Welcome to Heuplus and our website at www.heuplus.io. At Heuplus, we take the protection of your data very seriously. In the following, we explain what information we collect when you use our website and services,
and how it is used.
The Basics
What law applies?
Our use of your personal data is subject to Turkey`s Data Protection Law 6698 (“DPL”), the EU General Data Protection Regulation ("GDPR"), and of course we process your personal data accordingly.
In addition, we take all reasonable steps to keep the use or disclosure of protected health information to an absolute minimum in order to provide the promised services. As such we work hard so that our services meet
or exceed industry standards with respect to the U.S. Health Insurance Portability and Accountability Act ("HIPAA") of 1996. For further information on our Practices in regard to your protected health information,
please refer to our HIPAA Statement.
What is personal data?
Personal data is any information about personal or factual circumstances that relate to a person. This may include name, date of birth, email address, postal address or telephone number, but also online identifiers
such as IP addresses or device IDs.
What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade
union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is
necessary to consent to the processing.
What is processing?
"Processing" is any operation or set of operations that is performed on personal data, whether or not it is done automatically. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party within the meaning of the DPL and the GDPR is Heuplus Inc.
If you have any questions or wish to exercise your rights, please contact us at info@heuplus.io or WhatsApp us on +90 850 309 7497.
What are the legal bases for processing?
According to the DPL and the GDPR, we should have at least one of the following legal bases to process your personal data:
• To fulfill contractual obligations
(The purposes of the data processing are primarily based on the service we provide).
• In connection with our legitimate interests.
(Where necessary, we process your data beyond the actual performance of the contract to protect legitimate interests of us or third parties. Examples include:
• Ensuring IT security and IT operations,
• Corporate governance measures and further development of our services,
• defense against claims by third parties and
• Enforcement of our own claims).
• Based on your consent
(If you have given us your consent to process personal data for specific purposes).
• To comply with legal obligations.
(Processing to comply with our legal obligations.)
Am I obliged to provide data?
In the context of our business relationship, you are only obliged to provide personal data that is required for the establishment, implementation and termination of a business relationship or that we are legally
obliged to collect. Without this data, we usually have to refuse to conclude a contract or can no longer fulfill an existing contract and may have to terminate it.
Data that we collect automatically
Log data
Each time you visit our website, our system automatically collects the following data from the visiting device and stores it in a so-called log file: (i) name of the file accessed, (ii) date and time of the visit,
(iii) amount of data transferred, (iv) notification of successful retrieval, type of browser and version used, (v) IP address (identification of the user's device), (vi) operating system of the visiting device, (vii)
Internet service provider of the visiting device, (viii) website from which you access our website, and (ix) which pages of our website you access. The legal basis for this processing is our legitimate interest.
Hosting
The hosting service used by us for the purpose of operating our website is Google. In doing so Google processes inventory data, contact data, content data, usage data, meta data and communication data of customers,
interested parties and visitors of our website and services, on the basis of our legitimate interests.
Fonts
We have integrated Google Fonts by Google, and Font Awesome of Fonticons Inc. To enable the display of fonts, a connection to Font Awesome’s and Google’s server is established when our website is
accessed. This enables Google and Fonticons to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.
Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be
small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential
Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies
used to display advertisements to you (“advertising” cookies).
As set out in Turkey`s Law No. 6563 (“RCEL”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further
information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Cookie consent
Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s)
or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and
your consent.
Links to other websites
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy
on the third-party website itself.
Data we collect directly
Contact
The processing of personal data depends on the nature of your contact. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also contain
certain personal data. The personal data collected when you contact us is used to process your request, and the legal basis is your consent.
We also offer to contact us via the messaging services of WhatsApp. If you contact us via WhatsApp we store and use the mobile phone number, you use and - if provided - your first and last name in accordance with the
provision of a contractual or pre-contractual measure to process and respond to your request.
We are present on social media (currently Instagram, Facebook, LinkedIn, X (formerly Twitter) and YouTube (Google)). If you contact or connect with us via social media platforms, we and the relevant social media
platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a
contract.
Please note:
As a rule, we do not require special categories of personal data to contact you. We ask you not to provide us with such information from the outset. If such information is relevant for contacting you, we process it
together with your other data. Your data will not be used by us for automated decision-making or profiling, nor will it be passed on to third parties. Your data will be processed by us or on our behalf.
