This privacy policy and personal data protection notice shall be binding between bulutklinik.com, Bulut Klinik Teknoloji A.Ş. and the website located at “www.bulutklinik.com” and its sub-addresses (hereinafter referred to as “BULUTKLINIK”), on the one hand, and the person registering as a user or users (hereinafter referred to as the “USER”), on the other hand. BULUTKLINIK belongs to bulutklinik.com Bulut Klinik Teknoloji A.Ş., and the information security of our users visiting this website is of importance to us. For this reason, the principles we have adopted for the confidentiality and security of your personal data are set out in this privacy policy.
This privacy policy and personal data protection notice constitutes an annex to and an integral part of the User Agreement concluded with the USER.
Your use of any of the products and services offered to you by BULUTKLINIK means that you have read and accepted the principles set forth in this privacy agreement, that you have been informed of matters relating to the confidentiality and integrity of your personal data, and that you accept that legal and criminal liability shall rest with you in the event that you breach this privacy procedure.
BULUTKLINIK undertakes to keep the confidential information provided by you, the users, strictly private and confidential, and to preserve it as a secret. By this notice, BULUTKLINIK undertakes to take all necessary technical, legal and administrative measures in this respect and to exercise in full all the care incumbent upon it.
Personal Data Collected and Method of Collection
If you use BULUTKLINIK, your personal data shall not be shared with third parties unless required by the user agreement or by the applicable legislation. You have the right to update and change the information you shared during registration at any time.
Within the scope of the terms set out in this privacy policy, the following information is defined as ‘Personal Data’. Users provide the following data to BULUTKLINIK in the digital environment during membership sign-up.
Name, surname, address, telephone, business or personal e-mail address
Password and similar security information used for authentication and account access
-Information regarding users’ use of BULUTKLINIK and the application is obtained by means of Cookies, which are a necessary technical communication file. This information is obtained in order to identify access to the services offered and usage habits. It is listed below.
Browser Type
IP
Operating System
Logins to the System
Purchase History
Viewing Details
Viewing Duration
Pursuant to Articles 3 and 7 of Law No. 6698 on the Protection of Personal Data (“KVKK”), data that has been irreversibly anonymised shall not be deemed personal data under the provisions of the said Law, and processing activities relating to such data shall be carried out without being bound by the provisions of this Privacy Policy.
In addition, various feedback regarding the use of the services provided to users, information communicated by users via e-mail or telephone, and information provided by the user through the forms offered on the website constitute other data obtained.
In order for you to receive services through the website, it may be necessary for your real identity information (name/surname) to be shared with BULUTKLINIK. You shall be deemed to have warranted the accuracy and currency of the data and information about you that you provide during membership of or receipt of services from BULUTKLINIK. The information requested from you must be completed truthfully and must be updated in the event of any future change. In addition to the required identity information, sharing your Turkish Republic identity number or certain registry and tax identification information of your company may also be required during registration to our internet portal. Such sensitive information shall be used solely to confirm the accuracy of your identity information and, once your information has been confirmed, shall be protected in the website database.
Purpose of Use of Data
BULUTKLINIK may, where necessary, record the IP addresses and other contact information of users and use them for this purpose, in order to identify and resolve possible system issues in the internet portal and mobile application through which it provides services. This information is used to identify users in general terms and to generate demographic data. The traffic data retention obligations set out in Law No. 5651 and the relevant regulations are reserved.
Users’ data such as contact and demographic information shall be shared by BULUTKLINIK with its affiliates or the group companies to which it belongs, limited solely to marketing activities such as introductions, advertisements, campaigns, promotions, announcements and the like. In such cases, BULUTKLINIK shall take care to protect the interests of users.
Data provided to BULUTKLINIK by the user through the surveys and forms offered on the website, when the user is contacted, or when permission-based electronic marketing is carried out, may be used for statistical purposes.
By means of Cookies, which are a technical communication file, information regarding the user’s use of the website and mobile application, as well as IP addresses, may be obtained. The said technical communication files are small text files sent by a website to the user’s browser to be stored in the main memory. The technical communication file serves to obtain statistical information such as the number of website visitors, the purpose of the visit and the duration of the visit. Applications such as Google Analytics and Google Adwords may collect this information anonymously for the purpose of anonymous measurement and listing. Browsers are generally designed to accept these cookies by default; however, users may change this setting if they wish.
Storage and Processing of Personal Data
Personal data obtained may be transferred, stored and processed domestically or abroad, in another country where the facilities of the service providers with which BULUTKLINIK works are located, in accordance with the relevant legislation and the prescribed security measures.
