App Privacy Policy

‍THIS PRIVACY POLICY (“POLICY”) DOCUMENT IS AN ELECTRONIC RECORD IN TERMS OF THE LAW ON THE PROTECTION OF PERSONAL DATA (KVKK), LAW NO. 6698 AND RELATED REGULATIONS. THIS ELECTRONIC RECORD IS GENERATED BY A COMPUTER SYSTEM AND DOES NOT REQUIRE ANY PHYSICAL OR DIGITAL SIGNATURES.

THIS DOCUMENT IS PUBLISHED IN ACCORDANCE WITH THE PROVISIONS OF THE LAW ON THE PROTECTION OF PERSONAL DATA (KVKK), LAW NO. 6698 AND THE REGULATION ON PERSONAL HEALTH DATA, WHICH REQUIRES PUBLISHING THE RULES AND REGULATIONS, PRIVACY POLICY, AND TERMS OF USE FOR ACCESS OR USAGE OF THIS PLATFORM.

We are happy to have you here at Novocuris patient engagement mobile software. Please note that this Policy applies to this application and all products and services offered on and through this application (“Platform”).

The Platform is owned by Novocuris Ltd, a company incorporated under the United Kingdom laws and/or its affiliates (hereinafter may be referred to as the “Company” “We” “Us”, and “Our”) and is licensed to ESTE MEDICAL GROUP (hereinafter referred to as “Health Care Provider”). The Company is committed to respecting your online privacy and recognises your need for appropriate protection and management of any information you share with the Company on and through the Platform. This Policy explains how the Company and/or Health Care Provider will collect, use, share and process information in relation to the Services and/or HCP Services provided on the Platform.

The Company through its Platform provides services of connecting Health Care Provider and their associated Practitioners (as defined below) to individuals/patients seeking medical help from such Health Care Provider and/or Practitioners, as an intermediary. This Policy shall be deemed to be incorporated into the terms of use of the Platform (the “Terms of Use”) and shall be read in addition to the Terms of Use. In the event of any conflict between this Policy and the Terms of Use, the interpretation placed by the Company shall be final and binding on you.

This Policy is prepared in accordance with the Law on the Protection of Personal Data (KVKK), Law No. 6698, and the Regulation on Personal Health Data. It complies with the requirements for ensuring reasonable security practices and procedures in handling sensitive personal data and the processing of personal data within Turkey.

By accessing, browsing or otherwise using the Platform and/or by giving the Company your information and/or by explicitly giving your consent (as indicated and recorded on the Platform), you expressly agree to be bound by the terms of this Policy. If you do not agree with the terms mentioned herein, please exit this Platform and restrict your access. By accepting this Policy, you understand and agree to the collection, use, sharing and processing of personal information as described herein. If you provide the Company with personal information about someone else, you confirm that (a) such information is accurate and up-to-date; (b) such person is aware that you have provided their information; and (c) they consent to both the disclosure and the use/processing of their information in accordance with this Policy. This Policy applies to all current and former visitors, users and others who access this Platform.

If you are unwilling or unable to be legally bound by this Policy, please do not use the Platform. You cannot accept this Policy if: (a) you are not lawfully entitled to use the Platform; or (b) if you are not of legal age to form a binding agreement with the Company in accordance with the applicable laws.

‍1. DEFINITIONS

For the purpose of these Terms, wherever the context so requires, the term:

1. ‍“Client(s)” or “User(s)” refers to individuals who seek medical treatment and use the Platform to connect with Health Care Provider and/or Practitioners;
2. “Services” shall refer to a broad range of technology solutions offered by the Company via the Platform including but not limited to connecting Users (individuals and organisations) to Health Care Providers and/or Practitioners for medical support;
3. “Health Care Provider Services” or “HCP Services” shall refer to a broad range of services provided by Health Care Providers and/or Practitioners on and through the Platform; and
4. ‍“Practitioners” refers to licensed medical practitioners associated with Health Care Provider who provide their professional services on and through the Platform and/or have listed themselves or by Health Care Provider on the Platform.

