PROTECTION OF PERSONAL DATA AND OUR CONFIDENTIALITY POLICY

INFORMATION ABOUT THE LAW ON THE PROTECTION OF PERSONAL DATA, AND OUR DATA PROTECTION and CONFIDENTIALITY POLICY

Dear user; we, as Her yerde Sağlık, acting in the capacity of “data controller”, provides you with this Information Text regarding proper data collection and processing for your personal data shared by you while visiting our website pursuant to the Law on the Protection of Personal Data (No. 6698) including Article 6 expressing sensitive personal data. It is recommended to read this information text carefully that shows the identity of the data collector and representative in the process of data collection and processing, the persons to whom processed personal data might be transferred and the purposes for the same, the legal reason for personal data collection and shows your rights. To make you further understand the text and fulfill our obligations specified on Article 3 of the Law on the Protection of Personal Data (No. 6698), information regarding the processes of data processing is given below. In this respect;

Clear consent: implies obtaining approval for a certain issue based on information and free will,

Anonymization: implies sanitizing personal data concerning an identified or identifiable natural person, such that such data cannot be matched even with other data.

Relevant person: natural person whose personal data are processed.

Personal data: any kind of information relating to an identified or identifiable natural person.

Sensitive Personal Data: implies information about race, ethnic origin, political opinion, idea of life, religion, sect or other beliefs, appearance, association, foundation or union membership, health status, sexual life, criminal conviction, cautionary attachment and biometric and genetic data.

Personal data processing: implies any kind of activity regarding gathering, recording, storing, preserving, changing, re-organizing, sharing, transferring, taking over personal data, making derivable personal data and preventing classification or use of personal data that are processed wholly or partly by automated means as well as to non-automated processing as a part of recording system.

Committee: implies Personal Data Protection Committee

Authority: implies Personal Data Protection Authority

Data processor: implies a natural or legal person who processes personal data only on behalf of the data controller

Data Recording System: implies recording system where personal data are configured and processed based on certain criteria.

Data controller: implies a natural or legal person who determines the purpose of personal data processing and processing ways and is responsible for constructing and managing data recording system.

1. COLLECTING PERSONAL DATA AND LEGAL GROUNDS

Methods and Legal Grounds for Collecting and Processing Your Personal Data that are collected and processed to be able to provide you, our precious customers in line with the abovementioned goals through all verbal, written or digital medium in accordance with goods and services in line with regulation and so that our Company can completely and correctly perform the obligations originating from the agreement and legal obligations within this scope. Your personal data will be collected, processed and shared within scope of conditions and purposes of personal data processing as provided under Articles 5 and 6 of the Law on the Protection of Personal Data and for reasons and goals proposed under this information text.

2. PERSONAL DATA PROCESSED BY HERYERDE SAĞLIK

Within scope of the Law on Protection of Personal Data, Data Controller, Information Form and Explicit consent of the Related Persons, private information, including the data on your health, personal data will be collected and processed by our Company under title of data collector, within the following principles. The law on Protection of Personal Data projected that the related persons will be enlightened in line with Article 10 of the law. The obligation for enlightening projected on data collectors aims to clearly define for which purposes personal data of the related persons will be processed, to whom and which purposes the processed data can be transferred, method for collecting personal data by data collector and its legal grounds, rights of the related persons and identity of the data collector and representative. The aim of our company in accordance with this text is to thoroughly inform you how your personal data will be collected and processed and to ensure that your rights are reminded to your party. Explicit consent is the consent regarding a specific topic based on information and free will. So, in a way, upon reading this text, it is a declaration of approval for processing your personal data, including data that is specific; based on your free will, sufficient information in a manner that will not yield to any doubt. Within this context, in light of the following goals for processing personal data, we kindly ask you to check the boxes regarding the topics for which you consent your personal data to be processed.

