Privacy Policy

MEDICANA HEALTH GROUP PRIVACY POLICY

Effective Date: […./01/2017]
As Medicana Healthcare Group and its subsidiaries (“Medicana,” “we,” “us,” “our”), we understand the importance of privacy for our customers, and we strive to be transparent about how we collect, use, disclose, transfer, and store your information. This Privacy Policy provides a general framework for our practices related to information. The Privacy Policy applies to our website, online transactions, the Medicard application, and services provided at Medicana hospitals (collectively called "Our Services").
We may change this Privacy Policy occasionally to reflect changes in laws and regulations, industry practices, and technological developments, among other reasons. Please note that this Privacy Policy applies to our website, your online transactions, and your dealings with our hospitals that fall within the scope of this Privacy Policy. The Privacy Policy applies regardless of whether you access our Services using a computer, mobile phone, tablet, TV, or any other device or whether you physically access our premises. You must carefully read the Privacy Policy each time you use our Services, as by using our Services, you confirm that you agree to the practices outlined in this Privacy Policy.
It is also essential for you to regularly check whether the Privacy Policy has been updated. When we update the Privacy Policy, we will notify you of any significant changes by adding a notice to the relevant Services. By accessing or using our Services after we have added this notice, you agree to the new practices outlined in the update. The most current version of the Privacy Policy will always be available on our website. You can check the "effective date" at the top to see when the Privacy Policy was last updated.

What Information Do We Collect About You?

The information you provide directly.

Some Services allow you to provide us with information directly. For example:

• Our Health Services, offered at our hospitals, require customers to provide us with personal identification information such as name, surname, ID number, etc. For example, suppose you apply for a health examination at our hospitals. In that case, you will need to provide us with your identification information so we can provide you with the service.
• We may request your identification information so that you can make an appointment through the Online Transactions section on our website.
• We may ask for your identification information so you can benefit from our Medicard service.
• We may request your identification information, work experience, and educational background so that you can apply for a job through the HR section on our website.

In addition to the information you provide, we may also collect information related to your use of other Medicana hospitals' services that you have received. For example, we may collect the following information:
Personal identification information — all personal identification information such as name, surname, national identification number, etc.
Health information — Information about all the treatments you have received at our hospitals,
Contact information — Email, phone number, etc., that can help us communicate with you can also be provided.

Information From Third-Party Sources

We may gather information about you from publicly available and commercially available sources to the extent permitted by laws and combine such information with other information we have collected about you. Additionally, as part of our provision of Services, we may request your family members who act as third parties to provide us with information about you.

The Other Information We Collect

Furthermore, we may collect additional information about your health status or use of the Services with your consent, either during the collection process or through other methods.
You may choose to provide only some types of information (such as current information about your health status), but not providing this information may result in not being able to use certain Services or not being able to benefit from them as you intended fully.

Automatically Collected Information

We automatically collect specific personal data when you use our website or products. This data may include some or all of the following types of information:

• Your Internet Protocol ("IP") address;
• User and account names and related data;
• Telephone number;
• SIM (Subscriber Identity Module) card number;
• Device identification numbers such as Machine Identification, IMEI, and/or MEID;
• Geographic location based on GPS/Wi-Fi/communication network local information.
  Except for situations where we need to preserve the identifying characteristics of the data, we anonymize and store the data we collect in a way that will not identify you. For example, when we collect your IP address, we anonymize it by hiding the last group of digits (e.g., changing the number from 192.168.1.1 to 192.168.1.XXX).

How Do We Collect Your Information?

We collect your information through various methods, including our website, Medicard service, Online Transactions available on our website, and job application services provided through our HR department. Additionally, we may collect your information through our call center service or physical applications submitted at our hospitals. These methods may involve collecting your information verbally, written, or electronically.

How Do We Use Your Information?

We may use the information we collect for the following purposes:

• Enabling you to register for a Service;
• Providing a Service that you have requested;
• Providing personalized services to you based on your past activities on our Services;
• Conducting advertising activities such as providing personalized advertisements with sponsored content and sending promotional communications to you;
• Evaluating and analyzing our market, customers, products, and services (including soliciting your opinion on our products and services and conducting customer surveys);
• Improving our Services and developing new products and services by understanding how our Services are used;
• Conducting free prize draws, prize competitions, or promotions to the extent permitted by law;
• We are using the information for other purposes with your consent.
  We may combine the information we collect from you for purposes consistent with this Privacy Policy.

