850 377 77 01 are recorded to measure customer satisfaction.
II. Contact Information ("Contact Information"): Address information, e-mail address, contact address, registered electronic mail address (KEP), telephone number, fax number, work area social media account,
III. Identity Information (“Identity Information”): Name-surname, TR identity number,
IV. In order to quickly resolve any problems or disputes that may arise regarding the identification of system-related problems, our company records and uses the IP address of visitors. IP addresses can also be used to identify users in a general way and to collect comprehensive demographic information. Our company undertakes to keep confidential information strictly private and confidential, to consider this as a confidentiality obligation, and to take all necessary measures and show due diligence to ensure and maintain confidentiality, to prevent all or any part of the confidential information from entering the public domain or from being used unauthorized or disclosed to a third party.
V. The Company may obtain information about users visiting our website and their use of the website by using a technical communication file (Cookie). The technical communication files in question are small text files that a website sends to the user's browser to be stored in the main memory. The technical communication file facilitates the use of the Internet by storing the status and preferences about the site.
The technical communication file helps to obtain statistical information about how many people visit the site, for what purpose and how many times a person visits the site, and how long they stay on the site, and to dynamically generate advertisements and content from user pages specially designed for users. The technical communication file is not designed to receive data or any other personal information from the main memory or your e-mail. Most browsers are initially designed to accept the technical communication file, but users can change the settings so that the technical communication file does not arrive or a warning is given when the technical communication file is sent. VI. Preferences on pages logged in using the user name and password, IP records of transactions performed, cookie data collected by the browser and data containing browsing time and details, location data, internet access logs, entry and exit logs, page views
5. PERSONAL DATA OWNERS:
I. Visitor: Persons who visit the Website, persons who physically visit the Company and fill out the “Visitor Form”, persons who participate in seminars and events organized by the Company or who visit the Company stand at congresses attended by the Company and share their personal data with the interview form.
II. Talent/Talent Candidate: Real persons who have applied to join the Company or have opened their CV and related information to the Company’s review. In accordance with Article 4/2 ç of the KVKK, “data must be related, limited and proportionate to the purpose for which they are processed”, the personal information of candidates who apply to our company from job search portals and whose applications are printed, downloaded and shared with third parties are destroyed and not stored after the recruitment process is completed. The records of candidates who withdraw their applications during the recruitment process are also destroyed and not stored in accordance with the same article.
III. Customer: Person who purchases products or services from the Company.
IV. According to our quality policy, the conversations you have with our +90 850 377 77 01 line are recorded to measure customer satisfaction.
V. Company Shareholders: Real persons who are shareholders of the Company.
VI. Company Officials: Company board members and other authorized real persons.
VII. Employees, Shareholders and Authorities of Cooperating Institutions/Customers: Real persons who work for institutions/companies (such as business partners, suppliers, but not limited to these) and Customers with whom the Company has any kind of business relationship, including shareholders and authorities of these institutions.
6. COLLECTION METHOD AND LEGAL REASONS OF PERSONAL DATA
Your personal data will be collected physically and/or electronically through the website, mobile application, marketplaces, user agreement, written forms and declarations and e-mail, and may be stored for the period required for the purpose for which they are processed in the KVKK and relevant legislation. You can review the Storage and Destruction Periods within the scope of the periods for which your personal data will be stored in Article 13.
Your personal data may be collected, processed and transferred by the Company in accordance with the basic principles stipulated by the KVKK in line with the realization of the purposes explained above, and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK, for the purposes specified in this Disclosure Text.
In this context; your personal data may be collected, processed and transferred within the scope of Article 5 of the KVKK, based on the legal grounds that (i) it is mandatory for the data controller to fulfill its legal obligation, (ii) the processing of personal data belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or execution of a contract, (iii) the processing of data is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person, or (iv) your explicit consent.