Pursuant to the Personal Data Law, personal data obtained may be processed by BULUTKLINIK in compliance with the law and the principle of good faith, in an accurate and up-to-date manner, for legitimate purposes, in a proportionate manner and for periods compliant with the relevant legislation. Personal data may also be processed without the explicit consent of the data subject in the following cases.
It is expressly provided for by law
It is necessary for the protection of the life or physical integrity of the person, or of another person, who is unable to express consent due to actual impossibility or whose consent is not deemed legally valid
Processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract
It is necessary for the data controller to fulfil its legal obligation
The data has been made public by the data subject himself/herself
Data processing is necessary for the establishment, exercise or protection of a right
Data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject
Persons with Access to Data
All individual and corporate data submitted by users to BULUTKLINIK shall not be disclosed to third parties, except for the specified purposes and the mandatory cases required for the performance of the services. Mandatory cases are, within the scope of the performance of the services set out in the terms of use: ensuring user privacy and security, resolving errors and issues, improving the services, verifying user information, and research and assessments required to be carried out for the performance of the services. For these purposes, such data may be shared with third parties and institutions with which BULUTKLINIK cooperates, within the scope of the activities that are the subject of the agreement, and may be transferred to third parties domestically and abroad.
Special categories of personal data processed on BULUTKLINIK are, except for legal obligations, accessible only by the User. Neither BULUTKLINIK nor third parties may access the User’s information or the special categories of data of third parties. Such data is the property of the User.
BULUTKLINIK shall not in any way disclose to third parties the user’s name and surname, title, address, telephone number, e-mail address and any other individual / corporate information intended to identify the user, except for the purposes specified in the agreement and the mandatory cases required for the performance of the services. The cases constituting exceptions to this are listed below:
Cases where compliance is required with legal obligations under the laws in force and international agreements that are also effective in domestic law
Cases relating to the fulfilment of the requirements of the agreements between Users and BULUTKLINIK and their implementation
Where information concerning users is duly requested in the course of an inquiry or investigation conducted by the competent administrative and/or judicial authorities,
Cases where it is necessary to provide information in order to protect the rights or security of users
If the user has given permission for the sharing of his/her personal information
For the purpose of protecting and defending BULUTKLINIK’s property rights
For the purpose of determining user profiles to be used within BULUTKLINIK
Right and Method of Access to Data
By applying to BULUTKLINIK, the User has the following rights concerning himself/herself.
To learn whether personal data has been processed and, if so, to request information in this regard
To learn the purpose of processing of personal data and whether it is used in accordance with its purpose
To know the third parties to whom personal data is transferred domestically or abroad
To request rectification of personal data in the event that it has been processed incompletely or inaccurately
To request the erasure or destruction of personal data in accordance with the relevant legislation
To request that the rectification, erasure and destruction operations carried out in accordance with the relevant legislation be notified to the third parties to whom such data has been transferred
To object to the occurrence of a result to the detriment of the person himself/herself by means of the analysis of the processed data exclusively through automated systems
To request compensation for damages in the event of suffering damage due to the unlawful processing of personal data
The User may submit the above-mentioned requests in writing to the address Reşit Paşa Mh. Katar Cd. No:4 İç Kapı No:1101 - İtü Teknokent Arı-3 Sarıyer / İstanbul -. In accordance with the requests explained, BULUTKLINIK may provide its reasoned positive/negative response in writing or through digital means. As a rule, the necessary actions relating to requests shall be free of charge. However, in the event that the actions require a cost, BULUTKLINIK reserves the right to request a fee. Such fees shall be determined on the basis of the tariff set by the Personal Data Protection Board pursuant to Article 13 of the KVKK.
Status of Personal Data upon Acceptance or Rejection of the Agreement
By accepting this agreement, the User shall be deemed to have accepted the recording, storage, use and sharing with third parties of the personal data provided to BULUTKLINIK, as well as its storage abroad and its sharing with third parties located abroad, for the purposes specified within the framework of this agreement.
By accepting this agreement, Users acknowledge that they have been informed of the arrangements within this scope and that they shall be deemed to have consented to the practices.
The User acknowledges that, in the event that he/she makes a request that results in any of his/her personal data being unusable by BULUTKLINIK, he/she may be unable to benefit from the services specified in the User Agreement. The User declares that any and all liability that may arise in this context shall rest with him/her.
In the activities carried out on BULUTKLINIK, pursuant to the KVKK (Law No. 6698): Personal data belonging to Users has been processed in accordance with the procedures and principles prescribed in the legislation. Personal data is processed on the grounds that, in order for services to be provided on behalf of BULUTKLINIK, it is directly related to the establishment or performance of a contract, and furthermore that processing of personal data belonging to the parties to the contract is necessary.
