Data Policy

1. USER INFORMATION TEXT ON THE PROTECTION OF YOUR DATA BY THE PROCEDURES AND PRINCIPLES OF THE PERSONAL DATA PROTECTION LAW NO. 6698 (“KVKK”)

As a SELLER established in Turkey; As the data controller, your data is obtained in the following ways, depending on the situation,

• within the scope of our legal relations,

• within the framework of the purpose requiring their processing and in connection with this purpose, in a limited and measured way,

• maintaining the accuracy and the most up-to-date version of the personal data you have notified or notified us of,

We inform you that it will be recorded, stored, preserved, reorganized, shared with the institutions that are legally authorized to request this personal data, and that it will be transferred to third parties in the country, transferred, classified, and processed in other ways listed in the KVKK.

1.1. WHICH PERSONAL DATA DO WE PROCESS?

Your data that we share with us or that may be subject to processing, if necessary, are as follows:

Username Alphanumeric domain name that identifies the user but does not contain any identifying information.

Date of birth User’s date of birth

Gender User’s gender information

1.2. HOW AND FOR WHAT REASONS DO WE REQUEST YOUR DATA?

As the SELLER, we collect your data, which we request from you, to fulfill our legal obligations, to perform the service contract between us, for the reasons stipulated in the laws and accordance with the legitimate interest of the SELLER, through your verbal, physical or electronic transmission to us.

Your data may be processed by the SELLER for purposes and reasons such as but not limited to the following purposes and legal reasons.

To carry out the user service relationship, we will establish with you, a particular;

• neurofeedback training activity

• EEG measurement data

We store your information.

It may be processed to exercise our right of defense or to fulfill our legal obligation if requested by us within the scope of a duly legal process.

Your data will be retained for the maximum period specified in the relevant legislation or required for the purpose for which they are processed, and possibly for the legal statute of limitations.

1.3. SHARING YOUR DATA WITH THIRD PARTIES IN DOMESTIC AND ABROAD

Your data can be shared and analyzed anonymously with specialist doctors to create new treatment methods for different brain conditions.

Your data mentioned above are transferred to AWS to be kept in a secure and high-speed global database and can be used as anonymous data to realize new inventions and treatments in the field of health.

1.4. SHARING YOUR DATA WITH THIRD PARTIES ABROAD

1.4.1. YOUR RIGHTS

By Article 11 of the KVKK, regarding your data, provided that you prove your identity;

• To learn whether the SELLER is processing personal data about you and if so, to request information about it,

• To learn the purpose of processing your data and whether they are used for the purpose,

• To learn whether personal data is transferred domestically or abroad and to whom

You have the right.

In addition, you have the right to request the correction of your incorrect and incomplete personal data from the SELLER and to inform the recipients whose data has been or may have been transferred.

You may request the destruction (deletion, destruction, or anonymization) of your data from the SELLER within the framework of the conditions stipulated in Article 7 of the KVKK. At the same time, you can request that the third parties to whom the data has been or may be transferred be informed about your destruction request. However, by evaluating your destruction request, we will evaluate which method is appropriate according to the conditions of the concrete case. In this context, you can always request information from us about why we have chosen the destruction method we have chosen.

You may object to the results of your personal data analysis, created exclusively using an automated system if these results are contrary to your interests.

If you suffer damage due to the unlawful processing of your data, you can request the removal of the damage.

Your requests in your application will be concluded free of charge within thirty days at the latest, depending on the nature of the request. However, if the transaction requires a separate cost for the SELLER, the fee in the tariff determined in the Communiqué on Application Procedures and Principles to the Data Controller may be charged by the Personal Data Protection Board.

By the first paragraph of Article 13 of the KVK Law; The SELLER, who is the data controller, must submit the applications to be made regarding these rights in writing or by other methods determined by the Personal Data Protection Board (“Board”).

In this context, applications are to be made to our SELLER in writing, by printing out the form;

• With the personal application of the Applicant,

• Via notary public or

• By being signed by the Applicant with the secure electronic signature defined in the Electronic Signature Law No. 5070 and sent to the SELLER registered [email protected] e-mail address,

• It can be sent to us by e-mail sent from the e-mail address that the Applicant has previously notified the SELLER and registered in the SELLER’s system.

In matters related to the processing of your data, you can submit your application to the SELLER by filling out the application form on the SELLER’s website, in writing, or by using the registered e-mail address, secure electronic signature, mobile signature, or your e-mail address that you have previously informed us and included in our records. you must. Depending on the nature of your request and your application method, the SELLER may request additional verifications (such as sending a message to your registered phone or calling) to determine whether the application belongs to you or not, and thus to protect your rights. For example, if you apply through your e-mail address registered with the SELLER, we may contact you using another communication method registered with the SELLER and request confirmation of whether the application belongs to you.

2. USER EXPRESS CONSENT ON THE PROTECTION OF PERSONAL DATA BY THE LAW ON PROTECTION OF PERSONAL DATA NUMBER 6698 (“KVKK”)

SELLER established in Turkey; as data controller,

• your data we obtain in the following ways, depending on the situation,

• within the scope of our legal relations,

• within the framework of the purpose requiring their processing and in connection with this purpose, in a limited and measured way,

• maintaining the accuracy and the most up-to-date version of the personal data you have notified or notified us of,

We inform you that it will be recorded, stored, preserved, reorganized, shared with the institutions that are legally authorized to request this personal data, and that it will be transferred to third parties in the country, transferred, classified, and processed in other ways listed in the KVKK.

2.1. TRANSFER OF YOUR DATA ABROAD

Your data may be transferred to persons/companies abroad, especially if the SELLER has a legitimate interest that does not impair the fundamental right and freedom of the data subject in sharing the data, or if it requires the performance of a relevant contract, by the Law on the Protection of Personal Data, and the personal data may be transferred by these persons/companies. can be processed.

