General Data Protection Regulation

As Integro Sağlık Hizmetleri ve Bilişim Teknolojileri Ticaret Anonim Şirketi (“IntegroHealth” or “Company”), we are committed to protecting your privacy. This privacy policy contains explanations regarding the processing of your personal data in the context of your use of the IntegroHealth mobile application and website, in accordance with the Personal Data Protection Act No. 6698 (“PDPL”).

Which Personal Data Do We Collect?

We collect the following personal data in connection with your use of the mobile application and website.

Patients

Personal Data
Processing Purposes
Legal grounds
Your data processed during registration and profile creation. name, surname, Turkish ID number or passport number, e-mail address, phone number, date of birth, country, gender, profile name, password, photo and ID/passport image if you share your ID or passport image during the identity verification process marital status*, nationality*, residence*,
Work phone number*, address*
foreign language*, educational background*, occupation*, emergency contact list*, language and time zone selection*, photo*

*It is not mandatory to enter this information.

Registering for our services and creating your account
Delivery of our services
Contacting for operational and promotional processes when necessary
Ensuring your communication with doctors
Confirmation of your credentials

Performance of the contract pursuant to Article 5/2(c) of the PDPL

Your data processed within the scope of your use of our services. Disease information, symptom information, past and current treatment and hospital information, laboratory records, reports and results, allergen information, pregnancy information, body temperature information, medication information, test information, doctor reports, vital signs, doctor’s name and surname information, prescription information, blood type, height, weight, medical history, drug, smoking and alcohol use, hereditary disease information, epicrisis, examination information, amount of water drunk, blood pressure, sugar, pulse rate, respiratory rate, temperature, nutritional information, sleep pattern information, saturation information, exercise information, sexual activity and sexual partner information, test result information, vaccination information, surgery information, information on family and medical history, disease and device adherence information, fertility information and fertility history for female users, information on disability status and percentage of disability, type of special equipment/equipment, if any, and the location of this special equipment/equipment

Your information described above will be processed in the application (i) if you enter such information, (ii) if and when you provide the information during our consultations with the doctor, or (iii) if you integrate your IoT device with the application, depending on your preference.
Delivery of our services
Doctors getting information about your health condition and determine the right treatment methods
Writing prescription and doctor’s report
Creating your treatment plan and carrying out the treatment process
Identification of your symptoms and diseases
Analysis of your health and disease status
Determining reminders and making the reminders you request

Explicit consent pursuant to Article 6/2 of the PDPL

Performance of the contract pursuant to Article 5/2(c) of the PDPL

Pursuant to Article 6/3 of the PDPL, the processing of data by persons subject to confidentiality for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing
Your data processed within the scope of appointment creation. payment information, appointment information (complaint subject to appointment, date and time, place, doctor information)

IntegroHealth does not store your credit card information.
Execution of all appointment processes with doctors, including appointment creation, change and cancellation
Realization of appointment payment
Performance of the contract pursuant to Article 5/2(c) of the PDPL
Your data processed within the scope of your communications with doctors. Appointments, verbal, written and/or video interviews and communication process with doctors*

*The conversation between the patient and the doctors is not recorded by IntegroHealth.
Video or written communication with doctors
Realization of video doctor appointments
Delivery of our services
Performance of the contract pursuant to Article 5/2(c) of the PDPL

Your data processed within the scope of your use of our application and website. IP address, device information saved in the application, location information, application history, cookies
Delivery of our services
Registration and tracking of the devices you have paired to the app
If you use the ambulance app, the ambulance will reach your location
Showing you hospitals near you
Realization of analysis activities
Improving our services
Showing you relevant content

For more detailed information on cookies, please review our cookie policy.
Performance of the contract pursuant to Article 5/2(c) of the PDPL

Legitimate interest of the data controller pursuant to Article 5/2(f) of the PDPL

Explicit consent pursuant to Article 5/1 of the PDPL
Your data processed in case you realize an advantageous membership or subscription. name, surname, phone number, subscription details of your e-mail subscription, your remaining usage information

In the provision of our services within the scope of the subscription, the categories of personal data and processing purposes related to service provision apply. Please refer to the relevant row of the table.
Provision of your subscription
Determining your subscription usage
Delivery of our services
Performance of the contract pursuant to Article 5/2(c) of the PDPL
Your data processed within the scope of your communication with the call center. name, surname, call center call records, phone number

Since the content of the request is determined by you, if you share personal data other than those just mentioned in the content of the request, this data may also be processed by our company.
Provision of call center service
Confirmation of identity
Ensuring that services are carried out in accordance with the legislation
Delivery of our services
Performance of the contract pursuant to Article 5/2(c) of the PDPL

IntegroHealth allows individuals to create profiles for patients other than themselves and to enter information about hereditary diseases within its mobile application and website. In this context, if a separate profile is created, the personal data of the profiled patients will also be processed by IntegroHealth in accordance with this Privacy Policy. In addition, if disease information about family members is entered as part of hereditary disease and family history information, this data is processed by IntegroHealth. If you create more than one profile from your own account or provide hereditary disease and family history information, we assume that you have given this Privacy Policy to the patient whose information you are sharing and that you are sharing their data with us with the knowledge of that patient.

