Privacy Policy

1. Data Controller

Next Plus Health (the “Company”) acts as the data controller within the meaning of the Turkish Personal Data Protection Law No. 6698 (“KVKK”).

Registered office: Maltepe, Istanbul, Türkiye
Contact: info@nextplushealth.com

2. Personal Data Collected

The following personal data may be processed through our platform (the website and the Next Plus Health mobile application):

• Identity data: First name, last name; Turkish ID number where required for payment and invoicing
• Contact data: Telephone number, e-mail address, delivery and billing address
• Location data: Device location, only where you grant permission, so that ambulance services can be provided in an emergency and a nearby blood pressure monitor can be detected
• Transaction data: Service requests, appointment and purchase records, order details, user feedback. Payments are collected through the PayTR infrastructure; your card details are not stored by the Company.
• Visual and audio data: Camera and microphone data during video consultations; photos and documents you upload
• Technical data: IP address, device model, operating system, application version, advertising identifier (on iOS only where you grant permission), error and crash logs
• Behavioural data: Application usage data, screen transitions and interactions
• Health data (special category personal data):
  • Known medical conditions, where you choose to share them
  • Measurements taken from connected devices such as wristbands, scales and blood pressure monitors: heart rate, blood pressure, blood oxygen, sleep, steps, weight, body temperature, heart rate variability and similar
  • Measurements you enter manually
  • Data read from Apple Health or Health Connect, where you grant permission
  • Appointment and consultation details relating to the healthcare service you receive (doctor, psychologist, dietitian)

3. Purposes and Legal Grounds for Processing

Your personal data is processed for the following purposes:

• Creating your account and verifying your identity
• Providing online healthcare services (doctor, dietitian, psychologist, etc.) and appointments
• Displaying and tracking measurements from your connected devices
• Providing emergency and ambulance services
• Carrying out purchase, payment, invoicing and delivery processes
• Managing customer relations and support processes
• Fulfilling legal obligations
• Improving service quality, detecting errors and enhancing the user experience
• Measuring advertising performance

Your general personal data is processed on the legal grounds set out in Article 5 of the KVKK: the establishment or performance of a contract, compliance with a legal obligation, and legitimate interest.

Your health data is processed solely on the basis of your explicit consent or the other legal grounds listed in Article 6 of the KVKK, and only for the purpose of providing you with healthcare services.

4. Cookies and Tracking Technologies

Our website uses cookies and our mobile application uses similar technologies (SDKs). These technologies are used for the following purposes:

• Session management
• Remembering user preferences
• Traffic and usage analysis
• Measuring advertising performance

On iOS devices, your advertising identifier is used only if you grant permission in the prompt displayed by the application (App Tracking Transparency).

On Android devices, you can reset or delete your advertising identifier under Settings > Google > Ads on your device.

5. Third-Party Services and Advertising Technologies

Our platform uses the following third-party service providers:

• Meta Platforms (Facebook / Instagram SDK and advertising services): Used to measure the results of our advertisements. Only the following information is transmitted to Meta:
  • installation and opening of the application
  • completion of registration
  • payment amount and currency
  • the fact that an appointment was created; the specialty booked is not transmitted
  • device and advertising identifier information
• AppsFlyer: Used to measure which channel an advertising campaign generated installs and usage from (attribution and analytics).
• OneSignal: Used to send push notifications.
• PayTR: Used to collect payments securely.
• Microsoft Clarity: Screen interactions (taps and scrolls) are recorded in masked form to improve the usability of the application. No recording takes place on screens containing health data.
• Google (Google Tag Manager, Google Analytics and Google advertising services): Used to analyse the use of our website and to measure advertising performance.

Through these services:

• Application usage may be analysed
• Advertising performance may be measured
• Personalised advertisements may be served (including remarketing)

Your health data is never transferred to any of these services for advertising or marketing purposes.

6. Transfer of Personal Data

Your personal data may be shared with the following parties under the conditions set out in Articles 8 and 9 of the KVKK:

• Healthcare professionals who provide services to you (doctor, psychologist, dietitian)
• Business partners
• The technical service providers listed above
• Authorised public institutions and bodies

The servers of some service providers (Meta, AppsFlyer, OneSignal) are located abroad. These transfers are carried out with the necessary security measures in place, in accordance with Article 9 of the KVKK.

7. Data Retention Periods

Your personal data is retained for the periods specified in the applicable legislation and in a manner limited to and proportionate with the purpose of processing. At the end of these periods it is deleted, destroyed or anonymised.

8. Special Provisions on Health Data

• Data obtained from Apple Health and Health Connect is used solely to display it to you within the application and to provide healthcare services. This data is not used for advertising, marketing or data sale purposes and is not shared with third parties for such purposes.
• You may withdraw your Apple Health and Health Connect permissions at any time from your device settings.
• You may remove connected device links from the My Devices screen in the application.

9. User Rights

Under Article 11 of the KVKK you have the following rights:

• To learn whether your personal data is being processed
• To request information if it has been processed
• To learn the purpose of processing and whether the data is used in accordance with that purpose
• To know the third parties to whom your data has been transferred, domestically or abroad
• To request the rectification of incomplete or inaccurate data
• To request the erasure or destruction of your data
• To object to a result arising against you from the analysis of processed data exclusively by automated systems
• To claim compensation for damage suffered as a result of unlawful processing

You may submit your requests to info@nextplushealth.com.

10. Data Security

Technical and administrative measures such as SSL encryption, authorisation and access control, server security measures and regular audits are applied to protect the security of your personal data.

11. Data Deletion and Account Closure

You may request the deletion of your account and personal data. To do so, simply send an e-mail with the subject “Account deletion request” to info@nextplushealth.com, stating your registered telephone number.

Your request will be completed within 30 days at the latest. When your account is deleted, the following data is also deleted or anonymised:

• your profile information
• your health data
• your device data

Records that must be retained by law (for example invoice details) are kept only for the statutory period.

12. Changes

This privacy policy may be updated from time to time. Updates will be announced on our website.

This is an unofficial English translation provided for convenience. In the event of any discrepancy, the Turkish version of this document shall prevail.