Confidentiality, Personal Information and Cookies Policy

Confidentiality, Personal Information and Cookies Policy (“Policy”) (Date of Update: 23.08 2019)

Welcome to our website. We, as Can Medikal Hizmetler A.Ş. Özel Lifemed Tıp Merkezi (“Lifemed”), have prepared this policy to ensure that users / visitors / members (all abreviated as “data owners”) who use our www.hairtransplantationlifemed.com extension site (the “Site”) and benefit from our services are able to benefit safely from our services and our site anda re informed about our policy. This policy also describes how the personal information you share with us is used, processed and protected.

By using our site and using our services, we strongly indicate that you have read, reviewed, and accepted the terms of the policy. By using our website and services, you agree to the practices and rules set out in this policy. Users of our website do so on their own initiative and are obliged to comply with all relevant legislation provisions. All visitors within and outside Turkey who use this website agree that the site is subject to the laws and regulations of the Republic of Turkey. Our company reserves the right to changeç, modify, add or remove policy provisions under the legislation. Any changes to this policy will be posted on this website. We encourage you to check our website from time to time to continue to be aware of the current state of our policy. By looking at the “Last Updated” date on this page, you can see if the policy has been revised since you last visited our site. Please read this policy and its provisions carefully. Your use of our site and/or use of our services means that you agree to be bound by the terms of this policy without any limitation, compliance or modification with the terms of our Terms of Use. If you do not agree to these terms and conditions at any time, we strongly request that you cease use of the site.

Information Gathered: Various “Personal Information” and “Impersonal Information” may be collected through our website. Personal information is information that identifies or may identify you as an individual, such as name-surname, e-mail address. Impersonal information is aggregate information, demographic information, IP addresses, and other informaion that does not direcly reveal your identity.

a. Impersonal Informations: Impersonal information is anonymous information and non-personally identifiable information. Impersonal information, Cookies, Internet Protocol addresses and web logs; pixel tags and other non-personal information, including through our website, collected from four different sources. Details on these are given below;

i) Cookies: Cookies may be used for the purposes of like most web sites, our site is a realization of a function which is essential to the operation of the site; performance analysis and enhancement of the site; ( for example, performance and accordingly determining the number of visitors to the site or visitors to find what they're looking for the settings to be done in facilitation of), providing ease of use; (e.g. recall of search queries on subsequent visits by a visitor to the site, etc.), personalization, targeting and advertising; (for example, displaying ads linked to their interests on the page that visitors view, etc.). Cookies are small text files that are stored on your device or network server through browsers by the websites you visit. Cookies are created by servers associated with the website you visit. This allows the server to understand when the visitor visits the same site. Cookies do not contain Personal Information about visitors, such as name, gender, or address. Cookies may be classified for their owners, lifetime and purpose of use;

Platform cookies and third party cookies are used by the party that placed the cookie. Platform cookies are created by Lifemed, while third party cookies are managed by different people who are partnered with Lifemed.
Session cookies and persistent cookies are used based on the time it is active. Session cookies are deleted after the visitor leaves the site, while persistent cookies can remain on the visitor’s devices for various periods of time, depending on the usage area.
For purposes of use, wealso use technical cookies, verification cookies, targeting/advertising cookies, personalization cookies and analytical cookies.

Visitors to our site always have the opportunity to personalize their preferences for cookies by changing the browser settings in which they view the site. If the browser being used ofers this option, it is possible to change the preferences for cookies through the browser settings. Thus, although this may differ depending on what the browser offers, data owners may be able to block the use of cookies, choose to receive alerts before the cookie is used, or simply disable or delete certain cookies. Preferences for cookies may neet to be made separately on each device specific to which the visitor has Access to the platform. We would also like to remind you that the various functions of the site may not work if some cookies are closed.

ii) IP Protocol Addresses and Web Logos: Collecting IP addresses is standard practice on the internet and is done automatically by many websites. We collect and store your IP address to diagnose problems with our servers, to manage our website, to ensure that you have access to the data service that will ensure your connection to the site as quickly as possible, and to provide you with a personalized experience in terms of the language used in your visits and the region accessed by the site. Our web servers automatically collect visitors’ Internet Protocol (IP) addresses and log files. Your IP address is an ID number automatically assigned to your computer by your Internet service provider (ISP). The number is automatically identified and stored in our server log files when you visit the site, along with the time of your visit and the page you visit. This information is collected in general and does not contain any personal information.

