As ZAREN GROUP and its affiliates (“Zaren,” “we,” “us,” “us,” “our”), we recognise how important privacy is to our patients 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 information practices. The Privacy Policy applies to the Zaren Group website, online transactions on the website and services performed at Zaren Group Member merchants (collectively referred to as “Our Services”).

We may change this Privacy Policy from time to time for various reasons, such as to reflect changes in laws and regulations, changes in industry practices and technological developments. Please note that the Privacy Policy applies to our website, your online transactions and the transactions you perform in our hospitals that are covered by this Privacy Policy. The Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, TV or any other device to access our Services or physically access them in person. It is very important that you read the Privacy Policy carefully, as each time you use our Services, you are consenting to the practices we describe in the Privacy Policy. By using our Services, you consent to the practices described in the Privacy Policy.

It is also very important that you frequently check whether the Privacy Policy has been updated. When we update the Privacy Policy, we will notify you of any changes we deem important by adding a note to the relevant Services. By accessing or using our Services after we add this notice, you are consenting to the new practices set forth in the update. The most recent version of the Privacy Policy in effect 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?

Information That You Provide Directly:

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

• Our Health Services that we offer in our hospitals require our patients to provide us with all their identity information such as name, surname, T.R. Identity Number, etc. For example, if you apply for a health examination at our hospitals, you will need to provide us with your identity information in order to provide you with services.
• We may request your identity information so that you can make an appointment from the Online Transactions section on our website.
• We may request your identity information, your country of residence, your contact number and e-mail address in order to make an application with the form you fill out for us to contact you from the contact section on our website.

Information About Your Use Of The Services:

In addition to the information you provide, we may collect information about your use of our Services that you have received from other Zaren Group Companies. For example, we may collect the following information:

• Identity information-Name, surname, ID Number, etc. all identity information
• Health information – Information about all the treatments you have received at our hospitals
  Contact information-E-mail, telephone number, etc. information to help contact you may be transmitted to us

Information From Third Party Sources:

• We may receive information about you from publicly available and commercially exploitable sources (to the extent permitted by law) and may combine this information with other information we receive from or about you. We may also ask your third party relatives to provide information about you for the purpose of providing our Services.

Other Information We Collect:

• We may also collect other information about you, your health or your use of the Services, with your consent at the time of collection or otherwise.
• You may choose not to provide us with certain types of information (e.g., current information about your health status), but your failure to provide this information may result in you not being able to use or enjoy some of the Services as you would like.

Information Collected Automatically:

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

• Your Internet Protocol (“IP”) address
• Your user and account names and related data
• Telephone number
• SIM (Subscriber Identity Module) card number
• Device identification numbers such as Machine ID, IMEI and/or MEID
• Geographical location based on GPS/Wi-Fi/communication network localisation information

Except where we need to retain the identifying characteristics of the data, we anonymise the data we collect and store it in a form that does not identify you. For example, when we collect your IP address, we anonymise your IP address by hiding the last group of digits (e.g. 192.168.1.1 becomes 192.168.1.XXX).

How Do We Collect Your Information?

Your information may be collected verbally, in writing or electronically through our website, our job application service that you can perform from the Online Transactions and contact section on our website, our call centre service, physical applications you have made to our hospitals.

How Do We Use Your Information?

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

• To register you for a Service
• To provide a Service you have requested
• To provide you with personalised services based on your past activity on our Services
• For advertising activities, such as providing sponsored content with customised advertisements and sending you promotional communications
• For evaluation and analysis of our market, patients, products and services (including asking your opinion about our products and services and conducting patient surveys)
• To improve our Services and develop new products and services by understanding how our Services are used
• To organise free prize draws, prize competitions or promotions to the extent permitted by law; and
• For other purposes with your consent.

We may combine the information we collect from you and use it for purposes consistent with this Privacy Policy.

To Whom Do We Disclose Your Information?

