Pariwa Teknoloji Anonim Şirketi Personal Data Privacy
Policy and Privacy Notice
Introduction
For Pariwa Teknoloji Anonim Şirketi (“we” or “Pariwa”),
protecting privacy and processing personal data lawfully are of the highest
priority, and we commit to safeguarding your privacy. This privacy policy
explains how your personal data are collected, processed, stored, and disclosed
by us. It applies to the processing of your personal data on our website,
platform, and mobile application (collectively, the “Services”). We recommend
that you read this privacy policy carefully before using any of our Services.
We may amend this privacy notice from time to time,
particularly if your rights or fundamental freedoms may be affected due to any
changes in our activities or in applicable laws and regulations. Where such
changes require your consent under applicable data protection legislation, we
will contact you to obtain your consent before the changes take effect.
Who We Are
We are Pariwa Teknoloji Anonim Şirketi, registered at
Kavaklıdere Mahallesi, İncir Sokak No:25/1, Bornova–İzmir. We operate the
“https://www.pariwa.com” platform and ensure continuity of the service.
Pursuant to Law No. 6698 on the Protection of Personal Data
and in our capacity as the data controller, we are obliged to protect your
personal data in accordance with the provisions of the Personal Data Protection
Law.
You can contact our Personal Data Protection Officer
(“PDPO”) by sending an email to iletisim@docplanner.com, by submitting your
questions via mail to our registered office address, or through another method
permitted under applicable legislation.
User-Specific Sections
I. IF YOU ARE A PATIENT/CLIENT (A NON-PROFESSIONAL USER
OF OUR PLATFORM)
If you are a patient/client, or more generally a user who
visits our website to obtain information about physicians/specialists, the
following information applies to you:
A) How do we obtain your personal data; for what purposes
and on what legal basis do we process them?
1. Registering for our Services
When you register on our website or use our Services, we
obtain your personal data directly from you.
When you register for our Services, we ask you to provide
basic personal data, including your email address. You also have the option to
register using social media platforms such as Facebook or Google. In that case,
you will be asked to allow such third-party providers to share certain personal
information with us (as indicated on the registration page).
You may also provide additional information about yourself
such as your first name, last name, gender, and phone number. We will store
this information to enable you to use the Services.
You can use our Services via our website or mobile
application. Our Services enable you, among other features, to: schedule
appointments with physicians/specialists; have online consultations with
physicians/specialists; send messages to physicians/specialists; and rate your
experience with a particular physician/specialist. You can also review your
visit history and manage your user account through our platform and mobile
application.
In your mobile user account, you can manage push
notifications (e.g., pop-up windows) and other similar system notifications. If
you choose not to receive such notifications, you can disable them through your
account settings.
When you register to use our Services, you enter into a
legally binding contract with us. This contract constitutes a legal basis for
processing your personal data pursuant to Article 5(2) of the Personal Data
Protection Law.
In addition to the legal condition of being directly related
to the establishment and performance of a contract, your personal data may also
be processed in accordance with other legal conditions set out in Article 5(2)
of the Personal Data Protection Law. These conditions are that processing is
necessary for us, as the data controller, to comply with our legal obligations,
and processing is necessary based on our legitimate interests as the data
controller. For processing activities that require consent, such processing
will be carried out only upon obtaining your explicit consent, within the scope
of Article 5(1) of the Personal Data Protection Law.
2. Scheduling an appointment or examination with a
Physician/Specialist
If you schedule an appointment or examination with a clinic
or physician/specialist via our website or mobile application, we obtain
additional information from you electronically through the platform you use.
This information may include:
We will store these data on our platform solely for the
purposes of enabling you to view, cancel, or reschedule your appointment and
transferring these data to the physician/specialist or the clinic where the
physician/specialist works. After your personal data are transferred to the
physician/specialist or the clinic, they become the data controller of your
personal data and process your personal data for their own purposes (for
example, to provide medical or similar services). Such processing will be subject
to the relevant physician’s/specialist’s or clinic’s privacy policy and privacy
notice.
If you schedule an appointment or examination with a
physician/specialist or clinic listed on our platform, we may process certain
personal data that may relate to health (in particular: the
physician/specialist or clinic you will visit; the reason for your visit; your
past visits) (e.g., storing them and sharing them with the physician/specialist
or clinic). Therefore, before we process or transfer such health-related
personal data, we will request your consent. Your consent is required for
sharing your data with the physician/specialist with whom the appointment is
booked and for providing our appointment and technical Services to you. If
consent is not given, we cannot provide you with our appointment and technical
Services. Processing of your health-related personal data based on your consent
is in accordance with Article 6(2) of the Personal Data Protection Law.
