MEDICANA HEALTH GROUP CONFIDENTIALITY POLICY
Effective Date: […./01/2017]
Medicana Health Groups and its affiliates (“Medicana”, “We”, “to us”, “Our”) know how important the confidentiality is for our clients and we make efforts to be transparent about how we collect, use, disclose, transfer and store your information. This Confidentiality Policy offers a general frame for our procedures performed on information. Confidentiality Policy applies to the web site of Medicana Health Group, online procedures available in the site and our Medicard practices as well as services delivered in Medicana hospitals (hereinafter collectively referred to as “Services”).
We may amend this Confidentiality Policy, hereby, at times in order to reflect the amendments in laws and regulations and changes in sector-based practices and technological developments. Please always remember that the Confidentiality Policy applies to our web site, your online transaction and Medicard-based procedures as well as the procedures you perform at our hospital subject to this Confidential Policy. Confidentiality Policy is valid irrespective of using computer, mobile phone, tablet, TV or any other device to access our Services. Since you approve the procedures specified in the Confidentiality Policy for each time you use our Service, it is very important to read the Confidentiality Policy carefully. By using our Services, you approve the procedures specified in the Confidentiality Policy.
It is also very important for you to check, frequently, whether the Confidentiality Policy is updated or not. When we update the Confidentiality Policy, we inform you about significant amendments, in our opinion, by added a note to relevant Services. After we add this warning text, it is assumed that you approve new procedures specified in the update when you access to or use our Services. The most recent valid version of the Confidentiality Policy will always be accessible in our web site. You may check the “Effective Date” that is shown on top of the page to see date of the last update.
Which information do we collect about you?
Details that are directly communicated by you
Certain Services guides you to communicate the information directly to us. For example:
•Healthcare services delivered at our hospitals oblige our clients transfer their identity details (name, surname, R.T. ID Nr. etc.) to us. For example, when you visit our hospitals for medical examination, you will need to disclose your identity details to use in order to have our hospitals deliver services to you.
•To schedule an appointment on Online Transactions tab of our web site, we may seek your identity details.
•We may request your identity details in order to enable you utilize our Medicard service.
•We may ask your identity details and information about your work experience and educational life in order to allow you make a job application to HR tab of our web site.
Details about use of our Services by you can be transferred to us.
In addition to information you give, we may also collect details about use of our Services delivered by other Medicana hospitals. For example, we may collect following information:
Identity details – all identity details such as name, surname, R.T. ID number,
Health information – details about all treatments you received at our hospitals,
Contact details – information that helps communication with you, such as e-mail, phone number etc.
Information disclosed by third parties
We may obtain information about you from sources that are open to public and can be used commercially (to the extent allowed by laws) and we may combine such information with other details we obtained from you or other details about you. Moreover, we may seek information about you from your relatives (regarded as third party) in order to ensure delivery of our services.
Other Information We Collect
Moreover, we may collect other information about you, your health status and use of Services by you by obtaining your consent while the information is collected or via other methods.
You may prefer not to disclose certain information (for example, up-to-date information about your health status) with us, but failure to disclose such information to use may cause inability to use certain Services or it may lead to delivery of certain Services not as you wish.
Automatically Collected Information
We collect certain personal data automatically when you use our web site or products. This information may involve all or some of below mentioned information:
•Your Internet Protocol (“IP”) address;
•Your user and account names and relevant data;
•SIM (Subscriber Identity Module) card number;
•Device identity number, such as Machine Identity, IMEI and/or MEID;
•Geographical location based on local information of GPS/Wi-Fi/connection network.
Excluding the conditions that require us store and retain identifier feature of data, we anonymize the collected data and we store them such that your identity cannot be disclosed. For example, when we collect your IP address, we anonymize your IP address by hiding the last group of digits (for example, 192.168.1.1 is processed into 192.168.1.XXX).
How do we collect your data?
Your personal data can be collected in any and all verbal or written forms or in digital media through our web site, our Medicard service, online services on our web site, your job application over our HR department, call center service and your physical admissions to our hospitals.
How do we use your data?
We may use your data, which we have collected, for following purposes:
•To record you for a certain service;
•To deliver a Service that you requested;
•To provide you with personalized services based on your previous activities in our Services;
•For advertisement activities, such as communicating sponsored content through private advertisements and sending promoted communications to you;
•Evaluation and analysis of our market, clients, products and services (including but not limited to asking your opinion about our products and services and carrying out client surveys);
•To improve our Services and develop new products and services by understanding how our Services are used;
•To organize free-of-charge gift draws, prize competition or promotions to the extent allowed by laws, and
•For other purposes subject to your approval.