‍2. SCOPE OF THIS POLICY

1. This Policy is an electronic record in the form of an electronic contract established under the Law on the Protection of Personal Data (KVKK), Law No. 6698. This Policy does not require any physical, electronic, or digital signature.
2. By accessing or using the Platform or providing us with your information, you confirm that you have the legal capacity to enter into a binding agreement with the Company as per applicable Turkish laws, particularly under the Turkish Code of Obligations and KVKK, Law No. 6698. The Company will handle your personal and third-party data responsibly, exclusively for the purposes outlined in this Policy and strictly within the limits of the relevant legal regulations. This Policy ensures that any personal or third-party information handled by the Company is managed ethically, in compliance with Turkish data protection standards, and in alignment with industry best practices.
3. Please read the terms and conditions of this Policy carefully, before accessing or using this Platform. By accessing or using the Platform including its intermediary services, you agree to the terms of this Policy. If you are accepting this Policy on behalf of another person or company or other legal entity, you represent and warrant that you have full authority to bind such person, company or legal entity to these terms.
4. This Policy describes the types of information the Company collects, why and how the Company uses the information, with whom the Company shares it, and the choices you can make about the Company’s use of the information. This Policy also describes the measures the Company takes to protect the security of the information and how you can contact the Company about its privacy practices.
5. This Policy describes the Company’s current data protection policies and practices and may be amended/updated from time to time. Any changes to this Policy will become effective upon posting of the revised Policy on the Platform. It is recommended that you regularly check this Policy to apprise yourself of any updates. Your continued use of Platform or provision of data or information thereafter will imply your unconditional acceptance of such updates to this Policy.

‍3. TYPES OF INFORMATION COLLECTED BY THE COMPANY

1. ‍Personal Information: Personal Information means any information that may be used to identify an individual, including, but not limited to, the first and last names, billing/alternate address, nationality, country of residence, state, ZIP/Postal code, city, telephone number, mobile number, date of birth, age, gender, e-mail address, marital status, emergency contact number, emergency contact name, employer name, or any other information. The Company limits the collection of Personal Information which is necessary for its intended purpose.
2. ‍Heath Information: Health Information refers to any data, records, or information related to an individual's physical or mental health, medical history, medical conditions, diagnoses, treatments, medications, test results, medical procedures, healthcare provider information, insurance information, and any other information associated with the provision of healthcare services or the individual's health status. This includes, but is not limited to, information contained in electronic health records, paper records, digital medical images, medical billing records, and any other form of health-related documentation. Health Information encompasses both Personal Information and de-identified data related to an individual's health. It also includes blood group, medical records: past and present, and information relating to allergies, height, weight, dietary information etc.
3. ‍Sensitive Personal Information: Sensitive Personal Information of a person means Personal Information about that person relating to: passwords, financial information (bank accounts, credit and debit cards or other payment instruments), biometric information, physical information including GPS location, travel history, device ID.
4. ‍Non-Personal Information: Non-personal information means information that does not specifically identify an individual or business, but includes information from you, such as your browser type, the URL of the previous Platforms you visited, your internet service provider (ISP), operating system & version and your internet protocol (IP) address, devise location, information about your mobile devise including hardware model, preferred language, unique devise identifier, your profession, field of work, information you provide us when you contact Us for help; information you enter into our system when using the Platform, such as while asking doubts, participating in discussions and taking tests and any other information you may give on and through the Platform. The Company may gather any non-personal information regarding how many people visit the Platform, the pages you visit, how long you visited our Platform, and the date and time you used the Platform. The Company may also collect Non-Personal Information that you voluntarily provide, such as information included in response to a questionnaire or a survey conducted by the Company.
5. ‍Usage Information: Usage Information includes without limitation all data and information collected automatically through the Platform (or through the third party analytics service providers), by use and access of the Platform in the nature of system administrative data, statistical and demographical data, and operational information and data generated by or characterizing use of the Platform including without limitation, Non-Personal Information, cookies, your search queries, comments, search results selected, number of clicks, pages viewed and the order of those pages, error logs, Platform traffic, time spent on the Platform, number of visits to the Platform and other similar information and behaviour indicating the mode and manner of use of the Platform.
6. Personal Information, Health Information, Sensitive Personal Information, Non-Personal Information and Usage Information hereinafter shall be referred to as “Information”. The Company limits the collection of Information which is necessary for its intended purpose.