iii) Pixel Tags: We may also use “pixel tags” or similar tools and HTML-formatted e-mail messages to provide you with more useful information and a more personalized experience on your next visit to our site. A pixel tag is usually a single pixel (1x1) electronic image that visitors to our site do not normally see and can be associated with cookies on visitors’ hard drives. Pixel tags do not contain personal information and allow us to count users who visit certain pages of our site to provide branded services and help detect the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, pixel tags can tell the sender whether an e-mail has been opened.

b. Personal Information: By virtue of the Personal Information Protection Law No. 6698 has been enacted on the date of April the 7th 2016, our company thus in the capacity of Data Officer and Data Processor, personal information; within the framework described in the law and adhering to the conditions and limits described below; obtain, save, store, update, modify, reorganize, disclose, transfer, share, classify, anonymize within the scope of the purpose and scope described below e.g.Basic Law of Health Services No. 3359, Health Services Law No. 663, the Decree Law on the Organization and Duties of the Ministry of Health and its Affiliated Organizations, Regulation on Outpatient Diagnosis and Treatment, Law No. 6698 on Protection of Personal Information, Regulation on Personal Health Data, regulations of the Ministry of Health and other relevant legislation and other forms enumerated in the law.

Personal Information Processed: Your personal and private Personal Information, especially your health data: name, surname, TR Identity Number and/or passport number and/or temporary TR ID number, place of birth and/or marital status, gender, health insurance, profession, your insurance card number, business register and/or patient identification number, business register and/or patient identification number and any other identification data that may identify you; your address, telephone number, e-mail address and other contact data, personal contact data obtained by customer representatives and/or patient services by virtue of call center standards, and Personal Information obtained when you contact us by e-mail, letter and / or other means; your financial data such as billing information; your data on private health insurance for the purpose of financing and planning health care services and your data on payment institution information such as the Social Security Institution; patient medical reports, diagnostic data, biometric and genetic data, laboratory results, test results, examination data, physician analysis and comments, appointment information, prescription information including but not limited to during and / or during the execution of medical diagnosis, treatment and care services all kinds of health information and data obtained as a result, your notifications such as survey, thank-you letter, complaints letters, satisfaction results; if you use the car park, your license plate information, as required by the legislation in our medical center, the images obtained from the camera records that are constantly recorded in public areas, Özel Lifemed Tıp Merkezi; all personal data related to your health data, IP address, cookie and other Personal Information, resume provided in this case, and any Personal Information related to your service contract, which you submit and / or enter through all web sites and online services of all information and documents that serve to make the identity of our customers / patients specific or identifiable are within the scope of Personal Information pursuant to Article 3/d of the KVKK ( “Personal Information”)

Your Personal Information can be processed by Özel Lifemed Tıp Merkezi by virtue of the purposes stated in Article 2 and can be transferred to the persons , institutions and organizations stated in Article 3 within the scope of your Express consent or the reasons specified in the relevant legislation.

Purposes and Legal Reasons for Processing Personal Information: Personal Information/your Personal Information may be processed by Lifemed for the following purposes:

-To fulfill our legal obligations under the Health Services Fundamental Law no 3359, Decree Law No 663 Concerning the Organization and Duties of the Ministry of Health, the regulation on Outpatient Diagnosis and Treatment, the law on protection of Personal Information No 6698, the regulation on personal health data and other legislation and the requirements of the services you request,

- Identification and verification to prevent your Personal Information from being intercepted by others,

- Protection of Public Health, Preventive Medicine, medical diagnosis, treatment and care services, planning and management of health services and financing,

- Planning and managing daily operations with the internal functioning of our Medical Center,

-Supply you special medicines and/or medical supplies and/or devices,

- Be able to inform you about the appointment if you make an appointment, provide information and / or remind you of the appointment,

-Performance of risk management and quality improvement activities,

-Meeting legal and regulatory requirements,

- Sharing and responding to information acquired with the Ministry of Health and other public institutions and organizations in accordance with the provisions of the legislation,

- Questioning your rights with the institutions/organizations that are contracted with our Medical Center or making financial agreements with these institutions regarding the health services provided to you,

- Sharing and authentication of information requested by contracted institutions/organizations, especially private insurance companies, within the scope of financing of Health Services,

