Data protection declaration

Valid from 26.05.2021

We, NuuLeaf Medical Group (hereinafter referred to as «we», «us» or «the Group»), headquartered in Sisli, Istanbul, Turkey, strive to protect your privacy and continually improve the services we offer you. This data protection declaration applies to the website and social media of NuuLeaf Medical Group (hereinafter referred to as «portal» or «website»).

Introduction

We are subject to Turkish and, where applicable, international regulations. Consequently, we comply with the principles recognised at the Turkish and, where applicable, international level to guarantee data protection and security. This declaration informs you in particular about how we collect the personal data to which we have access via our website, the purposes for which it is used, to whom it may be transmitted and what your rights are in relation to the processing of your personal data.

This data protection declaration is an integral part of NuuLeaf Medical Group policy.

Consent

By accessing our website and using the services and products we offer, you declare that you have carefully read this data protection declaration and accept the processing of personal data described herein. Any questions regarding this data protection declaration can be sent at any time to the registered e-mail (KEP) address of “[email protected]. If you do not agree with this declaration, you must refrain from accessing the portal and using our services and products.

Who is responsible for your personal data?

The Controller within the meaning of data protection legislation is HIS International Tourism Travel Agency Ltd., acting in the capacity of data controller. Sti. has been prepared in accordance with the KVK Law No. 6698 in order to provide detailed explanation and information regarding the processing of your personal data. In this context, for more detailed information, you can review the introductory information and personal data retention/destruction policy at and the records in the VERBIS system.

 How we process personal data?

We collect and process personal data with care and for the purposes described in this data protection declaration. In accordance with applicable legal regulations, we may also use your personal data in a manner different from that described in this data protection declaration. In this case, we will provide you with specific data protection statements or disclosures at the time of collection and, where appropriate, we will seek your consent. We will always make reasonable efforts to collect personal data in an anonymous or pseudo-anonymised form so that your identity is not identified or identifiable.

Which personal data do we collect for which processing purposes?

Personal data transmitted to us by the user

NuuLeaf Medical Group collects and processes personal data that users voluntarily transmit via an online form directly on the portal, via our contact e-mail address, via any other applications linked to the portal, by telephone or in any other way. This information includes in particular the following personal data:

Full name, postal address, e-mail address, telephone number, date of birth, gender;

Your message or request.

Personal medical information provided to us by the user to allow for a consultation and/or quote to be provided for medical services.

Personal data is provided expressly and voluntarily. Without said personal data, we will not be able to provide the services requested by the user in the desired quality, or at all.

NuuLeaf Medical Group processes the personal data provided by users for the following purposes:

provide, maintain, protect and optimise the services and information offered;

communicate with you and provide you with the best personalised information (for example, about our products and services);

offer you new services and information and to offer you personalised services and information which may be of interest to you;

comply with legal or other regulatory requirements and internal directives;

to establish, exercise and/or defend existing or potential legal claims, investigations or similar proceedings;

for other legitimate purposes, if such processing was indicated at the time of collection or arose from the circumstances.

Fulfilling the obligations regulated in consumer law, electronic commerce law, travel agency law legislation,

Evaluating and finalizing objections, suggestions, complaints and feedbacks before the service,

Social media, e-mail, phone, whatsapp etc. Answering pre-service questions and complaints through communication tools such as social communication channels, sharing the information requested by our customer candidate, making necessary calculations,

Conducting customer satisfaction research in order to increase service quality, tracking, organizing and improving customer experience and demands,

Auditing by accredited independent companies in order to provide certification as per the standard, and reporting the results to us,

Ability to present all service history records as evidence in possible legal disputes.

To be able to report the necessary information to the relevant authorities in order to receive "Health Tourism Service"; transportation, accommodation, transfer etc. organizations can be realized,

On what legal basis do we process your personal data?

The processing of personal data is based on at least one of the following legal grounds:

your consent, only if it can be revoked at any time (e.g. if you sign up for our newsletter or other marketing communications)

to enter into or perform a contract with you for medical services;

to comply with a legal obligation (e.g., for tax purposes or the purposes of investigations or legal proceedings);

to protect our legitimate interests (e.g., the protection and security of our products and services, systems or property; compliance with legal, regulatory and contractual obligations; the establishment, exercise and/or defence of legal claims; the maintenance and efficient organisation of business activities; the improvement and development of our services and the sale and marketing of our products and services).

Where the processing is based on your consent or our legitimate interests, you may revoke your consent or object to such processing at any time by contacting us directly at [email protected].

