Website Confidentiality Agreement:

How to use and protect the information we obtain about you and the services you request while your visit to this website and benefit from the services we provide through this site are subject to the conditions set forth in this "Confidentiality Policy". By visiting this website and requesting to benefit from the services we offer through this website, you accept the terms set forth in this "Confidentiality Policy". 

I. Purpose of personal data protection and processing policy:

As Hattuşa Sağlık Termal A.Ş., the data received from our customers or prospective customers have been kept confidential and never been shared with third parties due to the sensitivity of the work we have been dealing with. Protection of personal data is the basic policy of our company. Even before there was any legal regulation, our companies and affiliates attached great importance to the privacy of personal data and adopted this as a working principle and gave their employees working instructions in line with this principle. As Hattuşa Sağlık Termal A.Ş., we undertake to comply with all responsibilities brought by the Law on the Protection of Personal Data. Our company's principles regarding the protection of personal data also cover our affiliates. 

II. Scope and modification of the personal data protection and processing policy:

This Policy, prepared by our company, has been prepared in accordance with the Law on the Protection of Personal Data No. 6698. The law has entered into force with all its provisions as of today. The data obtained from you with your consent or in accordance with other laws listed in the Law will be used to improve the quality of the services we provide, to improve the services offered to you and our quality policy. Some of the data we have is depersonalized and anonymized. These data are data used for statistical purposes and are not subject to Law and our Policy. The Personal Data Protection and Processing Policy of Hattuşa Sağlık Termal A.Ş aims to protect the data obtained automatically from our customers, prospective customers, employees and customers and employees of companies working in partnership with us or other persons, and includes regulations related to these. 

Our company has the right to change our policy and Regulation - provided that it is in compliance with the law and that personal data is better protected. 

III. Basic rules regarding the processing of personal data

a) Compliance with the law and honesty rules: Hattuşa Sağlık Termal A.Ş questions the source of the data it collects or comes from other companies and attaches importance to obtaining them in accordance with the law and good faith. Within this framework, it makes necessary warnings and notifications to third parties (agencies and other intermediary institutions) that sell the services provided by Hattuşa Sağlık Termal A.Ş to protect personal data. 

b) Being accurate and up-to-date when necessary: Hattuşa Sağlık Termal A.Ş attaches importance to the fact that all data within the organization are correct, do not contain false information and finally, if there are changes in personal data, they are updated if they are communicated to them.

c) Processing for specific, explicit and legitimate purposes: Hattuşa Sağlık Termal A.Ş processes data only for the purposes it provides and obtains consent from individuals during the service. It does not process, use and make available data other than business purposes.

d) Being connected, limited and restrained for the purposes for which they are processed: Hattuşa Sağlık Termal A.Ş uses the data only for the purpose for which they are processed and to the extent required by the service.

e) Keeping for the period stipulated in the relevant legislation or required for the purpose for which they are processed:

Hattuşa Sağlık Termal A.Ş preserves the contractual data for the duration of the dispute, the commercial and tax law requirements. However, when these purposes disappear, it deletes or anonymizes the data.

It is important to note that whether Hattuşa Sağlık Termal A.Ş collected or processed data in accordance with the consent or law, these principles that we have listed above still apply. 

According to article 11 of the Personal Data Protection Law, you have the following rights. In order to facilitate these rights, an application form has also been prepared by Hattuşa Sağlık Termal A.Ş for you.

Persons whose personal data are processed have the following rights regarding their own data by applying to the contact person announced on our website by Hattuşa Sağlık Termal A.Ş;

a) Inquiring whether your personal data is processed or not,

b) If personal data has been processed, requesting information about it,

c) Learning the purpose of processing personal data and whether they are used in accordance with its purpose,

ç) To know the third parties to whom personal data is transferred within the country or abroad,

d) Requesting correction of personal data in case of incomplete or incorrect processing,

e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the law,

f) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

g) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems, 

ğ) To request the compensation of the damage in case of loss due to unlawful processing of personal data,

As Hattuşa Sağlık Termal A.Ş, we respect these rights.