3. AIM OF PROCESSING PERSONAL DATA

Your data to be processed by our Company and the aim for processing the data, it should be clearly specified for which purposes of personal data, including personal information of real persons are collected and processed in accordance with provisions of the regulation. Upon giving your explicit consent, personal data of your party to be processed regarding the following topics after approval from you, our customers within this scope and for abovementioned aims will be shared with persons specified in this information text;

Determining needs and demands regarding area of activity using personal data of our clients, to counsel needs and demands of the clients, guiding on goods and services to be purchased, improving variety of goods and services in light of demands and needs,

  1. Rendering better service for the customers, providing various advantages, planning of sale, marketing, information and special promotion activities targeting customer profiles, providing information on promotions, providing information on campaigns and conditions, conducting surveys and customer satisfaction studies, ensuring and accelerating purchases, planning and implementing of commercial and/or business strategies of our site, ensuring legal, technical commercial-business safety of relevant individuals in business relationship with our site, planning and implementation of activities necessary for recommendation and promotion of products and services provided by our party to relevant individuals after customization in accordance with satisfaction, utilization habits and needs of those individuals.
  2. Forming customer-oriented campaigns, managing cross-sales, identifying intended population, implementing activities that increase customer experience by following customer movements, development of our website and mobile application and their customization in accordance with customer needs,
  3. Implementation of direct and indirect personalized marketing and re-marketing activities and implementation of segmentation, targeting analysis and intra-company reporting activities,
  4. Providing a more special and effective service experience for you customers by analyzing activities and preferences of visitors who use heryerdesaglik.com, excluding personal data obtained from e-mail addresses, membership forms, forming and monitoring visitor records.

Performing market studies, planning and implementation of product and/or service sales and marketing processes including planning and implementation of customer satisfaction activities and customer relations management processes, planning and implementation of forming and/or increasing dependence to products and/or services provided by our website.

In addition, your personal information will not be used for any commercial purposes excluding the actions listed above and situations required by the legislation. In accordance with the exceptions identified in article 5(2) and article 6 (3) of PDPL (i) It is stipulated clearly in law, (ii) It is necessary in order to protect the life or physical integrity of the data subject or another person where the data subject is physically or legally incapable of giving consent, (iii) It is necessary to process the personal data of parties of a contract, provided that the processing is directly related to the execution or performance of the contract, (iv) It is necessary for compliance with a legal obligation which the controller is subject to, (v) The relevant information is revealed to the public by the data subject herself/himself, (vi) It is necessary for the institution, usage, or protection of a right, (vii) It is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed, Her yerde Sağlık is authorized to obtain and process your personal data, including your personal data with specific content, without the open consent of the relevant individual, due to necessity of processing data for the benefit of data controller as the examples stated below

  1. Carrying out necessary works by the relevant units to allow commercial activities on our website and conducting business processes accordingly,
  2. Establishing right and receivable of relevant persons,
  3. Informing competent bodies in line with the regulation,
  4. Meeting the obligations within the scope of Consumer Protection Law, Retail Trade Regulation Law, The Law On Regulation Of Retail Trade, The Law on the Regulation of Electronic Commerce, Regulation on Distance Contacts and other legal regulations by our Company and Branch Offices, our call center, our affiliated companies and any form of media including but not limited to our website and social media pages.
  5. Your personal data will be processed to receive your orders that you made on our website and deliver your products properly.

4. OUR COOKIE POLICY

Our website has the right to link the users’ transactions –even they do not sign in-with a cookie and identify marketing lists that base metrics like the number of pages displayed, duration of visits and target completions. Later, target-specific, interest-based advertisements may be displayed to users on the website or other websites within the advertising network. While Google AFS advertisements are directed to our website, Google may send cookie to users’ browser, read relevant cookies or read marks to get information.

5. PROCESSED PERSONAL DATA TRANSFER

Inland or cross-border transfer of personal data is addressed in Article 8 and 9 of the Law on the Protection of Personal Data. In the light of the law, it is necessary to provide information by our party to transfer your personal data legally. Your personal data can be shared with company officials, our affiliates, partners, suppliers, shareholders and authorized state institutions and organizations and private institutions to allow relevant units to perform necessary works and conduct necessary work processes to provide relevant persons with products and services offered by our website, to allow relevant units to perform necessary works to accomplish commercial activities conducted by our company, to plan and implement our company’s commercial and/or business strategies and to arrange and implement activities required to customize products and service offered by our website and recommend and promote them for relevant persons considering their legal, technical and commercial safety in accordance with the conditions and purposes of personal data transfer specified in Article 8 and 9 of the law. Name, last name and contact information of website user can be shared with payment institutions in accordance with framework agreement with the approving payment institution and Regulation on Prevention of Laundering Proceeds of Crime and Financing Terrorism issued on Official Gazette No 26751 dated 9 January 2008 for identity verification at payment process. Provided that provisions projected in accordance with Law No. 6698 are fulfilled, our company may transfer the data to domestic third parties as well as international third parties. Data of the individuals getting services from our contracted hospitals will be transferred to Her Yerde Sağlık Company.

