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Privacy Policy


Effective Date: […./01/2017]

As Medicana Education Group and its subsidiaries ("Medicana," "us," "to us," "our") we know how important privacy is to our customers and we are trying to be transparent about how we collect, use, disclose, transfer and keep your data. This Privacy Policy provides a general framework for our practices about data. The Privacy Policy applies to the Medicana Education Group website, online transactions on the website, and services performed at the Medicana educational institutions (collectively referred to as "Our Services").

We may occasionally change the Privacy Policy for various reasons to reflect changes to laws and regulations as well as in industry practices and technological developments. Please note that the Privacy Policy applies to our website, your online transactions, and the transactions you carry out at our educational institutions covered by this Privacy Policy. The Privacy Policy applies to your use of the computer, mobile phone, tablet, TV, or any other device to access our Services, and independent of your physical access. It is very important that you carefully read the Privacy Policy since you give consent to our services indicated in the Privacy Policy each time you use our services. By using our Services, you agree to the practices described in the Privacy Policy.

It is also very important that you frequently check to see if the Privacy Policy has been updated. When we update the Privacy Policy, we notify you of important changes we have made by adding a note to the relevant Services. After we add this warning, you will have approved the new applications mentioned in the update by accessing or using our Services. The current version of the Privacy Policy will always be available on our website. To see when the Privacy Policy was last updated, you can check the "effective date" at the top.

What kind of data do we collect about you?
Data that you Directly Provide Us
Some services allow us to collect data about you directly. For example:
The education services that we provide in our educational institutions require our customers to share all of their credentials such as name, surname, Turkish ID Number etc. with us. For example, if you apply for registration in our educational institutions, you will need to provide us with your credentials so that we can offer you services.
We may ask for your identity and contact details for your requests submitted through the "Let us call you" section of our website.
We may ask for your credentials, work experience and your educational background so that you can apply for a job through the HR page on our website.

Data on your Use of the Services
In addition to the data you provide, we may collect data about your use of our Services from other Medicana educational institutions. For example, we can collect the following data:
ID Details—All ID data such as name, surname, Turkish ID Number etc.,
Education— Information about the education services that your child receives at our schools,
Contact Details—Contact details such as e-mail address, phone number etc. that help us contact you

Data from third parties
We may collect data about you from publicly traded and commercially available sources (as permitted by law), and we may combine these data with other data we may have about you. We may also request data from your relatives who are considered as third party to provide you services.

Other Data that We Collect
We may also collect other data about your use of the Services by obtaining your consent during collection of data or in other ways.
You may choose not to share with us certain types of data (e.g., relevant up-to-date data required for communication); but you may not be able to use some of the Services or use them as you like if you do not share these data.

Data Collected Automatically
We automatically collect some personal data when you use our website or our products. These data may include some or all of the following:
Your IP address;
Your user and account name and data about these;
Phone number;
SIM (Subscriber Information Module) card number;
Machine ID, device ID numbers such as IMEI and/or MEID;
Geographical location based on GPS/Wi-Fi/ communication network local information.

Except in cases where we need to retain the identifiable attributes of the data, we anonymize the data we collect and store it in a format that does not identify your identity. For example, when we collect your IP address, we anonymize your IP address by hiding the last group of digits (e.g., making the number 192.168.1.XXX).

How Do We Collect your Data?
Your data can be collected verbally, in writing or through electronic media via various methods such as our website, online transactions such as "Let Us Call You" etc. on our website, your job application via the HR page on our website, our call center service or your physical application to our educational institutions or by using the "Student Information Form".

How Do We Use Your Data?
We can use the data we collect for the following purposes:
In order to be able to register you and/or your student in a Service;
To provide a Service that you request;
To provide you with customized services based on your past activities with our services;
For advertising activities, such as providing sponsored content with customized ads and sending promotional communications to you;
To evaluate and analyze our customers, our products and services (including asking your opinion about our products and services and conducting customer surveys);
Understanding how our services are used to improve our services and develop services with new products;
To organize free, award-winning competitions or promotions to the extent permitted by law; and
For other purposes by seeking your consent.
By combining the data we collect from you, we may use it for purposes consistent with this Privacy Policy.

