Privacy Policy

At Turclinics, we respect your privacy and are committed to being transparent about what data we collect when you visit and use our Directory and our medical tourism directory at www.turclinics.com (our “Directory”) and how it is used.

This Privacy Policy applies only to our Directory and should you contact or visit the website of one of our selected Clinics, the relevant Clinic’s privacy policy applies. In such cases, we recommend that you read the relevant Clinic’s privacy policy.

General Information

  1. What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website. 

  1. What is Special Category Data?

Special Category Data means Personal Data that needs more protection because it is sensitive. This includes among others data concerning health and medical information. In order to lawfully process Special Category Data, it is necessary to consent to the processing.

  1. What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

  1. What law applies?

In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the UK’s Data Protection Act (“DPA”) and the EU's General Data Protection Regulation (“GDPR”).

  1. Who is responsible for data processing?

The responsible party for data processing is Turclinics of "AA HOUSE 311 27 OLD GLOUCESTER STREET LONDON UNITED KINGDOM WC1N 3AX" (“Turclinics”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, you can reach us via email using support@turclinics.com, or write to us at the above address.

  1. What are the legal bases of processing?

We only process your Personal Data if we at least one of the following applies:

  • you have given your consent,
  • the data is necessary for the fulfilment of a contract / pre-contractual measures,
  • the data is necessary for the fulfilment of a legal obligation or
  • the data is necessary to protect our legitimate interests, provided that your interests are not overridden. 

Data we collect automatically

  1. Log data

Each time you visit our Directory, our system automatically records the following data from the visiting device and stores it in a so-called log file: 

  • Name of the retrieved file, 
  • date and time of the visit,
  • amount of data transferred,
  • message about successful retrieval, type of browser and version used, 
  • IP address (identification of the user's device),
  • Operating system of the visiting device, 
  • Internet service provider of the visiting device, 
  • website from which you access our Directory, and 
  • which of our Directory pages you are accessing. The legal basis for processing is our legitimate interest.
  1. Hosting

To provide our Directory, we use the services of turhost.com (Aerotek Bilişim Sanayi ve Ticaret AŞ) who process all data to be processed in connection with the operation of our Directory on our behalf. The legal basis for the data processing is our legitimate interest in providing our Directory.

  1. Economic analyses and market research

For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.

  1. Cookies

We use so-called cookies on our Directory. 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. 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.

  1. Cookie consent 

Our Directory uses a to obtain your consent to the storage of certain cookies on your end device or to the use of certain technologies and to document this consent. When you enter our Directory, the following Personal Data is transferred to us:

  • Your consent(s) or revocation of your consent(s)
  • Your IP address
  • Information about your browser
  • Information about your terminal device
  • Time of your visit to the website

This is required and ensures that we only process the Personal Data of our Directory visitors in accordance with their instructions. The legal basis for processing is our legal obligation.

Data we collect directly

  1. General

We may ask you for Personal Data when you:

  • use our Directory and services,
  • request services, support, or information form a clinic that is listed (we and the respective clinic are jointly responsible for the processing of your data and enter into a so-called joint-controller agreement),
  • participate online or otherwise in marketing and advertising activities,
  • subscribe to Turclinics`s marketing and promotional emails or other materials,
  • interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
  • contact us.

In order to provide you with a more consistent and personalised user experience in your interactions with Turclinics, data collected through one source may also be linked to other data collected by Turclinics through other sources. This may include data that helps us identify you when you access our Directory through several different devices.

  1. Contacting us

In addition to your name, e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.

  1. Use of our listing services

If you wish to use our listing services and its features, we process the Personal Data you voluntarily provide for the purpose of introducing you to our selected Clinics and providing you with details to make informed decisions about your medical tourism journey. Depending on how you use our listing services, you may provide certain details such as your contact information to your chosen Clinic(s). 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 or medical needs and expectations. As a rule, your chosen Clinic(s) does not require any Special Category Data in order to contact you. By choosing to provide this data, you consent to the processing of that data. You have choices about the data you provide and how you share it. The legal basis for processing of your Personal Data and Special Category Data is the establishment and implementation of the user contract with your chosen Clinic(s) as well as your consent. 

  1. Registration as a Clinic Account

On our Directory, we offer Clinics the opportunity to register an account. The data is entered into our registration form and transmitted to us and stored. The data is not passed on to third parties. The following data is collected as part of the registration process:

  • Company Name
  • First name/ last name 
  • Email address 
  • Password

The following data is also stored at the time of registration:

  • The IP address of the user
  • Date and time of registration

The legal basis for processing is consent and the fulfilment of a contract. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. As a Clinic, you have the option at any time to delete your registration with us. You can change your data stored with us at any time independently and / or delete or have deleted. If the data is necessary for the fulfilment of a contract or for the execution of pre-contractual measures, an early deletion of the data is only possible, as far as contractual or legal obligations do not oppose a deletion.

  1. Information that we share with others

You share information with other users when you voluntarily disclose information on the service (including your clinic profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.

  1. Information that we receive from others

In addition to the information you provide to us directly, we receive information about you from others, including other users who provide us with information about you. For example, when they leave a review about your services. The legal basis is the fulfilment of the user contract for the use of the platform as well as your consent. 

  1. Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. 

Social Media 

We have a presence on social media based on our legitimate interests. If you contact or interact with us via social media platforms, we and the respective 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 contractual performance, if any.

Marketing

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

Principles of processing Personal Data

  1. Storage and Retention

We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with UK`s retention periods for up to 6 years. 

  1. Security

Our Directory uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website. 

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

  1. Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

  1. International Transfer

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer. 

  1.  What we do not do
  • We do not request Personal Data from minors and children;
  • We do not use Automated decision-making including profiling; and
  • We do not sell your Personal Data.

Your Rights and Privileges 

You can exercise the following rights:

  • Right to information
  • Right to rectification
  • Right to object to processing
  • Right to deletion
  • Right to data portability
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

  1. Updating your information and withdrawing your consent 

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object (including withdrawing of consents you have given us) to its processing, please do so in your account or by contacting us. 

  1. Access Request 

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

  1. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office (“ICO”) www.ico.org.uk and the supervisory authority in Turkey is: The Turkish Personal Data Protection Authority (“KVKK”) www.kvkk.gov.tr. However, we would appreciate the opportunity to address your concerns before you contact the ICO/ KVKK or any other supervisory authority.

Changes 

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will revise the effective date. This Privacy Policy was last updated on Sunday, 10th of March, 2024.

Questions

If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.