6. STORING YOUR PERSONAL DATA

Your personal data are processed for achieving the goals described on this information form as required by limitation principle based on aims and provided that the period is limited to the duration which is required in line with tradition of commercial practices; data are deleted, destroyed or anonymised when period expires. The personal data you provide to the system can only changed by your party; all necessary technical and administrative measures are taken by our Company so that third parties cannot reach or change the information. However, Her Yerde Sağlık and patented brands are not liable in any way if your address or password is known or the membership is used by third parties. Credit card information required on the payment page is not stored by any means on servers of Her Yerde Sağlık or the companies providing services in order to provide maximum level of security for you, our precious clients who conduct transactions on the site. All transactions related to payment are directed to be performed between the bank and your computer through interface of Her Yerde Sağlık. Additionally; when clearly projected by law, your data, which are made public by the persons themselves that are required to be processed for legitimate benefits of our company with title of data supervisor, can be used for our company to fulfill the legal obligations due to the title of data supervisor for fulfilling the goals that are specified to be limited under this sentence if the periods mentioned under this article expire, provided that fundamental rights and freedoms of the related person are not violated. Therefore, it will not be allowed for your stored personal data to be accessed for other purposes and can only be used in mandatory situations. Upon ending of the mentioned mandatory situations, your personal data will be deleted, destroyed or will be made anonymous in line with procedures.

7. RIGHTS OF THE RELEVANT INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED

Our valued customers, in case where you require to use your rights as owners of the personal data obtained, processed and transferred by our company described under this title and/or PDPL pursuant to this information text and principles and procedures stipulated in regulation; Following your application to our company; your requests included in the application are concluded within thirty (30) work-days, depending on the nature of the request, without any costs. However, if the procedure requires an extra expenditure from the Company, you may be charged a cost that shall be no means above the limit determined by Personal Data Protection Committee. Pursuant to article 11 of the law on protection of personal data you, our valued customers or visitors (data owner) have the right to (i) learn whether your personal data is processed or no, (ii) request details if they are processed, (iii) learn the intent of processing your personal data and whether they are used in line with the intention, (iv) learn local and international third parties who are shared your personal data, (v) Request correction and having third parties, who were already transferred the personal data, about the correction, if personal data is incompletely or incorrectly processed, (vi) Request deletion or disposal of personal data, if causes that require processing the personal data are no more valid, although personal data are processed in accordance with the Law and provisions of other relevant laws, and having third parties, who were already transferred the personal data, notified about the relevant procedure, (vii) Raise an objection to a negative outcome arising out of analyzing the data exclusively with automated systems and (viii) demand compensation of losses if you suffer a loss due to illegal processing of your data. You may use these rights given to you by applying to our Company via e-mail from bilgi@heryerdesaglik.com or other methods foreseen in the Law on Protection of Personal Data, you may also use "Data Owner Request Form" which is under Information and request forms section of our web site for detailed applications. Changes may occur regarding subjects included in this form in accordance with legal and technological developments.

You may submit your additional requests, demands and complaints regarding all these subjects to our Company Her Yerde Sağlık Elektronik ve Ticaret A.Ş from below mentioned communication channels. Relevant procedure takes precedence in cases when a relevant request should be concluded in accordance with a certain procedure (method-time-form) pursuant to law. Address: İvedik Osb Mah. 2224 cad. No: 1 İÇ KAPI NO: 185 Teknopark / Yenimahalle / ANKARA, Phone: 0850 325 50 50, bilgi@heryerdesaglik.com, (Web Site: www.heryerdesaglik.com) Whatsapp 555 969 30 30