With regard to ensuring the confidentiality and security of health data of third persons, special categories of personal data, patient information and all other information uploaded by the User to the cloud system belonging to BULUTKLINIK, action shall be taken in accordance with the Regulation on the Processing of Personal Health Data and Ensuring Privacy and with other legislation in force.
Data Retention Period
Personal data provided by Users shall be retained for the duration of the provision of the services, for the purpose of providing BULUTKLINIK services. In addition, in the event that any dispute arises with the User, BULUTKLINIK may retain personal data, limited to the purpose of enabling the necessary defences to be made within the scope of the dispute, for the limitation periods determined in accordance with the relevant legislation. The traffic data retention obligations set out in Law No. 5651 and the relevant regulations are reserved.
Accuracy of Data
Users acknowledge that it is mandatory to register with accurate and up-to-date information when becoming a member of the system. In the event of any change, this information must be updated. Otherwise, BULUTKLINIK shall not be liable for any resulting damages.
System Security
BULUTKLINIK shall in no way be liable for any direct and/or indirect pecuniary and/or non-pecuniary damages that may arise from the use of the BULUTKLINIK internet portal. BULUTKLINIK has taken the necessary measures to ensure that it is free from viruses and similar malicious software. However, in addition to this, users must procure their own virus protection system and provide the necessary protection in order to ensure ultimate security; by visiting the website belonging to BULUTKLINIK, the user shall be deemed to have accepted that he/she is responsible for all errors that may occur in his/her own software and operating systems and for their direct or indirect consequences.
Due to the nature of the internet, information may circulate on the internet without adequate security measures and may be obtained and used by unauthorised persons. Such use and any damage arising from such use shall not be the responsibility of BULUTKLINIK.
Security of Credit Card and Payment Information
All product or service purchase transactions carried out through BULUTKLINIK or the mobile application are performed by means of certificates. Users’ credit card information is in no way recorded or stored. This information is encrypted with the protocol and transmitted directly to the relevant bank. The user’s payment information is used solely for the purpose of invoicing the user for the service or product purchased. This personal data is also protected by being stored with the protocol.
Links to Third-Party Websites
We may provide links on our internet portal to other websites that are not operated by BULUTKLINIK. When visiting any of these websites, you browse within the scope of the security policies and terms of use of the website you visit. BULUTKLINIK is not responsible for the policies and practices of the said websites.
Security of Passwords and Liability
The passwords of all users registered with BULUTKLINIK are secured by special encryption techniques. However, the security of the passwords held by the user, his/her assistants and the personnel employed by them is entirely the responsibility of the user. The password must be known only by the user. The legal and criminal liability that will arise in the event that the password falls into the hands of unauthorised third parties shall rest with the user.
Amendments to the Agreement and System Features
BULUTKLINIK reserves the right to change, suspend or discontinue the use of all products and services on the website, the pricing of website use, the information and the visual elements without prior notice.
BULUTKLINIK reserves the right to make amendments and updates to this agreement. In such a case, the amendments shall enter into force upon publication on the website. It is the responsibility of the user to follow the current version of the agreement.
BULUTKLINIK has unilateral discretion during member registration. It reserves the right to decide unilaterally not to accept any persons or companies it wishes as members of the website and to remove them from membership when it deems necessary. The accounts of users deemed inappropriate by the administrators may be closed or their memberships suspended without notice.
Intellectual Property Rights
All rights relating to BULUTKLINIK’s name rights, content, templates, design and all documents, programs and scripts within the website are reserved. Unless otherwise stated on the pages, no document page, graphic, design element or other element within BULUTKLINIK may be copied, moved elsewhere, quoted, published on the internet or through any publication medium, or used without permission.
Permission-Based Electronic Communications
BULUTKLINIK may, as regulated by law, communicate with users via e-mail, SMS or telephone, send permission-based newsletters, carry out marketing, send communications on behalf of third parties, and collect data from these communication activities for statistical purposes. By accepting this agreement, the User shall be deemed to have consented to being contacted through these means and to receiving commercial electronic communications. Users may, if they wish, stop the sharing of the data for which they have given permission and cease to receive commercial electronic communications.
Disclaimer of Warranty
Notwithstanding the measures taken by BULUTKLINIK for the purpose of system security, BULUTKLINIK provides the services on an “as is” basis, does not undertake that they will operate without issues under all circumstances, and is not liable for errors that may occur in the services. BULUTKLINIK shall not be liable for any data loss that may arise due to any change, suspension or termination made on the system, or merely due to the use of the system.
Dispute Resolution
In the event of a dispute concerning the principles set out in this agreement, the competent courts and enforcement offices shall be the Istanbul Anatolian Courts and Enforcement Offices.