If you schedule an appointment or medical examination with a
physician/specialist, we will share your personal data with those
physicians/specialists, who also become data controllers with respect to those
data. Any processing by the physician/specialist or clinic will be subject to
that physician’s/specialist’s or clinic’s privacy policy or privacy notice.
We may send an appointment confirmation to your mobile phone
or email address. We may also send you a reminder when your appointment date
approaches. If the appointment is cancelled by the physician/specialist, we
will inform you accordingly. After the appointment, we may ask you to leave a
review on our website. Reviews are optional, and such reviews will be obtained
and published based on your consent.
Before the appointment, physicians/specialists may send you
a questionnaire regarding your symptoms or reason for the visit. Completing the
questionnaire is of course optional; however, it may help the
physician/specialist prepare for your appointment/examination. The
questionnaire is sent by physicians, and the responses are delivered only to
them: we do not see the responses and we do not process the personal data
contained in such questionnaires. Any processing of personal data entered into
such questionnaires will be subject to the relevant physician’s/specialist’s or
clinic’s privacy policy or privacy notice.
3. Storage of your personal data and sharing with
physicians
As part of our Services, we enable you to store your
personal data in your user account. This functionality, among others, provides
you with the following:
In addition, through your Health Profile in our mobile
application, we enable you to store health-related personal data in your mobile
application account. This functionality, among others, provides you with the
following:
When you add personal information, we will request your
explicit consent to process your health-related personal data. Your personal
data are processed and transferred based on your consent solely for the
purposes of providing you with the storage functionality described above and
sharing those data with the physicians/specialists you select. Your personal
information will not be used by us for any other purpose, and such data will
not be sold or transferred to third parties without notifying you. Your consent
is optional and may be withdrawn at any time upon request. If you withdraw your
consent, the health-related personal data you uploaded to your user account
will be deleted by us.
If you create an appointment using our platform, you will
have the ability to share all or part of this information with the specialist
physician. You decide which of your data you want to share with each specialist
physician. Sharing your data with specialist physicians is optional, but it may
help the physician prepare for your appointment/examination. We will obtain
your consent before sharing your data, and we will share your data only with
the physicians/specialists to whom you decide to grant access to your Health
Profile. Only if consent is given will the personal data you select be shared
with the specialist physician. Please note that if your health-related personal
data are shared with physicians/specialists, those physicians/specialists act
as separate data controllers and process your personal data in accordance with
their own privacy policies.
To enable the storage feature in our mobile application, you
are required to share your first name, last name, and email data with us.
In addition, if you add them to the storage feature, we may
collect your phone number, identity information, health insurance (if any),
allergies, medical history, family medical history, medications taken, and
information related to your previous visits. For clarity, we will process your
health-related personal data only if you decide to add them. You are free to
add the data you deem appropriate; there is no minimum or mandatory data
requirement in this regard.
Transfer of your data based on your consent is in accordance
with Article 8 of the Personal Data Protection Law.
4. Starting a chat with a Physician/Specialist and/or
sending messages
While using our platform, you may start a chat with
physicians or send them private messages. When you use this functionality, we
will be aware that a chat is taking place; however, since these data are
end-to-end encrypted, we cannot access the information you provide to the
specialist during the chat or conversation.
You can access your chat history, your questions, and the
specialists’ answers at any time.
Before using the chat option, your consent will be requested
by us, and your personal data for the conversation and messaging options will
be processed pursuant to Articles 5(1), 5(2), and 6(2) of the Personal Data
Protection Law.
When necessary, we may provide additional privacy notices
and consent options regarding the use of the chat and messaging
functionalities.
5. Adding a review
If you add a review about a physician on our website, we may
obtain certain personal data about you (for example, if you mention your reason
for the visit or your medical history in the review). For this reason, your
consent is obtained for the processing of your health-related personal data.
Processing of your health-related personal data based on your consent is in
accordance with Article 6(2) of the Personal Data Protection Law.
Please be aware that your reviews are public. We recommend
that you do not include any private or similar sensitive information in your
review, as such information will not be hidden and will be visible to all users
of the platform.
6. Marketing
If you consent to receive marketing and commercial
communications, your email address, phone number, first name, and last name may
be processed by us for this purpose. You may opt out of receiving such
communications at any time. The legal basis for processing your personal data
for this purpose is Article 5(1) of the Personal Data Protection Law.
7. Other purposes
While using our Services, we may obtain additional data that
include information about your device, IP address, time zone and language, or
the browser you use. We may also obtain information about when you first and
last used our Services and how much time you spend while using our Services.