Please note, however, that revoking your consent does not affect the legitimacy of the processing based on consent before its revocation.

With whom do we share your personal data?

NuuLeaf Medical Group takes the necessary measures to ensure that only our authorised staff and auxiliaries with the required expertise have access to your personal data in order to achieve the purposes for which your personal data was collected.

We may transfer your personal data to the following categories of possible recipients, in accordance with the purposes and legal bases for processing described above, insofar as this is necessary for the intended processing of the data:

Other companies in the Group;

Relevant public institutions and organizations and other institutions they have authorized, to the extent permitted and required by the provisions of the legislation, in order to fulfill the obligations of our company before the law,

Hospitals and doctors who will perform related medical operations within the scope of Health Tourism Service,

Switchboard provider companies that work with the aim of accessing voice recordings in call center processes

Service providers who process personal data on behalf of and on the instructions of NuuLeaf Medical Group (hereinafter referred to as «Processors «, e.g., in the areas of IT, hosting and support);

Customers, partners, suppliers, insurance companies and other business partners;

Courts, conciliation bodies, law enforcement authorities, supervisory authorities, lawyers and other parties to current or potential legal proceedings, where necessary to comply with the law or to establish, exercise or defend legal rights and/or claims.

All these categories of recipients may in turn use third parties, so your data may also be accessible to them.

We carefully select our partners and processors and only choose them if we have sufficient guarantees that they have implemented appropriate technical and organisational measures in accordance with legal requirements.

Our Processors may only process personal data on our documented instruction. They are all subject to confidentiality requirements and may only use your personal data to the extent necessary to achieve the purposes for which your personal data was collected unless otherwise required by law.

How long do we keep your information?

In principle, personal data is deleted as soon as it is no longer necessary for the processing purposes for which it was collected, unless longer conservation is necessary to comply with applicable legal obligations (e.g., retention and documentation obligations), contractual or pre-contractual obligations or our legitimate interests (e.g., to assert, exercise or defend legal claims).

On this basis, we generally process personal data in compliance with the following rules and obligations:

Personal data that you have transmitted to us in connection with the use of our services and products offered on our portal or that you have communicated to us in any other way via the e-mail contact address will normally be retained until you ask us to delete it, revoke your consent to its storage or until the processing purposes for which it was collected have been fulfilled (e.g. once the processing of your request has been completed).

Personal data relating to a contract (including commercial documents and communications) is kept for as long as the contractual relationship exists, and then for a further ten years after the end of the contractual relationship, unless (i) a shorter or longer legal retention obligation applies in a particular case, (ii) retention is necessary for evidential purposes or another legitimate reason under the applicable legal regulations.

Social Networks

Our website contains links to social networks. These are not plugins provided by the social network which, without the user having any influence, already transmit data to the provider when the page is loaded. The social network buttons are merely links to our presence on the relevant network. No user data is transmitted by the website to the social network.

When you click on a link to one of our profiles created on social networks, a direct connection is established between your browser and the server of the social network concerned. The network thus receives the information that you have visited our website with your IP address and that you have consulted the link. If you consult a link to a network while you are logged in to your account on the network concerned, the content of our site may be linked to your profile on the network, which means that the network may attribute your visit to our site directly to your user account. If you wish to prevent this, you must log out of your account on the relevant network before activating the corresponding links. An attribution takes place in all cases when you connect to the relevant network after clicking on the link.

Use of the contact form

You can use a contact form for general enquiries to get in touch with us. To do this, we generally need the following information (required *):

First name*

Surname*

E-mail*

Telephone number*

Country*

Message*

What are your rights?

You may ask NuuLeaf Medical Group, with proof of your identity, whether personal data concerning you is being processed. In addition, you have the right to request the rectification, total or partial deletion or restriction of the processing of your personal data, as well as to object to the processing of your personal data. The deletion of your personal data may result in you no longer being able to use our services.

If processing is based on your consent or on our legitimate interests, you may withdraw your consent or object to such processing at any time by contacting us directly by e-mail at [email protected]. Please note that we reserve the right to invoke any restrictions provided for by law, for example, if we are obliged to store or process certain data if we have an overriding interest in doing so (insofar as we are able to invoke it) or if we need to invoke rights.

Changes to our data protection declaration

NuuLeaf Medical Group reserves the right to amend, supplement or otherwise modify this privacy declaration at any time and without giving reasons. The current data protection declaration as published on the portal is authoritative.