Registration
We process your first name, last name, e-mail address, DOB and Gender and the data related to your contract with us data to handle the contractual relationship between you and us. The data provided will be used for
the purposes of creating and using the account and providing and/or using our services. In the context of the use of our registration and the use of your account, the legal basis for the data processing is the
fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as consent.
Profile
As a registered user, you have the opportunity to create a user profile with just a few clicks and details. Of course, you can change the information at any time via the settings in your profile. The legal basis for
the processing of your Personal Data is the establishment and implementation of the user contract for the use of the service.
When you use our services
We process various data in the context of the provision of our services and for the initiation and execution of the contractual relationship existing between you and us.
If you have contracted us to provide a service, we process your data (if provided: name, contact details (email address and telephone number), address, and all information required in the context of the performance
of the services including health data and medical history (previously contracted diseases, medications used, test results, and medical imaging reports etc.), exclusively for the purpose of processing and handling the
contractual relationship.
Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation,
and religious beliefs. By choosing to provide this data, you consent to our processing of that data.
You have choices about the Personal Data you provide and how you share it. You don’t have to provide Personal Data or Special Category Data; however, information about you helps you to get more from our
Services. It’s your choice whether to include Personal Data or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available. The
legal basis for the processing of your Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent. You may withdraw your consent and request
us to stop using and/or disclosing your personal and Special Category Data by submitting your request to us.
Our employees will also have access to data that you knowingly share with us for technical support or to import data into our services. We communicate our privacy and security guidelines to our employees and enforce
privacy safeguards strictly.
When providing services through our platform (Doctors)
We process various data in the context of the provision of your services through us. This may include your first name, last name, e-mail address, Phone Number, address, education/expertise history (university of
graduation, specialization location, etc.), employment history (hospitals where you have worked or are currently working, etc.)
Please note:
Also please note that when providing your services, you become the data controller and we become the data processor in accordance with Chapter 4 of the GDPR. Where we process Personal Data including Special Category
Data as data processor or in other words on behalf of you, we will process the Personal Data including Special Category Data involved in your use of our services in accordance with your instructions and shall use it
only for the purposes agreed between you and us.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our
employees and enforce privacy and protection safeguards strictly.
Further, please be advised that:
• some jurisdictions may require you to disclose your use of our services as your processor in your privacy policy and/or data processing agreement as applicable. For that
purpose all Personal Data including Special Category Data processed by us will be stored using the Google Cloud Services of Google in a designated European location.
• if you are providing us with Personal Data including Special Category Data relating to a third party, you agree a) that you have in place all necessary appropriate consents
and b) that such third party has read this Privacy Policy. You agree to indemnify us in relation to all and any liabilities, penalties, fines, awards, or costs arising from your non-compliance with these
requirements.
Data management and customer support
For optimal data management and customer support, we store the data related to your contract with us in our proprietary customer relationship management system. This data processing is based on our legitimate
interest in providing our customer service.
Administration, financial accounting, office organization, contact management.
We process data in the context of administrative tasks and the organization of our business and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the
provision of our contractual services. The processing bases are our legal obligations and our legitimate interest.
Payment Data
If you make a purchase your payment will be processed via our payment service provider. Payment data will solely be processed through our payment service provider and we have no access to any Payment Data you may
submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.
Economic analyses and market research
For business reasons, we analyze anonymized data relating to diseases, location (Coarse Location), gender and age. In doing so, we may take into account the profiles of registered users. The analyses serve us alone
and are not disclosed externally and processed using anonymous analyses and market research with summarized and or anonymized values. In all respects, the economic analyses and general trend determinations are
prepared anonymously.
Marketing
If you have given us your separate consent to process your data for marketing and promotional purposes, we are entitled to contact you for these purposes through the communication channels for which you have given
your consent.
You may give us your consent in a variety of ways, such as by checking a box on a form asking for permission to send you marketing information, or sometimes your consent is implied from your interactions or
contractual relationship with us. In cases where your consent is implied, it is based on the assumption that you could reasonably expect to receive a marketing communication based on your interactions or contractual
relationship with us.