4. CONSENT

1. By mere use of the Platform, you expressly consent to the Company’s use, access, processing and disclosure of your Information and third-party information in accordance with this Policy. If you do not agree with the terms of this Policy, please do not use this Platform.
2. In case you wish to avail any or all of the HCP Services provided on the Platform, the Company shall provide a method for sign-up and login, which may include username and password, mobile number and OTP based login, biometric authentication, or any other mechanism as may be available on the Platform (“Login Credentials”) as set out in the Terms of Use. You may be required to fill in the Information on the Platform including full name, email address, mobile number and/or a one-time password sent on your mobile number to set up your account on the Platform. You hereby explicitly agree that your use and access of the Login Credentials shall be governed by the Terms of Use read with the terms of this Policy and any other agreement that you may enter into with the Company. You should not share your Login Credentials, one-time password or other security information for your account with anyone. If We receive instructions using your Login Credentials, We will consider that you have authorized the instructions.
3. Your acceptance of this Policy signifies your consent to the processing of your personal data by the Company and forms a valid and binding agreement between you and the Platform/Company for data processing, as per the terms of this Policy and in accordance with Article 5 of the Law on the Protection of Personal Data (KVKK), Law No. 6698.

5. CLIENT’S INFORMATION

1. As a Client, you can create an account by giving us information regarding your name, mobile number, gender, date of birth, email address, and such other information as requested on the registration page. This is to enable us to provide you with the facility to use the account to book your appointments and store other health related information.
2. You can use the Platform without registering for an account, but to book an appointment, you may be asked certain information (including your mobile number, and such other information as requested when you choose to use the services without registration) to confirm the appointment.

6. COLLECTION OF INFORMATION

1. The Company may collect Information from you when you (a) register on the Platform; (b) update or change personal details in your account; (c) use the Platform for any of the HCP Services being offered thereon; (d) voluntarily participate in campaigns conducted by the Company on the Platform or respond to questionnaires published by the Company on the Platform (if any); (e) voluntarily complete a customer survey or provide feedback on any of our message boards or via email or via third-party service provider in relation to the products and HCP Services provided on the Platform; and (f) when you carry out transactions on the Platform.
2. You acknowledge and agree that Company may access certain features and data stored on your device, including but not limited to photos, files, and contact numbers, subject to your explicit consent. By granting access to photos, files, and contact numbers, you understand and agree that the Company may collect, process, and store this information in accordance with this Policy. You also acknowledge that you have the option to revoke your consent to access photos, files, and contact numbers at any time by adjusting the settings on your device or contacting the Company directly.
3. In order to enhance certain features of the Platform, such as uploading documents or accessing media content, Company may request access to photos and files stored on your device. This access is required to facilitate the functionality of the Platform and provide you with a seamless user experience. Company will only access photos and files upon your explicit authorization and will not use this information for any purpose other than as described in this Privacy Policy.
4. Company may request access to the contact numbers stored on your device to enable certain features of the Platform, such as syncing contacts or facilitating communication with other users. Access to contact numbers is optional, and you have the choice to grant or deny access to this information. Company will only access contact numbers upon your explicit consent and will not use this information for any purpose other than as described in this Privacy Policy. This information may be utilized for various purposes, including but not limited to: (a) recommending the Platform to contacts with explicit permission from the user; (b) suggesting adding family members/friends within your account to manage their health information; (c) notifying contacts in case of emergencies; (d) recommending connecting to a contact within a social network.
5. You hereby acknowledge and agree that all Information is provided by you to the Company voluntarily and the Information provided by you is not subject to any undue influence.
6. The Company may use cookies to monitor the Platform usage including, without limitation, to provide useful features to simplify your experience when you return to the Platform, like remembering your Login Credentials, Information and to deliver relevant content based on your preferences, usage patterns and location.
7. You are also required to provide your billing address as well as debit card details which may be aligned with third party payment wallets/gateways. The Company will use this Information only for processing billings. For your convenience, the Company saves the billing information and remembers certain details of the payment choices made by you in the event you would like to carry out any other transaction on the Platform again.
8. The Company may also collect Non-Personal Information or Usage Information based on your browsing activity and in relation to your use or access to the Platform which may or may not be publicly accessible.
9. Information collected by the Company from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
10. You may use the Platform without providing the Company any Information about yourself. However, you may not be able to access certain intermediary services of the Platform in case you choose to do so.