Your data that may be transferred abroad by us are as follows:

Username Alphanumeric domain name that identifies the user but does not contain any identifying information.

Date of Birth User’s date of birth

Gender User’s gender information

2.2. PURPOSE OF TRANSFER OF YOUR DATA ABROAD

Your data mentioned above are transferred to AWS to be kept in a secure and high-speed global database and can be used as anonymous data to realize discoveries and treatments in the field of health. Regarding this explicit consent text, “I have read and understood the explicit consent text. By ticking the checkbox “I approve and consent to the processing of my data in the ways specified in the text”, you will consent to the transfer of your data mentioned above for the specified purposes

2.3. LIGHTING TEXT UNDER THE LAW ON THE PROTECTION OF PERSONAL DATA

As HMS Health Mobile Software A.Ş, we process your personal data, and at the same time, we do our best to protect your data by taking the technical and administrative measures stipulated by the laws. With this text, we would like to inform you in detail about the processing of your personal data.

3. COOKIE POLICY

The Cookie Policy (hereinafter referred to as the “Policy”) has been prepared by HMS Health Mobile Software A.Ş (hereinafter referred to as “HMS Health Mobile Software A.Ş” for short) and our website (hereinafter referred to as the “Website” for short). ) constitutes the supplement of the Clarification Text within the scope of the Law on the Protection of Personal Data. HMS Health Mobile Software A.Ş has prepared this Policy to explain which Cookies are used on the website.

3.1. WHAT IS A COOKIE?

Cookies are small pieces of information stored by your browser on your computer’s hard drive. It is generally used to provide you with a personalized experience while using the website you are visiting, to improve the services offered, and to improve your experience, and can contribute to the ease of use when navigating a website.

3.2. WHAT ARE THE TYPES OF COOKIES?

Cookies are subject to various distinctions according to their lifetime, purpose of use, and the owner of the cookie or the party placing the cookie.

By lifetime: Session Cookies, Persistent Cookies

By intended use: Mandatory/Technical Cookies, Analytical Cookies, Functional/Functional Cookies, Targeting/Advertising Cookies

By Cookie Owner or Cookie Setter: First-Party Cookies, Third-Party Cookies

• Session Cookie: These are the cookies that are created while you visit a website and are used during your visit and are valid until the browser window is closed. The purpose of such cookies is to ensure the continuity and security of your visit.

For example, it allows filling out online forms consisting of multiple pages.

• Persistent Cookies: They are created the first time you visit a website and remain on your hard disk depending on their lifetime or until you delete them. The purpose of such cookies is to increase site functionality by providing a faster and better service to visitors.

For example, remembering visitor preferences, and determining the content to be transmitted in line with these preferences.

3.3. COOKIES ACCORDING TO THE PURPOSE OF USE

• Mandatory/Technical Cookies: These are mandatory cookies for the website you visit to function properly. The purpose of such cookies is to provide the necessary service by making the site work.

For example, it allows accessing secure parts of the website, using its features, and browsing on it.

• Analytical Cookies: They collect information about the usage pattern of the website, frequency, and a number of visits, and show how visitors get to the site. The purpose of using these types of cookies is to improve performance and determine the general trend direction by improving the functioning of the site. They do not contain data that can identify visitor identities.

For example, they show the number of error messages shown or the most visited pages.

• Functional/Functional Cookies: Saves the choices made by the visitor within the site and remembers them on the next visit. The purpose of such cookies is to provide ease of use to visitors.

For example, it prevents the site user from re-entering the user password on each page they visit.

• Targeting/Advertising Cookies: They allow measuring the effectiveness of the advertisements presented to the visitors and calculating the number of times they are watched. The purpose of such cookies is to serve advertisements customized to the interests of visitors.

For example, it prevents the advertisement shown to the visitor from being shown again in a short time.

3.4.COOKIES BY Cookie OWNER OR PLAYER PLACING A Cookie

• First Party Cookies: These are cookies defined by the website visited and can only be read by this website.

• Third-Party Cookies: These are cookies that are defined by organizations other than the website visited and that enable reporting to the website regarding the service for which they are defined.

3.5. COOKIES USED ON OUR WEBSITE

Mandatory, functional, and analytical cookies used by our sites:

• Required to use the website interface and features as desired.

• It allows you to speed up the activities during your future visits.

• By enabling us to understand how the website is used by visitors, it helps us to gather statistical data and develop content in line with this data.

• Under no circumstances do we collect, store and process data that can identify you, and it does not qualify as personal data.

• Does not harm your computer and does not contain viruses.

Targeting and advertising cookies, on the other hand, are used within the scope of our legitimate interests and with the necessary legal commitments, provided that it does not harm your fundamental rights and freedoms, in order to personalize advertisements and analyze site traffic.

3.6. HOW ARE COOKIE PREFERENCES MANAGED?

To change your preferences for the use of cookies or to block or delete cookies, simply change your browser settings.

Many browsers give you the option to accept or reject cookies, to only accept certain types of cookies, or to be alerted by the browser when a website requests to store cookies on your device so you can control cookies.

It is also possible to delete cookies previously saved in your browser.

If you disable or refuse cookies, you may need to set some preferences manually, some features and services on the website may not work properly because we cannot recognize and associate your account. You can change your browser’s settings by clicking the relevant link in the table below.

Google Chrome http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647

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

MozillaFirefox http://support.mozilla.com/en-US/kb/Cookies

Opera http://www.opera.com/browser/tutorials/security/privacy/

Safari https://support.apple.com/kb/ph19214