Direct marketing is typically by email, but may include other less traditional or new channels. These forms of contact are managed by us or by our contracted service providers. Any direct addressed marketing sent or
conducted by us or on our behalf will provide you with the opportunity to opt out.
General Principles
Who receives my information?
Within Heuplus, those who have access to your information are those who need it to fulfill our contractual and legal obligations.
Processors used by us may also receive data for these purposes. These are companies in the areas of IT services, telecommunications, and sales and marketing. If we use processors to provide our services, we take
appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal provisions.
Data is only passed on to third parties within the framework of the legal provisions. We only pass on user data to third parties if this is necessary, for example, for contractual purposes or due to legitimate
interests in the economic and effective operation of our company, or if you have consented to the transfer of data.
How long will my data be stored?
To the extent necessary, we process and store your personal data for the duration of our business relationship, which includes, for example, the initiation and execution of a contract.
In addition, we are subject to various retention and documentation obligations, which result, among other things, from the statutory minimum retention periods and other retention periods prescribed in this sense,
e.g. retention periods under tax or commercial law. Depending on the document and the legal regulation, the periods specified there for storage and documentation are five to ten years.
How do we secure your data?
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. In addition, we have taken numerous security
measures ("technical and organizational measures"), such as encryption or access only when necessary, to ensure the most complete protection of personal data processed through this website.
Nevertheless, Internet-based data transmissions can always have security vulnerabilities, so that absolute protection cannot be guaranteed. And databases or records containing personal data may be breached
inadvertently or by unlawful intrusion. If we learn of a data breach, we will notify all affected individuals whose personal data may have been compromised as soon as possible after the breach is discovered.
Is data transferred to a third country?
We process data in the course of operating our website. We do not normally transfer personal data to countries outside Turkey and the EEA. However, if we do, we ensure that the processing of your personal data is
governed by processing contracts that include standard contractual clauses to ensure a high level of data protection.
Special category data
We do not process special category data unless it is necessary for the use of our services and explicit consent has been given.
Minors
We do not request personal data from minors and children and do not knowingly collect such data or share it with third parties.
Automated Decision Making
Automated decision making is the process of making a decision by automated means without human involvement. Automated decision making does not occur.
DO NOT SELL
We do not sell your personal information.
Your rights and privileges
Rights to protect your data
Under the DPL and the GDPR, you may exercise the following rights:
• Right to information
• Right to rectification
• Right to deletion
• Right to data portability
• Right to object
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority
• Right not to be subject to a decision based solely on automated processing.
Under HIPAA, you may exercise the following rights:
• You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you.
• You can ask us to correct health information about you that you think is incorrect or incomplete.
• You can ask us to contact you in a specific way (for example, home or office phone) or at a specific location (for example, to send mail to a different address).
• You can tell us your choices about what we share.
• You can ask us to limit what we use or share
• You can get a list of those with whom we have shared information
• You can get a copy of this Notice
• You can choose someone to act for you
• You can file a complaint if you feel your rights are violated
For further information on our practices in regard to your protected health information, please refer to our HIPAA Statement.
If you have any questions about the type of personal data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your data
If you believe that the data we hold about you is inaccurate or that we are no longer entitled to use it and you wish to request that it be rectified or erased, or object to its processing, please contact us.
Withdrawal of your consent
You may withdraw any consent you have given at any time by contacting us. The legality of the data processing carried out until the withdrawal remains unaffected by the withdrawal.
Request for information
If you would like to make a request for information about your data, you can inform us in writing. We will respond to requests for information and correction as quickly as possible. If we are unable to respond to
your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with the personal information you have requested or to make a
correction, we will tell you why.
Complaint to a supervisory authority
You have the right to lodge a complaint about our processing of personal data with a supervisory authority responsible for data protection. The supervisory authority in Turkey is the Personal Data Protection
Authority (KVKK). The KVKK is located at Nasuh Akar Mahallesi Ziyabey Caddesi, 1407 Sokak No:4 06520, Çankaya , Ankara, Türkiye, and online at www.kvkk.gov.tr. However, we would appreciate the opportunity
to address your concerns before you contact the KVKK or any other supervisory authority.
Changes
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
Contact us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above.
Effective Date
Saturday, 4th of November 2023