7. NOTIFICATION PREFERENCES

1. By using the Platform, you have the option to enable notifications to receive updates, alerts, and relevant information from the Company. By enabling notifications, you agree to receive notifications from Company through the Platform or other communication channels as specified by Company, including but not limited to SMS, email, WhatsApp, and push notifications.
2. Notifications may include, but are not limited to, updates on appointments, reminders, important announcements, promotions, and other relevant information related to the services provided by Company and/or Health Care Provider.
3. Company will determine the frequency and delivery method of notifications, which may vary based on the type of information being communicated and your notification preferences. Company will make reasonable efforts to ensure that notifications are timely, relevant, and delivered in accordance with your preferences.
4. You have the option to opt out of receiving notifications at any time by adjusting the notification settings within the mobile or contacting the Company directly. Please note that opting out of notifications may affect your ability to receive important updates and information from the Company.
5. By enabling notifications, you grant Company permission to send notifications to your device and access necessary information to deliver notifications effectively. This may include accessing device identifiers, notification preferences, and other relevant data as required.

8. USE OF INFORMATION

1. The Company uses the Information you provide to: (a) manage your account; (b) fulfil your requests for the HCP  Services offered on the Platform (including to book appointment,  manage payments, fees and charges and collect and recover money owed to the Company and/or Health Care Provider); (c) respond to your inquiries about its offerings and the transactions carried out on the Platform; (d) provide you with information about products and services available on the Platform and offer you other services that the Company believes may be of one interest to you; (e) resolve any glitches on the Platform including addressing any technical problems; (f) improve the services and content on the Platform and your experience of navigating through the Platform and carrying out transactions on the Platform; (g) administer the Platform; (h) learn about each user’s learning patterns and movements around the Platform; (g) manage the Company’s and/or Health Care Provider relationship with you (h) To provide you with a personalized shopping experience, such as by showing you products that are relevant to your interests or preferences and (i) to conduct research and analysis to improve Our products, services, and Platform.
2. The Company may use the Information to monitor your use of the Platform and may review and analyse the Information to provide you with customized service.
3. The Company may use your Non-Personal Information or Usage Information for internal business purposes, such as data analysis, research, developing new products and/or features, enhancing and improving existing products and services and identifying usage trends.
4. Subject to and in accordance with applicable laws, the Company has the right to use your Information for the purpose of conducting promotional/marketing related activities on the Platform, including but not limited to, using your Personal Information for making posters/banners to promote the services of the Company and/or Health Care Provider.
5. When you send an email message or otherwise contact the Company through its Platform, the Company may use the Information provided by you to respond to your communication. The Company may also archive such Information and/or use it for future communications with you to inform you regarding updates, newsletters, offers, new services and promotions.