Maximum Saving Policy / Stinginess Policy

According to this principle, which is called the principle of maximum savings or stinginess, the data reaching Hattuşa Sağlık Termal A.Ş are processed into the system only as necessary. Therefore, what data we collect is determined by the purpose. Unnecessary data are not collected. Other data transferred to our company are also transferred to company information systems. Extra information is not saved in the system, deleted or anonymized. These data can be used for statistical purposes. Health data from special quality data is taken only in order to provide better service to customers and to protect their health and are kept in the system with care. 

Deletion of personal data:

Personal data are deleted, destroyed or anonymized by our company automatically or at the request of the person concerned, when the periods required by law to be kept, the completion of judicial processes or other requirements are eliminated. 

Accuracy and data up to dateness: 

As a rule, the data contained in the Hattuşa Sağlık Termal A.Ş are processed as described by the persons concerned. The Hattuşa Sağlık Termal A.Ş does not have to investigate the accuracy of the data declared by the customers or the persons contacting the Hattuşa Sağlık Termal A.Ş, nor is this done legally and due to our working principles. Declared data is considered correct. The principle of accuracy and actuality of personal data has also been adopted by Hattuşa Sağlık Termal A.Ş. It updates the personal data processed by our company from the official documents received or upon the request of the relevant person. It takes necessary measures for this. 

Privacy and data security:

Personal data are confidential and Hattuşa Sağlık Termal A.Ş respects this privacy. Personal data can only be accessed by authorized persons within the company. All necessary technical and administrative measures are taken to protect the personal data collected by Hattuşa Sağlık Termal A.Ş and to prevent unauthorized access and to prevent our customers and potential customers from being victimized. In this context, it is ensured that the software complies with the standards, the third parties are carefully selected and the data protection policy is observed within the company. 

IV. Data processing purposes:

Collection and processing of personal data by Hattuşa Sağlık Termal A.Ş will be carried out for the purposes specified in the clarification text. Data is collected and processed in order to establish a contract and to provide better service to customers. 

V. Customer, prospective customer and business and solution partners data: 

Collection and processing of data for the contractual relationship; If a contractual relationship is established with our customers and prospective customers, the personal data collected can be used without the customer's consent. However, this usage takes place for the purpose of the contract. Data are used in line with the requirements of the service and better execution of the contract and updated by contacting customers when necessary. On the other hand, the data that our prospects (prospective customers) have left us by themselves are processed to provide them with easier and higher quality service afterwards. These data are deleted if they do not turn into a contractual relationship upon their request. 

Business and Solution Partners’ Data:

Hattuşa Sağlık Termal A.Ş adopts as a principle to act in accordance with the law while sharing data with both business and solution partners. Data is shared with business and solution partners with a commitment to data privacy and only as much data as required by the service, and they are forced to take precautions for data security. 

Data processing for advertising purposes:

Electronic messages for advertising purposes can only be delivered to persons whose prior consent has been received pursuant to the Law on the Regulation of e-Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages. The explicit availability of approval of the person to whom the advertisement will be sent is required. Hattuşa Sağlık Termal A.Ş complies with the details of the "approval" determined in accordance with the same legislation. 

Data transactions made due to the legal obligation of the company or explicitly stipulated in the law

Personal data can be processed without further consent in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation. The type and scope of data processing must be necessary for the legally permitted data processing activity and must comply with the relevant legal provisions. 

Company data processing:

Personal data can be processed in line with the service and legitimate purposes of the company. However, the data cannot be used for illegal services in any way. 

Processing special data:

According to the Law, individuals' race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, costume and dress, membership to associations, foundations or trade unions, health, sexual life, criminal conviction and security measures and biometric and genetic data are personal data of special nature. Hattuşa Sağlık Termal A.Ş also takes adequate measures determined by the Board in the processing of special quality data. 

Hattuşa Sağlık Termal A.Ş can only process data of special nature for the purpose for which it was collected, with the consent of individuals in order to provide better services. 

