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GoWellFly

Privacy Policy and Personal Data Notice

Last updated: 26.02.2024

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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This Privacy Policy and Personal Data Notice ("Policy") has been prepared in order to inform Users about the terms and conditions regarding the use of data obtained and/or to be obtained from Users in any manner whatsoever within the scope of the Services provided by GoWellFly through the Platform, as well as the manner in which such data are processed.

1. Definitions and General Explanations

In this Policy:

  • Individual User means a person who, other than a Clinic and a Supplier, accesses the Platform and benefits from the Services,
  • Platform means www.gowellfly.com, owned by GoWellFly, and/or its mobile application,
  • Law means the Personal Data Protection Law No. 6698,
  • Clinic means healthcare institutions registered on the Platform that are authorised to provide healthcare services within the scope of the relevant legislation,
  • User means, individually or jointly, the Individual User, the Clinic and the Supplier,
  • Terms of Use means the text on the Platform that is accepted by the Users,
  • Policy means this Privacy Policy and Personal Data Notice,
  • Supplier means the person who will offer products or services to other Users via the Platform,

Capitalised terms used in this Policy and not otherwise defined herein shall have the meanings ascribed to them in the Terms of Use.

Personal data means any information relating to an identified or identifiable natural person.

Personal data are processed in accordance with the following principles:

  • compliance with the law and the rules of good faith
  • being accurate and up to date
  • being processed for specified and legitimate purposes
  • being limited and proportionate
  • being retained for the period required

2. Collection of Personal Data and Data Controllership

GoWellFly, as a data controller within the scope of the Law, has the obligation to inform users.

However, an important point:

GoWellFly, with respect to the healthcare services to be provided to Users by the Clinic:

  • does not directly access health data
  • does not process such data as a data controller

Health data processed by the Clinic:

  • are the responsibility of the Clinic
  • GoWellFly is solely a technical infrastructure provider

For this reason:

Users shall direct their requests regarding health data directly to the relevant Clinic.

3. Collection of Personal Data

Data provided by Users to the Platform:

  • while registering
  • while filling in forms
  • while communicating
  • while using the Platform

may be processed within the scope of personal data.

The data collected:

  • Identity and contact information
  • Service usage information
  • Platform usage data
  • IP address and device information
  • Location information
  • cookie data

Health data, on the other hand, are processed only if shared by the user, and for the purpose of being shared with the Clinic.

4. Methods of Data Collection

Data are collected:

  • via the Platform
  • e-mail
  • telephone
  • cookies
  • automated systems

as set forth above.

5. Data Categories

Individual User

  • Identity information
  • Contact information
  • Service and transaction information
  • usage data
  • security data

Clinic Representative

  • identity
  • contact
  • professional experience
  • transaction data

Technical Data

  • IP address
  • device information
  • cookies
  • internet traffic data

6. Legal Grounds

Data are processed on the following legal grounds:

  • conclusion and performance of a contract
  • fulfilment of legal obligations
  • legitimate interest
  • being expressly stipulated by law

7. Purposes of Processing of Personal Data

Data are processed for the following purposes:

  • provision of platform services
  • user communication
  • customer support processes
  • service development
  • marketing and analytics
  • legal obligations

8. Use of Artificial Intelligence

Artificial-intelligence-supported analyses provided within the scope of the Platform:

  • are for informational purposes only
  • do not constitute medical diagnosis
  • do not replace a doctor's opinion

The User accepts that such recommendations are not binding.

9. Data Security

GoWellFly:

  • takes technical and administrative measures for data security
  • prevents unauthorised access
  • protects data integrity

For data security:

  • firewall
  • antivirus
  • access control
  • backup

systems and similar mechanisms are used.

10. Transfer of Data

Personal data may be transferred to:

  • clinics
  • technical service providers
  • business partners
  • legal authorities

as set forth above.

11. Cookies

Cookies are used on the Platform for the purposes of:

  • user experience
  • analytics
  • security

as set forth above.

12. Third-Party Sites

The Platform may contain redirections to third-party sites.

GoWellFly is not responsible for those sites.

13. User Rights

Users have the right to:

  • be informed whether their data are processed
  • request rectification
  • request erasure
  • object

as set forth above.

14. Application

Users may submit their requests:

E-mail: [email protected]

via the contact set forth above.

15. Amendments

GoWellFly reserves the right to update this notice.