7. PURPOSES OF PROCESSING AND USE OF PERSONAL DATA
The Company processes personal data within the framework permitted by the Law and for the purposes and reasons listed below.
o Conducting Information Security Processes: Measures taken for the safe use of our Site,
o Fulfilling the Requirements of User Agreements: Evaluating and matching applicants to the Site and conducting the processes in case of initiating usership on the Platform,
o Conducting Activities in Accordance with the Legislation and Fulfilling our legal obligations regarding the operation of the Site, fulfilling the requirements of tax obligations,
o Conducting Finance and Accounting Affairs,
o Conducting / Supervising Business Activities,
o Conducting User Relations Management Processes,
o Conducting Activities Aimed at User Satisfaction,
o Conducting Marketing Analysis Studies,
o Monitoring Requests / Complaints,
o Providing Information to Authorized Persons, Institutions and Organizations,
o Monitoring the Security of Data Controller Operations,
o Processing of Personal Data Being Necessary for Performance and Data Processing Being Mandatory for the Establishment, Use or Protection of a Right,
o Becoming a Party to a Contract,
o Communication Activities Execution
o Execution of Storage and Archive Activities
o Informing the Public and Users and Providing Additional Benefits to Users
o Data Processing is Mandatory for the Legitimate Interests of the Company, Provided that Fundamental Rights and Freedoms are Not Harmed
o Persons and organizations related to the services provided such as suppliers, cargo companies, including the Company's e-commerce infrastructure provider, program partner organizations that we cooperate with, domestic / international organizations and other 3rd parties from whom we receive services in order to carry out our activities and/or as Data Processors.
Accordingly, the Company processes your personal data within the framework of the Website Terms of Use, which you have approved by accepting our general terms of use when you registered on the site.
If you have entered your personal information to benefit from the Company's services, we will use your data to provide you with access to these services and to monitor access to the services. The consent you have given for the use of your personal data on the Website will also be valid for the Website managed by the Company for the purposes and scope specified in this Disclosure Text on the Protection and Processing of Personal Data, and the Company will be able to use your personal data on the website.
Your personal data may be processed in the presence of your explicit consent to be obtained in accordance with Articles 5 and 8 of the KVKK for the purposes listed above, in order to fulfill the requirements arising from the contract and the law.
Legitimate interest: In addition, we process some of your data for management purposes on the basis of our legitimate interest. In this context, there are requirements for ensuring secure access to the Website, taking precautions against fraud, and accounting.
Explicit consent: Your personal data may be processed in the presence of your explicit consent to be obtained in accordance with Articles 5 and 8 of the KVKK for the purposes listed above, in order to fulfill the requirements arising from the contract and the law. For example, in cases where your profile photo is reused by our services or you have not created an account on the platform but would like to receive information about our commercial offers / newsletter, we process your Personal Data based on your explicit consent.
Legal obligations: Your personal data is processed due to the legal obligations imposed on us in connection with the management of payments made through the platform and, in particular, the fight against terrorism and money laundering.
Other Reasons for Processing Data: Your personal data may also be processed on the grounds that data processing is expressly provided for by law, has been made public by the person concerned, and data processing is mandatory for the establishment, exercise or protection of a right.
Your Sensitive Data: We specifically avoid processing your private data. In this context, in the context of your membership, we strongly recommend that you refrain from providing any personal information that is not directly related to your competencies and especially your special (sensitive) data (race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, biometric and genetic data of the individuals) and that you black out the relevant parts in your CV and documents that you provide in writing and provide them to us.
If you provide your personal data for a purpose other than purchasing products and services, we may use your data in accordance with the purpose you have specified. For example, if you have reached us via e-mail, we may use the data you have provided to respond to you or solve your problem.
The person you have provided to the company or its affiliates or business partners
8. CASES WHERE PERSONAL DATA MAY BE PROCESSED WITHOUT EXPRESS CONSENT
The Company has the right to process general and special data with the explicit consent of the Relevant Person and without explicit consent in the cases stipulated in Articles 5 and 6 of the Law.
Cases where data can be processed without explicit consent:
Explicitly provided for in the laws; It is mandatory for the protection of the life or physical integrity of the person who is unable to give his consent due to actual impossibility or whose consent is not legally valid or of another person; It is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract; It is mandatory for the data controller to fulfill its legal obligation; It is made public by the relevant person himself; Data processing is mandatory for the establishment, exercise or protection of a right; Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.
