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Disclosure Text on Processing of Personal Data

At INVICTUS, we attach importance to the protection of the personal data of our valued users and the persons we cooperate with. This disclosure text has been prepared to explain the procedures and principles regarding the processing of personal data in accordance with the Law on Protection of Personal Data No. 6698 (KVKK) and to provide information.

Within the scope of KVKK, INVICTUS is accepted as "Data Controller".

1. WHAT IS PERSONAL DATA AND SPECIAL CATEGORIES OF PERSONAL DATA?

According to KVKK No. 6698, Personal Data means any information relating to an identified or identifiable natural person. Special Categories of Personal Data refers to data regarding your race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, dress and appearance, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and specific data regarding your biometric and genetic data.

2. HOW IS PERSONAL DATA COLLECTED?

INVICTUS may obtain personal data of persons with whom it has a relationship for any reason, from all kinds of written, verbal and electronic media, third parties and/or legal authorities. Collected personal data may be processed in accordance with KVKK for the purposes specified below.

3. FOR WHAT PURPOSES IS PERSONAL DATA PROCESSED?

As a rule, your personal data is processed by your explicit consent. However, pursuant to Articles 5.2 and 6.3 of the KVKK, it may be processed in permitted exceptional cases without seeking your explicit consent.

Your collected personal data;

  • Fulfillment of INVICTUS's legal obligations pursuant to the Basic Law on Health Services, Social Insurance and General Health Insurance Law, Medical Laboratory Regulation, Regulation on Personal Health Data and other relevant legislation,
  • Sharing of many personal data such as heart rate and rhythm, body temperature, blood pressure, respiratory rate, oxygen and stress levels, blood sugar amount, sleep patterns collected through wearable technological products, which are the main activity subject of the application, with doctors, life coaches, health professionals selected by users and/or other persons selected by the user, providing the service of follow-up by doctors selected by the user and performing necessary tests and examinations by doctors, (The sole responsibility of the COMPANY in this process consists of analyzing the data flowing into the application after tracking it and transferring it to the doctor. The responsibility of the COMPANY ends with the performance of the necessary analyses. Subsequent developments are between the doctor and the user. The COMPANY has no responsibility. Delays that may occur in servers may be caused by the manufacturer firm Huawei, and the COMPANY is not responsible for negative situations that may occur due to these delays.)
  • Providing, sending and transferring documents and results related to relevant services,
  • Planning and managing INVICTUS's internal functioning and service presentation,
  • Fulfillment of risk management and quality improvement operations,
  • Sharing requested information with private insurance companies and institutions within the scope of financing health services,
  • Identity verification,
  • Performing invoicing transactions,
  • Sharing requested information and documents with the Ministry of Health and other regulatory and supervisory institutions pursuant to relevant legislation,
  • Ensuring the physical space security of INVICTUS,
  • Realization of all kinds of commercial activities carried out by the Company,
  • Planning and execution of Company activities, operational processes and order tracking,
  • Follow-up, planning and execution of finance and accounting transactions,
  • Obtaining after-sales support services for goods or services purchased by the Company,
  • Planning and execution of corporate communication activities,
  • Ensuring business continuity,
  • Management and execution of relations with business partners and/or suppliers,
  • Creation and execution of information technologies,
  • Ensuring the security of Company headquarters and/or offices,
  • Ensuring the legal and commercial security of the Company and persons in business relations with the Company,
  • To perform identity determination of employees,
  • To contact employees or their family relatives in cases of necessity,
  • To make position changes within the Company,
  • To develop, manage and improve human resources, finance, accounting processes within the Company,
  • To fulfill legal obligations regarding the maintenance of the employment relationship and to maintain the employment relationship,
  • To ensure physical space security within the workplace,
  • To document the use of leave during working hours due to the legal transactions of the personnel,
  • To determine whether there is a health obstacle for the personnel to perform the position they work in,
  • To conduct research on employee candidates,
  • To contact the employee candidate, to evaluate whether they are suitable for the position within the company in terms of both required knowledge and professional experience and physical health status,
  • To develop, manage, improve human resources processes within the Company and to carry out employment relationship processes easier for candidates who transfer to employee status,
  • For the purposes of fulfilling other legal obligations, pursuant to Article 5 of the KVKK; based on the legal grounds of "it is expressly provided for by the laws, it is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract, it is mandatory for the data controller to fulfill its legal obligation, and it is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject", it may be collected and processed in accordance with KVKK No. 6698 through written/verbal/electronic/digital methods within the scope of e-mail channels and other applications, as well as information transferred to our company by establishing a legal relationship with our company, information to be obtained under a contract where you are a mutual party with our company or situations where you apply for a job to our company.

4. TO WHOM MAY YOUR PERSONAL DATA BE TRANSFERRED?

Your personal data may be transferred to legally authorized public institutions and organizations, legally authorized private law legal entities, our business partners, our shareholders, our company officials, our employees, contracted health institutions, doctors selected by you through the application and registered in the system, within the direction of the purposes mentioned in this disclosure text.

Your data is stored by the main service provider Huawei via servers located in Germany, and your data is transferred abroad only at the point of data storage. You need to examine the existing foreign data storage text in detail regarding this.

WHAT ARE THE RIGHTS OF DATA OWNERS?

Personal data owners have the following rights pursuant to Article 11 of the KVKK; a) To learn whether personal data is processed, b) To request information if personal data has been processed, c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose, d) To know the third parties to whom personal data is transferred domestically or abroad, e) To request correction of personal data in case of incomplete or incorrect processing, f) To request deletion or destruction of personal data within the framework of the conditions stipulated in Article 7, g) To request notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred, h) To object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems, i) To request compensation for the damage in case of loss due to unlawful processing of personal data.

HOW IS THE APPLICATION PROCESS TO THE DATA CONTROLLER?

You must submit your requests regarding your rights listed above to our company by filling out the application form at http://www.heartincare.com or by sending a written document to the COMPANY at the open address on the http://www.heartincare.com website via post or to one of the [email protected] e-mail addresses. The COMPANY, as the data controller, concludes the requests in the application free of charge as soon as possible and within thirty days at the latest depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged.

"I ACCEPT THAT I HAVE READ AND UNDERSTOOD THE INVICTUS PERSONAL DATA PROTECTION POLICY AND THE CUSTOMER AND/OR SUPPLIER / BUSINESS PARTNER EXPLICIT CONSENT TEXT AND I APPROVE ALL THESE TEXTS WITH MY OWN CONSENT."

* This document is for informational purposes.