We do not disclose your information to third parties without your consent for them to use for their own independent marketing or business purposes. However, we may disclose your information to the following organisations:

Affiliates. For the purpose of this Privacy Policy, your information may be shared with ZAREN Group affiliates.

Service providers. We may also disclose your information to companies that provide services on our behalf or for us, such as companies that assist us with billing or send emails on our behalf. These organisations may use your information for the sole purpose of providing services to us.

Patient / Patient Relatives We may disclose information about your health status for the purpose of informing your first degree relatives within the framework of the relevant health legislation.

Other Parties Where Required by Law or Necessary to Protect Our Services. We may disclose your information to other parties for the following reasons:

• To comply with the law or respond to mandatory legal notices (such as a search warrant or other court order);
• To verify or enforce policies governing our Services; and
• To protect the rights, property or safety of the Zaren Group or our respective affiliates, business partners or patients.

How Do We Ensure the Security of Your Information?

In order to ensure the integrity of all kinds of data necessary to support and maintain the Services we provide to our patients, to archive them for periods in accordance with the legal legislation, to prevent them from being shared with third parties other than the medical team that will carry out the diagnosis and treatment;

• Necessary software and hardware have been identified
• Necessary resources have been allocated to ensure uninterrupted provision of the necessary software and hardware
• What needs to be done in terms of protecting patient information has been conveyed to our staff through trainings, and their responsibilities have been put in writing through employment contracts
• The necessary infrastructure for backing up all data has been determined and responsible persons have been identified
• All kinds of access operations (reading, changing, deleting, adding) are restricted in our hospital information system
• Patient files and information are provided only to our patients themselves, their relatives to whom they have given written consent, relevant public institutions and organizations within the framework of health legislation, and authorized judicial authorities in judicial cases

The 3 basic principles of our hospital on information security are confidentiality, integrity and accessibility by the authorities.

Who Controls Your Data?

Within the scope of Law No. 6698 on the Protection of Personal Data, the “Data Controller” for each company within Zaren has been determined by us as follows.

1- ZAREN GROUP HEALTH AND TOURISM INDUSTRY TRADE ANONİM ŞİRKETİ

We hereby state that your information is collected within the scope of this Privacy Policy by the persons who have the title of “Data Controller” mentioned above and that these persons have the rights and obligations stipulated in Law No. 6698 as “Data Controller”.

Data Retention

We take reasonable measures to ensure that information about you is retained only for as long as required for the purpose for which it was collected or as required by applicable laws or contracts.

What Are Your Rights In Relation To Your Data

Regarding your data being processed within Zaren Group;

• To find out whether your data is being processed
• To obtain information if your data is being processed
• To find out what the purpose of processing your data is and whether your personal data is used in accordance with its purpose
• If applicable, to learn who are the third parties to whom the data is transferred at home or abroad and what data is transferred
• To request correction of data if it is incomplete or inaccurate,
• To request the deletion or destruction of your processed data if the reasons for the processing of your data no longer exist or if the data becomes outdated
• You can always send us your requests for your requests for correction or deletion of your data, if any, to be notified to third parties to whom the data is transferred.

Which Principles Do We Observe When Processing Your Personal Data?

Zaren observes the following principles when processing your personal data:

• Processing in accordance with the law and good faith
• Accuracy of data processing
• The scope of the processing is specific
• Processing is carried out for legitimate purposes
• The processing is relevant, limited and proportionate to the purpose for which the data is collected or reprocessed
• Up-to-date data
• Retention of data for the period necessary for the purpose for which they are processed

Third Party Links and Products On Our Services

Our Services may contain links to third party websites and services that are beyond our control. We are not responsible for the security or privacy of information collected by websites or other services. You should exercise caution and remember to review the applicable privacy statements for the third party websites and services you use.

If You Are A Minor

Zaren Group is concerned about the privacy and safety of minors on the Internet. Our Website is intended for the general public and not for use by minors.

Contact Information:

If you have any questions or concerns, please do not hesitate to contact us at info@zarenclinic.com or +90 542 550 36 59.