For example, contact and identification information such as name-surname, telephone, e-mail, etc., company information, answers to survey questions, entries made to forms, documents uploaded to the system, information regarding your educational status and CV, work history and bank account information/credit card payment records are included in the scope. The Site will not allow this data to be transferred to the Company records unless you, as the user, read and approve the Disclosure Text and Cookie Policy regarding the Protection, processing and transfer of Personal Data.
9. YOUR PERSONAL DATA THAT MAY BE TRANSFERRED
Your personal data specified below may be transferred within the scope of the Company's business and activities.
a. Contact Information: Your contact information such as address information, e-mail address, contact address, registered electronic mail address (KEP), telephone number, fax number, etc. may be transferred to the business partner, sponsor, supplier, real person or legal entity from which service is purchased, and its officials and employees, if necessary, in order to ensure communication between users, to the Company's authorities, employees and officers, and in the event that service is received for the fulfillment of these transactions.
b. Identity Information: Name-Surname data may be shared with Company employees, real or legal persons from whom services are received, and their employees and officers within the scope of communication between Talents and Customers.
c. Transaction Information: E-mail information sent via the Company website, call center records, website navigation and click information, internet access logs, login and logout logs, cookie usage information, internet protocol (IP) address, device ID, web page views and statistics regarding mobile and other digital applications, in order to ensure website security and efficiency, Company employees, officers, shareholders and third parties from whom services are received for these purposes, and their employees and officers; and also, if requested for reasons arising from the Law, this data may be shared with authorized public institutions and organizations.
d. Survey/Question Answers: Periodic survey information and answers to surveys conducted by the Company via telephone, e-mail and/or within the Platform, and answers to surveys conducted by real and legal persons with whom the Company cooperates may be shared with the public through the Company's Talents and Customers, real and legal persons with whom the Company cooperates, and employees and officers, and the Company's social media accounts, digital communication platforms, e-bulletins, and websites.
e. Visual Data: Photos shared by data owners with the Company, photos taken at seminars, congresses and events with the explicit consent of the data owner, may be shared with the public through the Company's social media accounts, digital communication platforms, e-bulletins, and websites.
f. Personal Information: Candidates or employees applying for a job at the Company; Educational status, certificate and diploma information, foreign language information, CV, courses attended, work experiences, references, performance information, work preferences, working hours, education and skills, information on which training on which date, e-mail, signed participation form, target achievement status, payment preferences and information may be shared with Customers for the purposes of matching between Talent and Customers and realizing relevant projects.
10. PURPOSES OF TRANSFERRING YOUR PERSONAL DATA
As explained in detail above, personal data processed by the Company in accordance with Articles 5 and 6 of the law and limited to the purposes mentioned in this disclosure text;
o It may be transferred for the purposes of carrying out and executing business activities and ensuring users register on the site, establishing communication between Talents and Customers, providing communication with Talents and Customers, being required within the scope of legislation or fulfilling activities, fulfilling the requirements within the scope of analyses and efficiency regarding user opinions and expectations.
o In the event of a commercial enterprise transfer, if the Company is transferred to another company through a merger or transfer, establishing a partnership or merging its business with another company, personal data may also be transferred as an asset of the Company. In this case, the data of the persons who apply for membership and become members in the system may be viewed by the relevant Company as a part of the system.
o It may be transferred to registration companies and representatives that we have authorized and that operate on behalf of our Company,
o Regulatory and supervisory institutions and public institutions or organizations that are explicitly authorized to request personal data by law,
o Business partnerships, supplier and contractor companies, banks, credit risk and financial institutions and other real or legal persons within the scope of the specified purposes,
o Tax and similar consultants, mandatory persons related to legal follow-up processes, public institutions and organizations and third parties from whom we receive consultancy, including auditors, and, without limitation, business partners, third parties from whom we receive service, authorized persons and organizations for the purposes specified above.
o Your personal data is not transferred abroad by the Company in any way, and if necessary, your explicit consent for the transfer will be obtained separately.
o Your personal data collected by any of the methods listed above, to be processed in Turkey or to be processed and stored outside Turkey, may also be transferred to service intermediaries located abroad (to countries accredited by the Personal Data Board and with sufficient protection in terms of the protection of personal data) in accordance with the contractual purposes, provided that they remain within the scope of the KVKK.
o Your personal data may be transferred in the presence of your explicit consent, to be obtained in accordance with Article 8 of the KVKK, for the purposes listed above, including the fulfillment of the requirements arising from the Individual and Customer User agreements and other purposes arising from the law.