Who do we disclose your data?
We do not disclose your data without your consent to third parties for their independent marketing or business purposes. However, we can disclose your data to the following organizations:

Subsidiaries. For purposes of the Privacy Policy, your data may be shared with the Medicana Education Group subsidiaries.
Service providers. We may also disclose your data to companies that provide our services or services for us, such as companies that help us with billing or send e-mails on our behalf. These organizations may use your data solely to provide us services.

Student Relatives. We may disclose information about the education performance of your child in order to give information to first degree relatives of your child as per relevant education legislation.
Other Parties as per Law or Required to Protect Our Services. There may be cases where we disclose your data to other parties for the following reasons:
To comply legally or to respond to mandatory legal notices (such as a search warrant or other court orders);
To verify or implement policies that govern our services and
to protect the rights, properties or security of the Medicana Education Group or related subsidiaries, business partners or customers.
Other Parties in connection with Corporate Transactions. As part of a merger or transfer process, or in case of bankruptcy, we may disclose your data to a third party.
Other Parties By Your Consent or By Your Request. In addition to the disclosures set forth in this Privacy Policy, we may share your data with third parties in accordance with your approval or request. 
How do we Ensure the Integrity of your Data?
To ensure the integrity of all kinds of data required for the support and maintenance of the services we provide to our customers, to archive them at times in accordance with legal legislation and to prevent them from being shared with third parties other than the medical team who will carry out the diagnosis and treatment;
The required software and hardware have been determined,
In order to provide the necessary software and hardware continuously, required resources have been allocated,
In order to protect customer data, staff have been given traininings on what needs to be done and their responsibilities have been outlined in an employment contract,
The required infrastructure to backup all the data has been identified and those who are responsible for this process have been appointed,
Educational institutions’ access to all kinds of access operations (reading, modifying, deleting, adding) have been limited in the information system,
Client (student) files and information are given only to our students, to their relatives who have been given written approval by the parents on behalf of the sudent, to the relevant public institutions and organizations within the framework of the educational legislation, and to judicial authorities in judicial institutions.

The three core principles for data security at our educational institutions are confidentiality, integrity and accessibility by authorities.

Who controls your data?

Within the scope of the Law No. 6698 Regarding the Protection of Personal Data, "Data Responsible" for each and every company in the Medicana group has been appointed by the Medicana Education Services and Trade Co.

We state that your data are collected under this Privacy Policy by the “Data Responsibles” and these persons enjoy rights and assume responsibilities outlined in Law No. 6698 in their capacity as "Data Officer".

Data Storage
We take reasonable measures to ensure that your data are kept only for as long as they are required by the purpose of the collection or by applicable laws or contracts.

What are Your Rights about your Data?
Regarding your data processed in the Medicana Education Group, you can always forward your request to us:
To find out about whether your data is processed,
To get information about it if your data are being processed,
To find out about the purpose of processing your data and whether your personal data are used in accordance with the purpose,
To find out about the third parties to whom data are being transferred in Turkey or abroad and which data are transferred,
To request correction if the data are missing or incorrect,
To request your data to be deleted or or destroyed if the reasons that require your data to be processed no longer exist or the data are no longer up-to-date,
To request that your request with respect to data correction or deletion are transfered to third parties if data are transferred to them.

Which Principles do We Observe When Handling Personal Data?
Medicana observes the following principles when handling your personal data:
Processing in a manner consistent with the rule of law and integrity;
Processing data correctly;
Having a specific scope for data processing;
Processing data for legitimate purposes;
Data processing should be linked with the purpose of collecting or reprocessing the data,
Data should be kept up-to-date,
Data should be kept as long as required for the purpose that they are processed.

Third Party Connections and Products in our Services
Our Services may include links to third-party websites and services beyond our control. The security or confidentiality of data collected by websites or other services is not our responsibility. Be careful and do not forget to examine the valid privacy statements regarding third-party websites and services you use.

If You are a Minor
As Medicana Education Group, we are concerned about the privacy and security of minors on the internet. Our website is designed for general public, not for use by minors.