Data obtained through membership transactions:

If you become a member of Hattuşa Sağlık Termal A.Ş, your personal data shared with us for the membership process are processed in our systems. If you subscribe to our system via Facebook, Google, or other social media tools; Information such as your name, surname, profile picture, and e-mail the address provided to the partners of the relevant social media tool is accessed and this information is transferred to Hattuşa Sağlık Termal A.Ş systems. 

Data processed with automated systems:

Hattuşa Sağlık Termal A.Ş acts in accordance with the law regarding data processed through automatic systems. Information obtained from these data cannot be used against the person without the express consent of the persons. However, Hattuşa Sağlık Termal A.Ş can make decisions about the people with whom it will process by using the data in its system. 

Cookie Policy:

Hattuşa Sağlık Termal A.Ş, as in many websites, uses technologies such as cookies etc. in order to improve the visit experience of website users and increase service quality. Hattuşa Sağlık Termal A.Ş Cookie Policy has been prepared in order to inform the website users about the cookies and the types of cookies used and to guide how the cookie preferences can be managed. 

If you do not approve the use of cookies, we request that you do not continue to the website or change your cookie preferences as shown in this Policy. We would like to remind you that some features of the website may lose their functionality if cookies are not allowed. 

What is a Cookie?

Cookies are small text files stored on your computer or mobile device when you visit a website. In these files, your IP address, session information, the pages you access, etc. data is stored. Thanks to cookies, your website preferences can be remembered, you can be kept open or you can be presented with the content you are interested in. For detailed information about cookies, you can visit www.aboutcookies.org and www.allaboutcookies.org. 

Cookies Types:

Cookies are divided into different types according to criteria such as storage time on mobile devices and by whom they are placed. The main distinction under these criteria is as follows:

Session Cookies: 

Session cookies are temporary cookies and are deleted from the device after closing the browser. The main function of these cookies is to ensure that the website works properly. 

Permanent Cookies: 

Permanent cookies remain on the device after they close the browser until they are deleted by the user or expired. 

First Party Cookies:

 First party cookies are cookies placed on the device by the operator of the website visited. 

Third Party Cookies: 

Third party cookies are cookies placed on the device and controlled by people other than the operator of the website visited. 

In the event that personal data is collected, processed and used in the websites and other systems or applications of Hattuşa Sağlık Termal A.Ş, the relevant persons are informed with a privacy statement and, if necessary, about cookies. People are informed about our practices on web pages. Personal data will be processed in accordance with the law. 

When you visit our website, we provide the following information to you about the cookies we use / will use on our page. 

Usage Purpose of Cookies Cookie Type

Google (analytics, doubleclick) Measurement

Advertisement

On-site improvement Functional and analytical cookies

Commercial cookies

Facebook Advertising Commercial cookies

Adjust Measurement

Advertisement

On-site improvement Functional and Analytical Cookies,

Commercial Cookies.

Hotjar Measurement

On-site improvement Functional and analytical cookies

Commercial cookies

3rd party companies (criteo, rtbhouse) Advertising Functional and analytical cookies

Commercial cookies

Cookies Used on Hattuşa Sağlık Termal A.Ş Website

Hattuşa Sağlık Termal A.Ş uses different types of cookies in accordance with its Privacy Policy. 

Mandatory Cookies: 

These are technical cookies that enable the website to work correctly and allow you to use its features. They are in the session cookie category. If these cookies are blocked, it results from the inability to use the website features. Your consent is not required for the use of mandatory cookies. 

Analytical Cookies:

Analytical cookies are used to improve your website experience. Analytical cookies allow us to understand how you are using the website (e.g. which pages you have visited, the duration of your visit, etc.). In this way, we can improve the content we offer or change the website design. 

Functionality Cookies: 

When you visit the website again, your language preferences, region selection, etc. allows to be remembered. 

Targeting / Advertising Cookies:

 Hattuşa Sağlık Termal A.Ş uses different first-party and third-party cookies for targeting and advertising purposes on its website. It is possible to block these cookies by changing the settings of your browser or by changing the cookie preferences as shown in this Policy. 

