KVKK Information Notice

The legally binding version of this document is the Turkish original. This translation is provided for convenience; in case of any discrepancy, the Turkish version prevails.

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Within the scope of the Personal Data Protection Law No. 6698 ("KVKK"), GoWellFly, in its capacity as data controller, is obliged to inform Users about the personal data processed via the Platform.

This Information Notice has been prepared for the purpose of providing information regarding what personal data are collected, by which methods and on which legal grounds they are processed, for which purposes they are used, to whom they may be transferred, and the rights of the data subjects.

1. Data Controller

Your personal data are processed by GoWellFly, in its capacity as data controller pursuant to the KVKK, for the purposes set forth in this notice.

2. Purpose and Scope

This Information Notice covers the processing of personal data of:

all Users who visit and use the Platform
Clinic representatives
Suppliers

as set forth above.

3. Definitions

The principal terms used in this notice:

Personal Data: any information relating to an identified or identifiable natural person
Special Categories of Personal Data: data falling within special categories, in particular health data within the scope of Article 6 of the KVKK
Data Subject: the natural person whose personal data are processed
Explicit Consent: consent regarding a specific subject, based on information and disclosed with free will

4. Personal Data Processed

The following personal data may be processed within the scope of the Platform:

4.1 Identity and Contact Information

first name, last name
e-mail
telephone number

4.2 Usage and Transaction Information

platform usage activities
requested services
user interactions

4.3 Technical Data

IP address
device information
browser information
system log records

4.4 Location Data

user access location

4.5 Special Categories of Personal Data (Health Data)

In the event that they are shared by the User:

health information
treatment history
medical documents

may be processed.

These data constitute special categories of personal data within the scope of the KVKK, and additional security measures are taken for their processing.

5. Method of Collection of Personal Data

Your personal data are collected:

via the Platform
during the use of the mobile application
via e-mail and telephone communication
via cookies
via automated systems

as set forth above.

6. Purposes of Processing of Personal Data

Your personal data are processed for the following purposes:

provision of Platform services
establishment of communication between the user and the clinics
execution of appointment and scheduling processes
improvement of the user experience
execution of customer support processes
execution of marketing and campaign processes
ensuring data security
fulfilment of legal obligations

7. Specific Provision on Health Data

Due to the nature of the Platform model:

GoWellFly does not directly provide healthcare services
is not the data controller of health data

Health data:

are processed by the relevant Clinic
the Clinic acts as the data controller

GoWellFly may process such data only:

within the scope of the technical infrastructure
in its capacity as a data processor

as set forth above.

8. Transfer of Personal Data

Your personal data may be transferred to the following parties:

clinics on the Platform
technical service providers
business partners
IT infrastructure providers
authorised public institutions and organisations

Such transfer:

in compliance with the provisions of the KVKK
in a limited and proportionate manner

shall be carried out as set forth above.

9. Transfer Abroad

Your personal data may be transferred abroad due to:

cloud systems
global infrastructure providers

as set forth above.

Such transfer is carried out in accordance with Article 9 of the KVKK.

10. Artificial Intelligence and Automated Processing

The artificial-intelligence-supported systems offered within the scope of the Platform:

are for analysis and recommendation purposes only
do not constitute medical diagnosis or treatment

The User accepts that:

these systems are not binding
they are of a supportive nature only

11. Data Security

GoWellFly:

takes the necessary technical and administrative measures to ensure data security
prevents unauthorised access
protects data integrity

Within this scope:

firewall
antivirus systems
access control mechanisms
regular security tests

are used.

12. Retention of Personal Data

Personal data:

for as long as the purpose of processing continues
for the period stipulated by the legislation

are retained.

At the end of the period:

they are deleted
destroyed
or anonymised

13. Rights of the Data Subject

Within the scope of Article 11 of the KVKK, data subjects have the right to:

be informed whether their data are processed
request information
request rectification
request erasure
object to processing
request compensation for damages

as set forth above.

14. Method of Application

Data subjects may submit their requests:

E-mail: [email protected]

via the contact set forth above.

Applications shall be concluded within 30 days at the latest.

15. Amendments

GoWellFly reserves the right to update this notice.