- e-invoicing, e-Archive invoicing and, if necessary, return and change transactions, issuing invoices in return for the services we offer,

- Taking all necessary technical and administrative measures within the scope of data security of the system and applications of our Medical Center,

- Analyze your use of health services to improve and improve the health services we offer you, and store your health data, and respond to any questions or complaints about our services,

- Information sharing to you through your preferred communication channel within the scope of treatment and service, identification of transaction information,

- Supply of necessary information in accordance with the demands and audits of regulatory and supervisory agencies and official authorities,

- Retain information about your health data, which must be stored in accordance with relevant legislation,

-Adaptation to domestic policies and principles,

- measuring patient satisfaction and increasing patient satisfaction after receiving health services,

- complaints/requests if you're giving permission to communicate and the ability to submit LifeMed you to take advantage of special promotional and informational activities, the provision of marketing and campaign activities of the newsletter/brochure sending data analysis-research to be done in order to inform and to communicate with you regarding our services limited to medical diagnosis, treatment and care in the execution of services, development, planning and management of health services financing, increasing patient satisfaction, investigation and related causes,

- backup/archive, storage and storage of transaction records, compliance with information retention, reporting and disclosure obligations under the provisions of the relevant legislation and the performance of our legal obligations.

Personal Information/Personal Information obtained and processed in accordance with the relevant legislation will be transferred to LifeMed's physical archives and/or IT systems and stored both in digital and physical media within the period described in this policy.

Personal Information Transfer: Your Personal Information by ensuring that all necessary technical and administrative measures are taken to ensure the appropriate level of security by virtue KVKK and the relevant health legislation; In line with the objectives in our policy; Basic Law of Health Services No. 3359, Decree Law No. 663 on the Organization and Duties of Ministry of Health and Affiliated Organizations, Regulation on Outpatient Diagnosis and Treatment 6698 Law on Protection of Personal Information, Regulation on Personal Health Data and other relevant legislation / or organizations; Depending on the payment method you prefer, the relevant Banks, online payment systems, the insurance / foundation / fund, if you have received services within the scope of the insurance company, foundation, fund and intermediary institutions, to resolve complaints and provide you with a better service to the infrastructure provider, e-invoicing / e-archieve invoicing operations to the relevant institutions / organizations and infrastructure providers, back up / storage / archiving / storage of the transaction records for the server hosting, archiving, storage and software services providers; complaints, or a problem that arises or the fulfillment of our legal obligations to Lifemed’s employees, legal, financial and tax consultants, auditors, as well as the persons allowed by the provisions of the legislation may be transferred. When transferring your Personal Information to third parties referred to in this section, a transfer will be made only to the extent necessary and relevant.

Method of Collecting and Storing Personal Information: Personal Information; for the purposes set out above; During and / or before and / or after your arrival to the health institutions within Lifemed; oral, written, visual or electronic media, phone, SMS, MMS, etc. telecommunication communication means via the Social Security Institution system online, shared records in case of benefit from the private insurance company, if you come to our Medical Center with your referral and / or if you transmit yourself, via the records of other health institutions and organizations, call center (e-mail), call center call records are collected through written, printed and similar channels such as web site, oral, journal subscription form, audio and video records made for security purposes, in automatic or non-automatic ways, in written, oral or electronic form and collected in physical and stored in a digital environment.

Lifemed, the Personal Information provided, in accordance with the provisions of the legislation in the case of a period of time foreseen by respecting the relevant periods; if such a period is not foreseen, they will only be able to keep it for as long as necessary for the purpose for which they were committed. Your Personal Information KVKK (Law on Protection of Personal Information) Article 7 / Item 1. Will be deleted, destroyed or anonymized when the purpose for processing according to 7 / f.1 has been removed and / or the statute of limitations required by us to process your data has expired.