9. DUTIES OF USERS

Each user of the Platform is bound by certain obligations while sharing their information, as per the provisions of the Law on the Protection of Personal Data (KVKK), Law No. 6698, in addition to the obligations prescribed under the Terms of Use of the Platform:

(a) To comply with the provisions of all applicable laws in force while exercising rights under KVKK;

(b) to ensure not to impersonate another person while providing their own personal data/Information for a specified purpose;

(c) To ensure not to withhold any material information when providing personal data for any document, unique identifier, proof of identity, or proof of address issued by the government or any of its agencies;

(d) To avoid registering a false or frivolous grievance or complaint with the Company or the Turkish Personal Data Protection Authority; and

(e) To provide only verifiably authentic information when exercising the right to correct or delete data under KVKK.

‍10. INFORMATION SHARING

1. The Company maintains your Information in electronic form on its devices and equipment including any form of physical or offline records. The Information is made accessible to employees, agents, Health Care Providers, Practitioners or partners and third-parties only on a need-to-know basis.
2. The Company does not rent, sell, or share Information with third parties or with other non-affiliated entities, except with your consent.
3. The Company may engage third party vendors and/or contractors to perform certain services such as advertising companies, and email marketing providers, who may have limited access to Information.
4. To process your transactions, the Company may direct you to a payment gateway service provider of its own choice, which may have access to the Information provided by you while making such payment.
5. The Company may share Information with government authorities in response to subpoenas, court orders and/or other legal processes, to establish or exercise legal rights; to defend against legal claims; and/or as otherwise required by law. This may be done in response to a law enforcement agency's request.

11. THIRD PARTY SERVICE PROVIDERS

1. Notwithstanding anything contained herein to the contrary, it is clarified that the Company is merely an intermediary and facilitator between Client and Health Care Provider and/or Practitioner listed on the Platform. The Company takes no responsibility for the actions and/or inactions including any negligence, fraud, breach of confidentiality, violation of applicable laws, of such Health Care Provider and/or Practitioner listed on the Platform. This Policy only regulates and governs the Information shared by you on and through the Platform and not the Information shared by you directly with the Health Care Provider and/or Practitioner, as the case may be, listed on the Platform. You are hereby advised to disclose any Information to the Health Care Provider and/or Practitioner, as the case may be, listed on the Platform at your own risk. As a result of which, to the extent permitted under the applicable laws, the Company disclaims any and all liabilities towards any losses, damages, costs, compensation, loss of goodwill, reputation and/or any expenses incurred by you as a result of the Health Care Provider and/or Practitioner, as the case may be, misuse of your Information, breach of safety and security of the Information and/or any unlawful action in relation to the Information.
2. The Company may engage third party vendors and/or contractors to perform certain support services for the Company, including, without limitation, software maintenance services, advertising and marketing services, web hosting services and such other related services which are required by the Company to provide its services efficiently. These third parties may have limited access to Information. If they do, this limited access is provided so that they may perform these tasks for the Company and they are not authorized by the Company to otherwise use or disclose Information, except to the extent required by law. The Company does not make any representations concerning the privacy practices or policies or terms of use of such platforms/third parties, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on and with such Platforms/third parties.
3. The Platform may contain links and interactive functionality interacting with the Platforms of third parties or third parties including without limitation the payment gateways, advertisements, social media Platforms. The Company is not responsible for and has no liability for the functionality, actions, inactions, privacy settings, privacy policies, terms, or content of any such platforms or third parties. Before enabling any sharing functions to communicate with any such Platforms or otherwise visiting any such Platforms, the Company strongly recommends that you review and understand the terms and conditions, privacy policies, settings, and information-sharing functions of each such third-party Platforms.

12. DISCLOSURE TO ACQUIRERS

The Company may disclose and/or transfer Information to an investor, acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of the Company.