How Can You Change Your Cookie Preferences? 

It is possible to customize or completely block cookies by changing the settings of the browser you use. You can find detailed information about the steps to be followed for different browsers from the links below: 

Browser Name Link

Google Chrome https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=tr

Internet Explorer https://support.microsoft.com/tr-tr/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox https://support.mozilla.org/tr/kb/cerezleri-silme-web-sitelerinin-bilgilerini-kaldirma

Yandex https://yandex.com.tr/support/browser-classic/personal-data-protection/cookies.xml

Safari https://support.apple.com/kb/PH21411?locale=tr_TR

To manage cookie preferences in other browsers, you can review the relevant browser's help or support page. 

Your Rights Regarding Your Personal Data:

If you submit your requests regarding your rights listed above to our Company in accordance with the application procedures stipulated in the Communiqué on Application Procedures and Principles to the Data Officer, Hattuşa Sağlık Termal A.Ş will finalize your request free of charge as soon as possible and within 30 (thirty) days at the latest. However, if the transaction requires an additional cost, Hattuşa Sağlık Termal A.Ş may charge the fee in the tariff determined by the Personal Data Protection Board

. 

Functional and Analytical:

Cookies contain data about remembering your preferences, using the website effectively, optimizing the site to respond to user requests, and how visitors use the site. Due to the nature of this type of cookies, they may contain your personal information such as user name, etc. 

Third-Party Cookies:

Hattuşa Sağlık Termal A.Ş websites / mobile applications / mobile websites work with third party reliable, well-known advertising providers. Third party service providers set their own cookies to serve you specific advertisements. Cookies placed by the third party collect the browsing information of visitors on websites, process them and analyze how they use it. 

Commercial cookies:

It serves to increase your user experience by presenting the ones with similar qualifications to the product/content you target in line with your interests and choices and by offering a more advanced, personalized advertising portfolio. The aforementioned session, permanent, functional, and analytical and commercial cookies are kept in the background for about 2 (two) months, and the necessary adjustments can be made in the individual internet browser settings. The removal process from these settings may vary based on the internet browser. 

How can I delete cookies? 

Many internet browsers are set to automatically accept and use cookies from the first time they are installed on your computer. By using the help or settings menus of your internet browser, you can block cookies or receive a warning when a cookie is sent to your device. You can use your browser's instruction or help options screen to learn about different ways to manage cookies and get detailed information about how to adjust the settings of your browser. 

VI. Data of our employees:

Personal data of our employees can be processed without approval, to the extent necessary in terms of business relations and health insurance. However, Hattuşa Sağlık Termal A.Ş ensures the confidentiality and protection of data belonging to its employees. 

Processing as per Legal Obligations:

Hattuşa Sağlık Termal A.Ş may process the personal data of its employees without obtaining a separate consent in order to clearly state the processing in the relevant legislation or to fulfill a legal obligation determined by the legislation. This matter is limited to the obligations arising from the law. 

Processing for the Benefit of Employees:

Hattuşa Sağlık Termal A.Ş may process personal data without obtaining consent for transactions for the benefit of company employees such as private health insurance. Hattuşa Sağlık Termal A.Ş can also process employee data for disputes arising from business relationships. 

Processing special data:

According to the Law, individuals' race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, costume and dress, membership to associations, foundations or trade unions, health, sexual life, criminal conviction and security measures and biometric and genetic data are personal data of special nature.

Hattuşa Sağlık Termal A.Ş also takes adequate measures determined by the Board in the processing of special quality data. Special personal data can only be processed, without the consent of the person, in relation to the cases permitted by the Law and to a limited extent. In order for our employees to benefit from insurance and health services, qualified data obtained from them are used only for the purpose. 

Data processed with automated systems:

Data processed in relation to employees regarding automated systems can be used in internal promotions and performance evaluations. Our employees have the right to object to the result against them and they do this by following internal procedures. The objections of the employees are also evaluated within the company. 