Rights and Exceptions of the Personal Information Holder: By applying to Lifemed in writing or by other means as determined by the Board; a) find out whether your Personal Information has been processed, b) request information about your Personal Information if it has been processed, c) find out whether your Personal Information has been used for its intended purpose, e) Requesting the deletion or destruction of your Personal Information in accordance with the provisions of Article 7 of the Law; g) to object to a conclusion against you that your Personal Information is analyzed exclusively by automated systems; and i) to claim damages if you suffer damage due to unlawful processing of your Personal Information. You have. If you wish, you can also use the Information Request Form, which is published on our website https://www.lifemed.com.tr/kisisel-verilerin-korunmasi/ , which you can physically obtain from Lifemed. It is possible to exercise your rights as of 07.10.2016, the effective date of the regulation. Your Personal Information requests; a) an e-mail to our company's e-mail address kvkk@lifemed.com.tr , b) Bağdad Cd. No: 191 / A 34730 Çiftehavuzlar-Kadıköy / Istanbul, Turkey. You can send to the address via registered mail, notary public or by hand delivery method with a petition / application letter. In addition, if the Board determines other methods for the transmission of the request, you will be able to submit your request by such methods. Our company will finalize your requests in the application as soon as possible according to the nature of the request and within thirty days at the latest. However, if the transaction requires additional cost, the fee in the tariff determined by the Board may be charged. Our company has the right to accept the request or to refuse by explaining the reason and to inform the person concerned in writing or electronically. If the request in the application is accepted, Lifemed will fulfill your request. If there is a fee in case the application is due to Lifemed's fault, the fee will be returned to the person concerned. In case of rejection of the application, inadequate response or failure to respond to the application in due time; the person concerned reserves the right to lodge a complaint with the Board within thirty days from the date of learning Lifemed's reply and in any event within sixty days from the date of application. Pursuant to Article 14/2 of the KVKK (Law on Protection of Personal Information), the Company cannot apply to the Board of Complaints unless the application path is exhausted. Persons whose rights are violated shall be entitled to compensation under the general provisions.

Notwithstanding, by virtue of Article 28/2 of the KVKK; except the right to claim damages; a) Personal Information processing is necessary for the prevention of crime or for criminal investigation, b) Processing of Personal Information publicized by the person concerned c) Personal Information processing is necessary for the conduct of supervisory or regulatory tasks and for disciplinary investigation or prosecution by authorized and authorized public institutions and organizations and public institutions based on the authority granted by law. We also note that processing will not apply where it is necessary to protect the economic and financial interests of the State in relation to budget, tax and financial matters.

Cases Where Personal Information May be Processed Without Express Consent in Accordance with KVKK: In accordance with Article 5 of KVKK, your Personal Information may be processed without your express consent in the following cases:

- In cases clearly foreseen in the law,

- If you are unable to disclose your consent as a data owner due to actual impossibility, or if your consent is not granted legal validity, your Personal Information must be processed in order to protect your own or someone else's life or body integrity,

- The processing of your Personal Information belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or bankruptcy of a contract,

- To be required to fulfill a legal obligation,

- Your Personal Information has been made public by you,

- Data processing is mandatory for the establishment, use or protection of a right,

- Data processing is mandatory for the legitimate interests of Can Medikal Hizmetler A.S, provided that it does not harm your fundamental rights and freedoms.

- In addition, your personal health data may be processed by persons under the obligation to keep secrets or authorized institutions without seeking the express consent of the person concerned for the protection of Public Health, Preventive Medicine, the conduct of medical diagnosis, treatment and care services, planning and management of health care and financing.

In addition, there is no need to obtain explicit consent for disclosure, Use and transfer of information to persons/institutions that may request information in order for our company to fulfill its legal obligations arising from the legislation to which it is subject and/or due to legal obligations.

Lifemed may take the necessary security measures under the provisions of the legislation, including physical, electronic and operational measures, to ensure the security of personal information collected through the site and to prevent unauthorized Access to data.

Other Provisions: Ads that appear on our site may also be served to you by our third party advertising partners. In addition, our site may contain links to third party websites that are not owned or operated by Lifemed. We put these links only for convenience. Putting a link on our site does not mean that the site linked by Lifemed is safe and/or approved. If you voluntarily provide personal information to any such third party website, your transaction will be carried out by this third party website and the personal information you provide will be collected by that third party and controlled by their privacy policy. Lifemed is not responsible for the content of these third party websites or their privacy practices, including the use of any personal information that you provide to them. Also, Lifemed is not responsible for the privacy practices or content of other linked websites, or for the privacy policies and practices of third parties, or for the Personal Information collected, processed-transferred or used by third parties.

If you have any questions or other requests regarding our policy, you can send these questions and/or requests by e-mail to info@lifemed.com.tr address. Note that email communications may not necessarily be secure. Therefore, please do not use your credit card information or other sensitive information in your e-mail correspondence with us.

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For informational purposes.