13. CONTROL OVER YOUR PERSONAL INFORMATION

1. You have the right to withdraw your consent for the processing of your personal data at any time, in accordance with Article 8 of the Law on the Protection of Personal Data (KVKK), Law No. 6698, by notifying the Company in writing via email at [email protected] or as otherwise indicated on the Platform. If you wish to correct your personal data at any time, you may contact the Company as per the terms of this Policy.
2. Once you withdraw your consent to share the Personal Information collected by the Company, the Company shall have the option not to fulfil the purposes for which the said Personal Information was sought and the Company may restrict you from using the HCP Services on the Platform and/or the Platform itself.
3. If you wish to delete your account, and thereby discontinue using the HCP Services provided by the Health Care Provider on the Platform, you may do so at any time, in accordance with the Terms of Use and/or any other agreement that you may enter into with the Company. In other cases, you may discontinue using the services provided by the Company on the Platform by writing to the Company at [email protected]
4. The Company is not liable for the Information you share with the Health Care Providers and/or the Practitioners directly. Upon your request for withdrawal of consent, removal of Information, rectification of Information or otherwise, we will undertake such necessary actions in compliance of the Applicable Laws to the extent the Information is within the control of the Company. We are not responsible or liable for the Information that is in control or within the infrastructure of the Health Care Provider and/or the Practitioners or any third party.

14. COMPLIANCE WITH LAWS FOR USERS OUTSIDE TURKEY

1. While We strive to ensure compliance with applicable laws and regulations, it is not feasible for Us to address the specific laws of every region. However, We are committed to protecting the privacy and Personal Information of all Our Users.
2. ‍Acceptance of Privacy Policy: By accessing and using Our Services and/or HCP Services, as a User outside Turkey, you acknowledge and agree to the terms of this Policy and Our data practices.
3. ‍Data Subject Rights: As a User outside Turkey, you may have certain rights regarding your Personal Information under the applicable laws of your region. While We strive to respect these rights to the extent required by law, please note that our ability to fully address specific legal requirements may be limited. We will, however, make reasonable efforts to assist you in exercising your rights as permitted by applicable laws.
4. ‍Compliance with Local Laws: While We endeavour to comply with applicable laws and regulations, including privacy and data protection laws, in all regions We operate, it is important to note that certain laws may have extraterritorial application. We encourage users outside Turkey to familiarize themselves with the local laws that may apply to their Personal Information and to assess the risks associated with using Our Platform and the HCP Services therein.

15. RECTIFICATION/CORRECTION OF PERSONAL INFORMATION

1. You shall have a right to access the Personal Information and/or Sensitive Personal Information that you have provided to the Company through the use of the Platform. Further, the Company shall provide a copy of the Personal Information and/or Sensitive Personal Information, free of charge, in an electronic format, upon such request.
2. You shall have the right to review your Personal Information and/or Sensitive Personal Information (as the case may be) submitted by you on the Platform and to modify or delete any Personal Information and/or Sensitive Personal Information (as the case may be), provided by you directly on the Platform. You hereby understand that any such modification or deletion may affect your ability to use the Platform. Further, it may affect the Company’s ability to provide its intermediary Services to you.
3. The Company reserves the right to verify and authenticate your identity and your account Information and/or payment Information in order to ensure your continued access to the Platform. Access to or correction, updating or deletion of your Personal Information and/or Sensitive Personal Information (as the case may be) may be denied or limited by the Company if it would violate another person’s rights and/or is not otherwise permitted by applicable law.
4. If you need to update or correct your Personal Information and/or Sensitive Personal Information that the Company may have collected to offer you personalized services and offers, you may send updates and corrections to the Company at [email protected] citing the reason for such rectification of Personal Information and/or Sensitive Personal Information. The Company will take all reasonable efforts to incorporate the changes within a reasonable period of time.