Telecommunications and internet:

Computer, telephone, e-mail, and other applications allocated to employees within the company are allocated to the employee only for business purposes. The employee cannot use any of these means allocated to his/her by the company for his/her private purposes and communication. The company can control and control all data on these devices. The employee undertakes that no other data or information will be kept on the computer, phones, or other tools allocated to him/her from the moment she/he starts working. 

VII. Transfer of personal data domestically and internationally:

Personal data can be shared with business and solution partners and Hattuşa Sağlık Termal A.Ş affiliates in order to for the service to be carried out by Hattuşa Sağlık Termal A.Ş. 

Hattuşa Sağlık Termal A.Ş will be able to transfer personal data to the following persons and institutions for certain purposes; 

To the business partners of Hattuşa Sağlık Termal A.Ş, limited in order to ensure the fulfillment of the objectives of the establishment of the business partnership, to the suppliers of Hattuşa Sağlık Termal A.Ş, to a limited extent, in order to provide our Company with the services required to fulfill the commercial activities of our company and that our company procures from the supplier externally, to solution partners of Hattuşa Sağlık Termal A.Ş to a limited extent to ensuring the execution of the commercial activities of our company that require the participation of the our affiliates, to the affiliates of Hattuşa Sağlık Termal A.Ş 

Hattuşa Sağlık Termal A.Ş has the authority to transfer personal data domestically and internationally within the conditions determined by the Board and in accordance with the other conditions in the Law and depending on the consent of the person. 

VIII. Rights of the person concerned:

Hattuşa Sağlık Termal A.Ş accepts that the relevant person has the right to ask for the consent to be obtained before the data is processed within the scope of the Law, and after the data is processed, she/he has the right to determine the fate of the data. 

On the other hand, individuals do not have a right to anonymized data within the Company. Hattuşa Sağlık Termal A.Ş may share personal data with relevant institutions and organizations in order for a judicial duty or state authority to exercise its legal powers in accordance with the business and contractual relationship. 

Personal data owners can submit their requests regarding the above-mentioned rights to ………………………………………………………………… by registered mail and photocopies of their identity cards (only a front-page copy for the identity card) to the Company by completely filling out the application form on the Company official website www.hattusa.com.tr. Your applications will be answered as soon as possible according to the content of your application or within 30 days at the latest after it reaches our company. You must submit your applications by registered mail. In addition, the part relevant to you only of your application will be answered, and an application made about your spouse, relative or friend will not be accepted. Hattuşa Sağlık Termal A.Ş may request other relevant information and documents from the applicants.

IX. Principle of Privacy:

The data of employees and other persons in Hattuşa Sağlık Termal A.Ş is confidential. No one can use, copy, reproduce, transfer to others, or use this data for any other purpose without compliance with the contract or the law. 

X. Process security:

All necessary technical and administrative measures are taken to protect the personal data collected by Hattuşa Sağlık Termal A.Ş and to prevent unauthorized access and to prevent our customers and potential customers from being victimized. In this context, it is ensured that the software complies with the standards, the third parties are carefully selected and the data protection policy is observed within the company. Security measures are constantly being renewed and improved. 

XI. Audit:

Hattuşa Sağlık Termal A.Ş carries out the necessary internal and external inspections for the protection of personal data. 

XII. Notification of Violations:

When Hattuşa Sağlık Termal A.Ş is notified of any violation regarding personal data, it immediately takes action to remedy the violation in question. It minimizes the damage of the person concerned and compensates for the damage. When personal data is captured from outside by unauthorized persons, it immediately notifies the Personal Data Protection Board. 

Applications regarding the notification of violations can also be made according to the procedures specified at http://www.hattusa.com.tr. 

Contact 

For your questions and requests regarding the a confidentiality agreement, you can print and fill out the form below and send that form to the address below as a registered letter. 

Hattuşa Sağlık Termal A.Ş 

Cevizlidere Cad. 1237. Sok. No:1/20 

Çankaya / ANKARA