To Whom Do You Disclose Your Information?

We will not disclose your information to third parties for their own independent marketing or business purposes without your consent. However, we may disclose your information to the following organizations:
Affiliates: We may share your information with Medicana Healthcare Group affiliates for this Privacy Policy.

Service Providers: We may also disclose your information to companies that provide services on our behalf, such as companies that assist us with billing or send emails on our behalf. These organizations will only use your information to provide services to us.

We may disclose information related to your health to your first-degree relatives for the purpose of informing them, in accordance with the relevant healthcare legislation.

Other Parties When Required By Law or Necessary to Protect Our Services. There may be situations where we disclose your information to other parties for the following reasons:

• To comply with the laws or respond to mandatory legal notifications (such as a search warrant or court order);
• To verify or enforce policies that regulate our services and
• To protect the rights, property, or safety of Medicana Health Group or its related affiliates, business partners, or customers.
  Other parties related to corporate transactions. We may disclose your information to a third party as part of a merger or acquisition transaction or in the event of bankruptcy.

Other parties with your consent or at your request. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties with your consent or at your request.

How Do We Ensure The Security of Your Information?

To ensure the integrity of all data necessary to support and maintain the services we provide to our customers, to archive them in compliance with legal requirements, and to prevent their sharing with third parties outside the medical team responsible for diagnosis and treatment.

• The necessary software and hardware have been identified,
• Resources have been allocated to ensure uninterrupted provision of the necessary software and hardware,
• Measures to protect customer information have been communicated to our personnel through training programs, and their responsibilities have been documented in employment contracts.
• The necessary infrastructure has been identified, and responsible parties have been assigned to back up all data,
• Access to all operations (read, modify, delete, add) in our hospital information system has been restricted.
• Patient files and information are only provided to the patients, their authorized relatives who have given written consent, relevant public institutions and organizations by health legislation, and authorized judicial authorities in case of legal proceedings.

The three fundamental principles of information security for our hospital are confidentiality, integrity, and availability to authorized personnel.
Who Controls Your Data?
We have determined the " Data Controller " for each company within the Medicana group as follows, under the scope of Law No. 6698 on the Protection of Personal Data.

1. Medicana Dental Hospital Inc.
2. Işıl Health Services Inc.
3. Samsun Medicana Private Health Services Inc.

We hereby declare that the individuals identified as "Data Controllers" above collect your information within the scope of this Privacy Policy and are subject to the rights and obligations stipulated under Law No. 6698 as "Data Controllers."
Data Storage

We take reasonable measures to ensure that information about you is only stored for as long as necessary for collection or as required by applicable laws or contracts.

What Are Your Rights Regarding Your Data?

Regarding your data processed within the scope of Medicana Healthcare Group:

• Learn whether your data is being processed or not,
• Get information on how your data is being processed,
• Learn the purpose of the data processing and whether your personal data is being used appropriately for that purpose,
• You have the right to know who the third parties are that transfer your data within the country or abroad and which data is being transferred.
• You can request the correction of any incomplete or inaccurate data,
• If the reasons for processing your data no longer exist or if your data becomes outdated, you have the right to request the deletion or destruction of the processed data,
• You can always submit requests to us for the correction or deletion of your data and for notifying any third parties to whom your data has been transferred.
  What principles do we adhere to when processing your personal data?
  When processing your personal data, Medicana adheres to the following principles:
• Processing in compliance with the law and principles of honesty;
• Ensuring accuracy in data processing;
• Defining a specific scope for processing,
• Processing for legitimate purposes,
• Processing in connection with the purpose for which the data was collected or re-processed in a limited and proportionate manner,
• Ensuring that the data is up-to-date,
• Retain the data as long as necessary for the purpose for which it was processed.

Third-Party Links and Products in Our Services.

Our services may contain links to third-party websites and services beyond our control. We are not responsible for the security or privacy of information collected by these websites or services. Please carefully review the applicable privacy notices of any third-party websites or services you use.

If You Are Not of Legal Age

At Medicana Health Group, we are concerned about the privacy and safety of minors on the Internet. Our website is not intended for use by minors but instead designed for the general public.