16. TERM OF STORAGE OF PERSONAL INFORMATION

1. The Company shall store your Information at least for such period as may be required and permitted by law or for a period necessary to satisfy the purpose for which the Information has been collected. These periods vary depending on the nature of the Information and your interactions with the Company.
2. You agree that you will not submit any false Information or any illegal or damaging content to the Platform. The Company reserves the right to terminate access to or the ability to interact with the Platform in response to any concerns the Company may have about false, illegal, or damaging content submitted by you, or for any other reason, in its sole discretion.

17. COOKIES

1. To enhance your experience with the Platform, many of the web/application pages use “cookies” and pixel tags and clear gifts on certain pages of the Platform. Cookies are text files the Company places in your computer's/mobile’s browser to maintain your log-in and session details. Company uses three types of cookies, necessary session cookies (including username, email ID, user access information) which enable Company to recognise you and makes it easier for you to return to the Platform and interact with the Company’s Services and/or the HCP Services without signing in again, and/or preference cookies (including search and browsing history) which are stored for the maximum duration permitted by law, and/or statistics cookies (including Usage Information such as unique request ID, statistical data) which are stored for 12 months or the maximum duration permitted by law (collectively referred to as the “Cookies”).
2. Cookies, by themselves, do not tell the Company your e-mail address or other personally identifiable information unless you choose to provide this information to the Company by, for example, registering on the Platform and/or by availing the HCP Services provided on the Platform. Cookies are designed to hold a marginal amount of data specific to a particular user and Platform and can be accessed either by the web server or the user device. However, once you choose to furnish the Platform with personally identifiable information, this information may be linked to the data stored in the Cookies. Company uses Cookies to understand site usage and to improve the content and offerings on the Platform. For example, Company may use Cookies to personalize your experience on the Platform (e.g., to recognize you by name when you return to the Platform). Company also may use Cookies to offer you products, programs, or services. Cookies may be placed on the Platform by third-parties as well, the use of which the Company does not control. You are free to accept or refuse the use of Cookies via the cookie banner that appears when you open/access the Platform.
3. Cookies are retained in your browser unless specifically deleted, depending on the type of Cookies. If you decline the Cookies, you may be unable to use certain features on the Platform and you may be required to re-enter your password frequently. By using or accessing the Platform and/or the HCP Services provided on the Platform, you hereby explicitly authorise the Company and give your consent to the Company to store, use and access Cookies for the purposes outlined in this Policy. Most browsers allow you to control Cookies through their settings, which may be adapted to reflect your consent to the use of Cookies, and they may also enable you to review and erase Cookies.
4. You can manage browser Cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive Cookies, how to disable Cookies, and when Cookies will expire. If you disable all Cookies on your browser, neither We nor third parties will transfer Cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit the Platform and some features and services may not work.

18. PROTECTION OF INFORMATION

1. The Company has taken adequate measures to protect the security of Information and to ensure that your choices for its intended use are honoured. The Company takes robust precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.
2. The Company considers the confidentiality and security of your information to be of utmost importance. It, therefore, uses industry standards, and physical, technical and administrative security measures to keep Information confidential and secure and the Company will not share your Information with third parties, except as otherwise provided in this Policy. Please be advised that, however, while the Company strives to protect Information and privacy, the Company cannot guarantee or warranty its absolute security when Information is transmitted over the internet into the Platform. The Company will annually evaluate this necessity considering your privacy and our relation while keeping the applicable legislation in mind. Non-Personal Information will be retained indefinitely.
3. Access to your online account on the Platform is via. your Login Credentials which is password protected and this helps to secure your account information. You are solely responsible for maintaining the confidentiality of your Login Credentials. To ensure safety of your Information, you are advised against sharing your Login Credentials with anyone. If you suspect any unauthorized use of your account, you must immediately notify the Company by sending an email to [email protected]. You shall be liable to indemnify the Company for any loss suffered by the Company due to such unauthorized use of your account.
4. For any loss or theft of Information, due to unauthorized access to your device through which you use the Platform or other reasons solely attributable to you, the Company shall not be held liable or responsible under any circumstance whatsoever. Further, the Company shall not be responsible for any breach of security or for any actions of any third parties/vendors or events that are beyond the Company’s reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the user, etc.  