Doctors

Personal Data
Processing Purposes
Legal grounds
Your data processed during registration and profile creation. name, surname, Turkish ID number, e-mail address, phone number, date of birth, country, hospital, gender, profile name, password, resume and other information provided by you for the creation of the about you page, signature, photo and ID/passport image, username and password if you share your ID or passport image during the identity verification process
Registering for our services and creating your account
Delivery of our services
Contacting when necessary
Ensuring your communication with patients
Creating your doctor profile
Performance of the contract pursuant to Article 5/2(c) of the PDPL
Your data processed within the scope of appointment creation. appointment information (date and time, location, patient information), your calendar
Execution of all appointment processes with patients, including appointment creation, modification and cancellation
Checking your appointment availability and booking the appointment
Performance of the contract pursuant to Article 5/2(c) of the PDPL
Your data processed within the scope of your communications with Doctors. Appointment, interview and communication process with patients

*The conversation between the patient and the doctors is not recorded by IntegroHealth.
Video or written communication with patients and other doctors
Realization of video appointments
Delivery of our services
Performance of the contract pursuant to Article 5/2(c) of the PDPL

Your data processed within the scope of your use of our application and website. IP address, location information, usage history, cookies
Delivery of our services
Processing your data within the scope of ambulance location tracking features if you work within the scope of the ambulance application
Realization of analysis activities
Improving our services
Showing you relevant content

For more detailed information on cookies, please review our cookie policy.
Performance of the contract pursuant to Article 5/2(c) of the PDPL

Legitimate interest of the data controller pursuant to Article 5/2(f) of the PDPL

Explicit consent pursuant to Article 5/1 of the PDPL

Third parties who attend the appointments*
* If you attend the appointments upon patients’ invitation, your following personal data may be processed.

Personal Data
Processing Purposes
Legal grounds
name, surname, e-mail address, degree of closeness to the patient, communication and contact process during verbal and/or written interactions and/or video calls.*

*The conversation between the patient and the doctors is not recorded by IntegroHealth.

Ensuring your participation to video or written communications between the patient and the doctor
Conducting video appointments
Delivery of our services

Making the personal data public by the data subject pursuant to Article 5/2(d) of the PDPL

Performance of the contract pursuant to Article 5/2(c) of the PDPL

Legitimate interest of the data controller pursuant to Article 5/2(f) of the PDPL

By Which Method Do We Collect Your Personal Data?

We collect your personal data through our website and mobile application.

To Whom Do We Transfer Your Personal Data?

We transfer your personal data to third parties for the purposes stated above and in accordance with Article 8 of the PDPL. We transfer your personal data to internet service providers, mobile application software maintenance and support service providers, our business partners, especially hospitals, laboratories and ambulance services, and suppliers/service providers from whom we receive support within the scope of product/service supply. We may share your personal data with authorized public institutions and organizations and authorities if we encounter the request of legal authorities.

Your personal data consisting of phone number, password and e-mail address will be transferred to servers abroad for storage purposes based on your explicit consent within the scope of Article 9 of the PDPL. For the avoidance of doubt, your health data is not transferred abroad.

What Are Your Rights Regarding Your Personal Data?

To the extent that your data is processed by IntegroHealth and IntegroHealth processes your data in the capacity of data controller, you have the following rights at any time by sending an e-mail to the e-mail address [email protected] in writing to the address Barbaros Plaza | Dikilitaş, Emirhan Cad. No:113 Kat: 11 Beşiktaş | İstanbul 34394 | Türkiye in person or by mail or by using the e-mail address registered in our system;

a. To learn whether your personal data is processed or not,
b. To request information regarding the processing activities of your personal data,
c. To learn the purposes of processing personal data and whether they are used appropriately for their purposes,
d. To know the persons your personal data is transferred within or outside the country
e. If your personal data is incomplete or incorrectly processed, to ask them to be corrected,
f. To request the deletion or destruction of your personal data in the event that the reasons requiring the processing of your personal data disappear or IntegroHealth has no legal basis or legitimate interest to process such data,
g. To notify third parties to whom your personal data has been transferred of your deletion and correction requests and to request them to perform the same actions,
h. To object to adverse consequences that may arise by analyzing your personal data through automated systems,
i. you have the right to request compensation for this damage in case you suffer damage due to unlawful processing of your personal data.

IntegroHealth will finalize your request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on its nature. If a cost arises due to the fulfillment of your requests, you may be charged the fees in the tariff determined by the Personal Data Protection Board.