We may combine the information that we collected from you and use them for purposes that comply with terms and conditions of this Confidentiality Policy.
Who do we disclose your information?
We do not disclose your information to third parties to allow them use your information for their own marketing or business purposes without your permission. However, we can disclose your information to below stated institutions:
Affiliates. Within scope of Confidentiality Policy, your information can be communicated to affiliates of Medicana Health Group.
Service providers. We can disclose your information to companies that provide services for or on behalf of our party such as companies that assist us for invoicing procedures or that send e-mails on behalf of us. These institutions can use your information only to provide services to our party.
Relatives of Clients (Patients). We can disclose information about your health status to inform your first degree relatives within scope of relevant health legislation.
Other Parties As Required by Law or In Cases Where It Is Necessary to Protect Our Services. We may disclose your information to other parties due to below listed reasons:
•To obey the law or respond mandatory legal notices (such as search warrant or another precept);
•To verify or practice the policies that regulate our services and
•To protect the rights, properties or safety/security of Medicana Health Group or relevant affiliates, business partners or clients.
Other Parties dealing with Corporate Actions. We can disclose your information to a third party as a part of merger or transfer or in case of bankruptcy.
Other Parties upon Your Approval or Request. In addition to explanations in this Confidentiality Policy, we can share your information with third parties upon your approval or request.
How Do We Ensure Security of Your Personal Data?
In order to ensure integrity of all required data, archive them in compliance with legislation and prevent disclosure thereof to third parties, excluding the medical team that will undertake diagnosis and treatment for supporting and maintaining the Services delivered to our clients;
•Necessary software and hardware are determined.
•Necessary resources are allocated for uninterrupted supply of required software and hardware,
•Activities to be performed to protect client’s data are notified to our personnel in trainings and their relevant responsibility is materialized through employment contracts.
•The infrastructure required backing up all data is determined and the people in charge of them are specified,
•Any and all means of access (reading, editing, deleting, adding) to the information system of our hospital are subject to authorization,
•Client (Patient) files and data are disclosed to patients, their relatives (should written consent is obtained from the patient) and to relevant bodies and organizations subject to health legislation as well as authorized judicial bodies in case of judicial conditions.
Three basic principles of our hospital about information security are privacy, integrity and access limited to authorized people.
Who Controls Your Data?
Pursuant to Personal Data Protection Law (Nr. 6698), “Data Controller” of each company affiliated to Medicana is determined by our party as follows.
1- Medicana Diş Hastanesi A.Ş.
2- Işıl Sağlık Hizmetleri A.Ş.
3- Samsun Medicana Özel Sağlık Hizmetleri A.Ş.
We declare that your information is collected by individuals with the title of “Data Controller” that are listed above pursuant to this Confidentiality Policy and these individuals have the rights and obligations laid down by the Law Nr. 6698 based on the title of “Data Controller”.
We take reasonable measures to ensure that your information is stored only for the period of time required by the reason of collecting information or valid laws or contracts.
What Are Your Rights Related to Your Data?
You can always send your requests about the following regarding your data processed in Medicana Health Group;
•To learn if your data are processed or not,
•If your data are processed, to receive information about this subject,
•To learn the aim of processing your data and whether your data are used in line with the aim or not,
•To learn the local or international third parties that are transferred the personal data and which data are transferred,
•To request correction, if personal data is incomplete or incorrect,
•To request that your data are deleted or destroyed if the reasons that require processing of your data no longer exist or data are out of date,
•To ask that your requests regarding correction or deletion of your data –if any- are notified to third parties to which the data are transferred.
What Are Our Principles While Processing Your Personal Data?
Medicana pays regard to below listed principles while processing your personal data:
•Processing in line with the laws and good faith;
•Processing the data accurately,
•Clearly determining the scope of processing,
•Processing the data for rightful purposes,
•Ensuring that the processing is in line with the purpose of collecting or reprocessing and that they are processes in a limited and reasonable manner,
•Making sure that the data is valid,
•Storing the data for a period required by the purpose of processing
Third Party Connections and Products in Our Services
Our services may be connected to third party web sites or services that are not under our control. Safety or confidentiality of information collected by web sites or other services are not under our responsibility. Please be careful and do not forget to view valid confidentiality notifications regarding third party web sites and services.
If You Are Not Of Full Age
Medicana Health Group is concerned about confidentiality and safety of individuals who are not of full age on the internet. Our web site has been designed for general public, not for individuals who are not of full age.