19. MINOR

The Company does not intend to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. The Company does not intentionally or knowingly collect Personal Information through the Platform from anyone under that age. The Company encourages parents and guardians to be involved in the online activities of minor to ensure that no Personal Information is collected from a minor without their prior consent. If you are using the Platform on behalf of someone else, including but not limited to, on behalf of your minor child/children/employer, you represent and warrant that you are authorised by such person to accept this Policy on their behalf and to consent on behalf of such person to the Company’s use of such person’s Personal Information as described in this Policy.

20. LIMITATION OF LIABILITY

1. The Company and/or Health Care Provider shall not be liable to you for any loss of profit, anticipated savings, goodwill, reputation or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary or consequential losses arising out of performance or non-performance of its obligations under this Policy.
2. The Company and/or Health Care Provider is not responsible for any actions or inactions of any third parties, that receive your Information.
3. Notwithstanding anything contained in this Policy or elsewhere, the Company and/or Health Care Provider shall not be held responsible for any loss, damage or misuse of your Information, if such loss, damage or misuse is attributable to a Force Majeure Event and/or any third party. The term “Force Majeure Event” shall mean any event that is beyond the reasonable control of the Company and/or Health Care Provider and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, epidemic, pandemic or national/state lockdown due to any reason and any other similar events not within the control of the Company and/or Health Care Provider and which the Company and/or Health Care Provider is not able to overcome.

21. OPT-OUT

Once you register as a user on the Platform, you may receive multimedia text messages as SMS, WhatsApp, Facebook, Instagram, Email, and phone calls from the Company and/or Health Care Provider on the registered mobile number and e-mails on your registered e-mail address.  These messages, e-mails and calls could relate to your registration, transactions that you carry out through the Platform and promotions that are undertaken by the Company and/or Health Care Provider. You have the option to ‘opt-out’ of all Company’s newsletters and other general email marketing communications by way of links provided at the bottom of each mailer. The Company respects your privacy and in the event that you choose to not receive such mailers, the Company shall take all adequate steps to remove you from such lists. However, you will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications.

‍22. CHANGES TO THIS POLICY

The Company reserves the right to update, change or modify this Policy at any time. The Policy shall come to effect from the date of such update, change or modification. It is recommended that you regularly check this Policy to apprise yourself of any updates. Your continued use of the Platform or provision of data or Information thereafter will imply your unconditional acceptance of such updates to this Policy.

23. GOVERNING LAW

Without reference to any conflict of laws principles, this Policy shall be governed by and interpreted in accordance with the laws of Turkey. The exclusive place of jurisdiction shall be Istanbul, Turkey. In the event of any dispute arising out of this Policy, the dispute shall be resolved through binding arbitration by a sole arbitrator, appointed jointly by both parties, in accordance with the Turkish Code of Civil Procedure and other relevant Turkish arbitration laws. The seat and venue of arbitration shall be Istanbul, Turkey.

‍24. GRIEVANCE REDRESSAL MECHANISM

In accordance with the Law on the Protection of Personal Data (KVKK), Law No. 6698, you have the right to readily available means of grievance redressal regarding your personal data collected by the Platform. The Platform/Company respects your rights and is hereby providing the contact details of the Data Protection Officer (DPO) as follows:

Name: Tushar Srivastava
Address: 64 Nile Street, International House, London, United Kingdom, N1 7SR
Phone number:+91 90051 26669
E-mail: [email protected]

If your grievance is not handled in compliance with the applicable laws by the Company, you have the right to file a complaint with the Turkish Personal Data Protection Authority under the provisions of the KVKK.

25. CONTACT DETAILS  

If you have any questions or concerns about this Policy, you may contact the Company at [email protected].