While using the mobile application, we may also obtain your
location information based on GPS data.
Our purposes for processing these personal data are:
We process these data pursuant to Article 5(2) of the
Personal Data Protection Law, in cases where processing is necessary for the
establishment and performance of our contract with you, for the establishment,
exercise, or protection of a right, for fulfilling our legal rights and
obligations, and based on our legitimate interests.
B) Do we process information and data related to your
health?
If you schedule an appointment or examination with
physicians/specialists, add a review, or start a chat with a
physician/specialist, we may learn information about your health status. We may
also act as a data processor on behalf of specialist physicians and clinics who
authorize us with respect to your health-related personal data. For more
details, please review the section above titled “How do we obtain your personal
data; for what purposes and on what legal basis do we process them?” and the
section below titled “Do we act as a data processor on behalf of
Physicians/Specialists and clinics?”.
C) Are there cases where you provide us with personal
data about other persons?
If you schedule an appointment on behalf of someone else
(for example, scheduling an appointment for a family member), we may obtain
that person’s personal data. We process such personal data for the same
purposes as those for which we process your personal data.
If you provide personal data about another person, you are
responsible for informing that person and, where necessary, obtaining their
consent.
D) Do we act as a data processor on behalf of
Physicians/Specialists and clinics?
We provide various services to physicians and clinics. These
services allow physicians and clinics, among other purposes, to upload and
store personal data of their patients. These services also enable sending
messages or emails and marketing campaigns to patients, and are used by
physicians and clinics to manage their work schedules.
For all these reasons, we act as a data processor and
process personal data of their patients in accordance with their instructions.
When we act as a data processor, we process personal data
only in line with the instructions of physicians and clinics (our customers),
and we do not process the relevant personal data for our own purposes. This
also applies to information about specialist physicians and clinics sent to you
through our platform, messages, email or similar communication methods, or
campaigns. It is not us but them who decide whether you will receive messages,
emails, or similar campaigns. We do not accept any responsibility for such
communications or for the processing of your personal data by physicians or
clinics.
If you do not wish to receive any messages, please contact
the physician or clinic that sends you the communication directly.
II. IF YOU ARE REGISTERED AS A PHYSICIAN/SPECIALIST
If you are a physician who uses our platform and Services in
your capacity as a specialist and (i) you have created a profile on the
platform, (ii) you have entered into a contract to obtain our Services, or
(iii) you work within or on behalf of a clinic that has entered into a contract
with us to obtain our Services, you are subject to the following:
A) How do we obtain your personal data? For what purposes
and on what legal basis do we process them?
1. Becoming a member of our Services and using our
Services
We obtain your personal data directly from you when you use
or register for our Services.
When you register for our Services, we ask you to provide
data related to your professional activities and other information that will
help us inform our users about you and will be published on your profile on our
platform. In particular, you may provide us with the following information:
If you have entered into a contract to obtain our Premium,
SaaS and/or other similar paid Services and/or if you have enabled the
appointment calendar and/or telemedicine feature on our platform, you may also
provide us with detailed information about your calendar, your service pricing,
and the payment methods you accept from your patients.
When you register for our Services, you enter into a legally
binding contract with us. Our obligation to perform and comply with our
obligations under that contract constitutes a valid legal basis for processing
your personal data, as set out in Article 5(2) of the Personal Data Protection
Law. In addition, as the data controller, we also process your personal data as
required by our legal obligations—for example, issuing invoices and keeping our
financial records up to date. This constitutes an appropriate legal condition
for processing your personal data under Article 5(2) of the Personal Data
Protection Law.
We also collect your personal data from clinics that have
entered into a contract with us to receive Services from us and within which
you work or with which you cooperate. These clinics may transfer your personal
data to us in line with their own responsibilities, and we process your
personal data in order to perform the contract we have entered into with the
clinic. Processing your personal data is very important to us; however, you may
always contact the clinic that transferred your personal data to us and object
to the processing, or withdraw the consent you provided for the use of your
personal information.
2. For marketing purposes
If you choose to receive marketing and commercial
communications, we may process your email address, phone number, first name,
and last name for this purpose. You can unsubscribe from receiving these
communications at any time. The legal basis for processing your personal data
for this purpose is Article 5(1) of the Personal Data Protection Law.
3. Other purposes
When you use our Services, we may obtain additional data,
including information about your device, IP address, time zone and language, or
the browser you use. We also obtain information about when you first and last
used our Services and how much time you spend while using our Services.