11. CASES WHERE YOUR PERSONAL DATA MAY BE TRANSFERRED WITHOUT REQUESTING EXPRESS CONSENT
Confidential information and personal information requested from our company by legal authorities in an official letter are shared with legal authorities.
Your personal data is clearly provided for in the Laws in accordance with the second paragraph of Article 8 of the KVKK; If it is necessary for the protection of the life or physical integrity of the person who is unable to express his/her consent due to a de facto impossibility or whose consent is not recognized as legally valid; If it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or execution of a contract; If it is necessary for the data controller to fulfill its legal obligation; If it is made public by the relevant person; If data processing is necessary for the establishment, exercise or protection of a right; If data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person,
Personal data other than health and sexual life listed in the first paragraph of Article 6 of the KVKK, regulated in the third paragraph of Article 6, may be transferred without the explicit consent of the relevant person in the cases foreseen by the laws; Personal data related to health and sexual life may only be transferred without the explicit consent of the relevant person in accordance with the obligation of confidentiality for the purposes of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing. 12. TRANSFERRED PERSONS AND TRANSFER METHODS
We share your personal data with legally authorized public and private institutions and organizations, Company officials, employees, officers and shareholders, domestic business partners, Customers and users, suppliers and sponsors, group companies, affiliates and subsidiaries, independent audit companies, real and legal persons within the limits required by the procurement of services for the purpose of performing the activities, and with the relevant real and legal persons through secure electronic or other communication channels according to the characteristics of the data and activity, within the framework of the purposes, requirements and limits specified in the legislation described above.
Within the scope of the Company's activities, electronic communication
13. STORAGE AND DESTRUCTION OF PERSONAL DATA
The Company will store personal data kept in accordance with all relevant legislation, primarily the KVKK, for the purpose of carrying out its commercial activities and for the period required by the processing purposes specified in this disclosure text, and confidentially, taking into account the statute of limitations as required by Article 12 of the KVKK and other legislation; it will not be shared with third parties in any way except for legal obligations and the regulations specified in this document.
The Company will store the personal data it obtains within the framework of the conditions specified in this Disclosure Text and the Website Terms of Use, so that Users can benefit from the site services in the best way possible, and for the period necessary for the purpose for which they are processed in order to fulfill the obligations arising from the nature of these Agreements.
In addition, the Company may store personal data for the duration of the limitation periods determined in accordance with the relevant legislation and limited to the purpose of establishing the necessary defenses within the scope of the dispute in the event of any dispute that may arise from the Website Terms of Use and the Individual/Corporate User Agreement or the Information Text and Cookie Policy.
Within the framework of the general principles regarding the processing of personal data, the Company bases all administrative and technical protection measures sought by the legislation in all its transactions and activities in order to ensure the preservation of personal data within the framework of the purposes specified in this Policy and periodically renews them.
In the event that the purpose of processing personal data is eliminated, the data will be deleted, destroyed or anonymized by our institution ex officio or upon the request of the relevant person. In the event that the data is deleted as we have stated, the data will not be reused or restored in any way.
In the event that the periods or services expire, the data in question is deleted or destroyed in accordance with the Law.
Your personal data will be kept confidentially in the database and systems of the Company in accordance with Article 12 of the KVKK; it will not be shared with third parties in any way except for legal obligations and the regulations specified in this document. The Company is obliged to prevent the unlawful processing of personal data in accordance with Article 12 of the KVKK, to prevent unauthorized persons from accessing the systems and databases where your personal data is stored, to take software measures such as access management and physical security measures. In the event that it is learned that personal data has been obtained by others through illegal means, the situation will be reported immediately, in accordance with the legal regulation and in writing to the Personal Data Protection Board.