When using the mobile application, we may also obtain your
location information based on GPS data. You can disable your location
information at any time.
Our purposes for processing these personal data are:
We process these data pursuant to Article 5(2) of the
Personal Data Protection Law, in cases where processing is necessary for the
establishment and performance of our contract with you, for the establishment,
exercise or protection of a right, for fulfilling our legal rights and
obligations, and based on our legitimate interests.
Information applicable to all users
Do we share your personal data with third parties?
Only for the purpose of providing services to you, we may
disclose your personal data to other companies that are part of the Docplanner
Group.
If you have permitted, based on your explicit consent, that
your personal data be shared with a physician/specialist, we will share the
data you chose to share with the relevant physician/specialist.
We may also share your personal data with third-party
providers solely for the purpose of providing our Services to you. These third
parties act as data processors and have entered into a data protection
agreement with us.
For example, we may share your personal data with the
following categories of data processors:
Finally, we may disclose these data to respond to legal
requirements, enforce our policies, communicate with judicial or regulatory
authorities where required by applicable law, and protect our rights and
property. We may also share your personal information with such commercial
entities if we plan to merge with, be invested in by, or be acquired by a
business, or if we undergo a corporate restructuring.
Unless you have given us prior consent, we will not transfer
your personal information to any other third party.
Do we transfer your personal data to countries outside
the European Economic Area?
Some of our service providers (data processors) are located
outside the European Economic Area, therefore we may transfer your personal
data to third countries. We ensure that such transfers always meet the
requirements of applicable data protection law, including the GDPR and the
Personal Data Protection Law.
Do we transfer the personal data of users in Turkey to
countries outside Turkey?
Since other group companies within the DocPlanner Group and
some of our service providers (data processors) are located outside Turkey, we
must transfer your personal data outside Turkey in order to provide services
via doktortakvimi.com. In accordance with the relevant provisions of the
Personal Data Protection Law, we will obtain your consent before transferring
your personal data. Under the Personal Data Protection Law, we request your
consent for such cross-border data transfers. If you do not provide your
consent, we will not be able to provide you with our Services. Transferring
your personal data in accordance with your consent is compliant with Articles
5, 6, and 9 of the Personal Data Protection Law.
For how long do we process your personal data?
We will retain the data we collect about you only for as
long as necessary for the purposes described above or for as long as required
to comply with our legal obligations. The period for which we retain
information about you will vary depending on the type of information and the
purposes for which we use it. In general, we retain our records for up to 6
years after you end your relationship with us in order to comply with our
legal obligations. For more details, please see the table below:
Purpose of processing — Retention period
What are your rights regarding the processing of your
personal data?
Under the Personal Data Protection Law, you have the
following rights:
If you would like to exercise any of these rights, you can
contact us (via the contact details at the end of this notice). We will fulfill
our legal obligations regarding your rights as a data subject.
A request for access to your personal data must be made in
writing or in another manner permitted by applicable legislation. We will try
to respond to your requests within a reasonable time and in any case within 30
days as required by the Personal Data Protection Law. To the extent
permitted by the legislation and guidelines published by the Personal Data
Protection Authority, we reserve the right to request a reasonable fee
reflecting the cost of providing you with information.
We aim to ensure that the information we hold about you is
always accurate. To help us keep your information up to date, you will need to
notify us of any changes in your personal information. Upon your request, we
will take reasonable steps to ensure accuracy and will correct inaccurate
personal data promptly and in any case within one month of your request.
Do we carry out profiling activities?
We do not make any decisions based solely on automated
decision-making processes. We do not use any profiling system or tool to
process your data.
Links to Other Sites
Our website or application may contain links to other
websites, including via social media buttons. While we try to link only to
websites that reflect our high standards of privacy and respect for
confidentiality, we are not responsible for the content, security, or privacy
practices used by other websites, and such links do not mean we endorse those
websites. When you create a link from our website or application to another
website, you are subject to that website’s terms and conditions, including (but
not limited to) its internet privacy policy and practices. Please check those
policies before submitting any data to those websites.
How do we protect your information?
We implement appropriate technical, physical, electronic,
and administrative measures to protect your personal data against unauthorized
access. We follow generally accepted industry standards to protect personal
information submitted to us both during transmission and after we receive it.
However, unfortunately, transmission of information over the internet
(including by email) is not completely secure. Although we commit to doing our
best to protect your personal data, we cannot guarantee the security of your
data transmitted to our website, platform, or personnel; therefore, any
transmission is at your own risk. Once we receive your information, we will use
strict procedures and security measures to prevent unauthorized access.