14. YOUR PERSONAL DATA OBTAINED BEFORE THE KVKK ENTERS INTO EFFECT
Your personal data obtained in accordance with the law through membership, electronic message permission, product/service purchase and other means before the effective date of the KVKK, April 7, 2016, is also processed and stored in accordance with the terms and conditions set forth in this document.
15. MEASURES TAKEN REGARDING THE PROTECTION OF PERSONAL DATA
The Company undertakes to securely protect your personal data.
The Company; under the conditions set forth in the Law and this Disclosure Text; undertakes to take all necessary technical and administrative measures and to have all necessary inspections carried out in a timely and complete manner in order to ensure the preservation of personal data, to ensure that personal data is not processed unlawfully, to ensure that personal data is not accessed unlawfully and to prevent data leaks.
Your personal data will be processed by taking all necessary information security measures, provided that it is not used for purposes other than those notified to you and within the scope, and will be stored and processed for the legal retention period or, if no such period is foreseen, for the period required by the purpose of processing. When this period expires, your personal data will be removed from the Company's data flows by means of deletion, destruction or anonymization.
16. YOUR RIGHTS AS A RELATED PERSON
According to Article 4 of the KVKK, the "Company" is obliged to keep your personal data accurate and up-to-date. In this context, in order for the "Company" to fulfill its obligations arising from the current legislation, our Customers must share their accurate and up-to-date data or update it via the website / mobile application.
Article 11 of the KVKK numbered 6698 entered into force on October 07, 2016 and, in accordance with the relevant article, the rights of the Personal Data Owner after this date are as follows: The Personal Data Owner may apply to the "Company Data Controller" and request; You can always contact us to get information about the following issues within the scope of the law;
a) Learning whether personal data has been processed,
b) Requesting information about personal data if it has been processed,
c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
ç) To know the third parties to whom personal data is transferred, domestically or abroad,
d) To request correction of personal data if it is processed incompletely or incorrectly,
e) To request deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
f) To request notification of the transactions made pursuant to subparagraphs (d) and (e) above to third parties to whom it is transferred,
g) To object to the emergence of a result against you due to analysis exclusively by automated systems,
ğ) To request compensation for damages in the event that you suffer damages due to processing in violation of the law.
You can always change your communication preferences and exercise your right to be forgotten.
Channels through which you can reach us for your requests:
As the data controller that will process your personal data, you can submit your requests within the scope of Article 11 of the KVKK, which regulates the rights of the relevant person, under the heading “The Company is the Data Controller within the scope of the KVKK. The Data Controller Representative to be appointed by the Company will be announced in the Data Controllers Registry and on the internet address where this document is located when the legal infrastructure is provided. Personal Data Owners can send their questions, opinions or requests to any of the following communication channels, via a notary or other methods determined by the Personal Data Protection Board. Your request will be responded to as soon as possible and within thirty (30) days at the latest in accordance with the law. However, if the transaction requires an additional cost, the Company reserves the right to charge a fee in accordance with the Law based on the tariff determined by the Personal Data Protection Board.
Company Information in Türkiye
Company Title
TFLL İlaç, Gıda Takviyeleri ve Kozmetik Ürünleri Sanayi Dış Ticaret Ltd. Şti.
Address
Barbaros Mah. Kardelen Sok. Palladium Tower No:2/10-33 Ataşehir İSTANBUL
Email
info@tfllpharma.com
Phone
+90 850 377 77 01
Company Information in Belgium
Company Title
TFLL Pharma Beigium BV
Address
Life Sciences Incubator BioVille Agoralaan Building Abis 3590
Diepenbeek / Belgium
Email
info@tfllpharma.com
Phone
+32 11 286 900
17. ENFORCEMENT
The effective date of this Policy is 02.09.2024. The Company reserves the right to make changes to the Policy in line with legal regulations. You can access the current version of the Policy on our website. If the provisions of the Privacy Policy change, they will come into force on the date they are published on the website.
We recommend that you read this Disclosure Text prepared for you before approving it, and thank you in advance for reading it.
