Privacy Policy

Changes to this Privacy Policy 

This Privacy Policy may be revised according to the updates in the application. When we make changes in the policies, this will be reflected by the ‘’Effective as of’’ date above. We recommend you review this Privacy Policy periodically to stay informed about the changes. Changes to this Privacy Policy will take effect as soon as changes are made on the application. If you continue to use the Platform and/or the Website after we make changes, it will be deemed to be your acceptance of those changes. If you object to any changes we make to this Privacy Policy, you may contact us or close your account and no longer access the Website.

INFORMATION THAT SURGBUDDY COLLECTS

We do not require sensitive information from our members. It is your choice whether to include your sensitive information (such as race, ethnicity, political opinion, philosophical, religious, sect or other religious beliefs, appearance, association, foundation or union membership, physical or mental health, sexual life, criminal record or/and biometric or genetic data) on your profile and make that sensitive information public. Please note that any content posted by you onto Platform, including but not limited to photos, videos, texts, profile information, profile updates, your comments, questions, answers…etc. becomes published content and is publicly available for anyone in the world to review. We kindly remind you that do not post or add personal information to your profile that you would not want to be publicly available. 

To provide SurgBuddy products, we must process your information. When you register to SurgBuddy Platform, you grant us a right to collect your personal information. For purposes of this Privacy Policy and legal definitions, ‘’personal information’’ means any data and information relating to an identified or identifiable natural person. Personal information does not include information that you post on the Platform or that is publicly available from government records, as well as de-identified or aggregated consumer information.

Information that SurgBuddy receives from you: 

• Registration and Profile Information

To register and create a user account, you give us some information. You provide us with personal information when you register on the Platform and update your account. This information may include your first and last name, geographic location, email address, mobile phone number, username and password. In this way, you create your basic level SurgBuddy profile and start using the application.

If you want to create a detailed profile, you may add specific information about yourself. However, you should know that SurgBuddy does not want any other additional information from you except from the essential ones. Yet, a detailed profile can enable you to use the application more efficiently. In this regard, the choose is entirely up to you.

SurgBuddy does not require sensitive information from users. It is your choice whether to include your sensitive information on your profile and make that sensitive information public. In this regard, please do not post or add personal information to your profile that you would not want to be publicly available.

• User Interactions

You may provide us personal information through communications or chats with other users on the Platform. You understand that other users may contact you through direct messages and comments on the Platform. Any messages that you send to other users through the Platform may not be private or confidential if either you or the recipient of the message discloses it to another person or chooses to publicly post it. In addition, as SurgBuddy may monitor these messages if a user chooses to report it and provide screenshots to be examined by us, and if SurgBuddy, in its sole discretion, believes that the messages are spam, fraudulent or otherwise violative of the SurgBuddy’s Terms of Use and Community Guidelines, we may disable or delete the account.

• Other Interactive Features

You also provide SurgBuddy to your personal information when you use certain features on the Platform, such as submitting texts, comments and other postings on the Platform. You understand that your Submissions are published or displayed on public areas of the Platform or transmitted to other users of the Platform or third parties. You post your Submissions with your username that you created in the registration part and your username (not your real name or your email) is displayed to other users when you post your Submissions to the Platform. If you use your first or last name as part of your username or your username is discoverable on the Internet, you accept that you are making this personal information publicly available and understand that other users may view this personal information and may be able to identify you from this personal information. SurgBuddy cannot control the actions of other users to the Platform with respect to your Submissions.

• Networks and Connections

We collect information about the people, accounts, hashtags, SurgBuddy groups that you are connected to and how you interact with them across our service and products, such as groups that you are part of.

• Your Usage

We collect information about how you use our service and products, such as the types of content that you engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our service and products. We also collect information about how you use features of our service and products such as our camera.

• Things Others Do and Information They Provide About You

We also receive and analyze content, communications and information that other people provide when they use our service and products. This can include information about you, such as when others share or comment on a photo of you or send a message to you.

• Device Information

We collect information from and about your computers, phones or other web-connected devices that you use for browsing to our Website that you use to access to the Platform or Website. Information we obtain from these devices includes:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types and plugins.
• Device operations: information about operations and behaviors performed on the device.
• Identifiers: unique identifiers, device IDs and other identifiers such as from games, apps or accounts that you use and Family Device IDs.
• Device signals: Bluetooth signals, information about nearby Wi-Fi access points, beacons and mobile phone masts.
• Data from device settings: information you allow us to receive through device settings that you turn on, such as access to your camera or photos.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed etc.

 HOW SURGBUDDY USES INFORMATION

SurgBuddy uses the information we collect about you or that you provide to us to improve, support and administer the Platform, to allow you to use its features and functionalities, and to fulfill and enforce our Terms of Use.

We generally use the information we collect:

• To fulfill requests for services, products, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.
• To improve and develop our Platform and conduct product development.
• To support the social functions of the Platform, including permit you and other users to connect with each other through the Platform and for you and other users to interact with Submissions posted through the Platform.
• To use Contents as part of our advertising and marketing campaigns to promote the Platform.
• To understand how you use the Platform, including across your devices.
• To infer additional information about you, such as your age, gender and interests.
• To help us detect abuse, fraud, and illegal activity on the Platform.
• To communicate with you.
• To enforce our terms, conditions and policies.
• To inform our algorithms.
• To combine all the information, we collect or receive about you for any of the foregoing purposes.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
• To provide contents and user support and match you with the possible surgery buddies.
• To detect, prevent and address technical issues and improve the security of the Platform.
• To validate the authenticity the Platform and display the content provided by you to others.
• To customize advertising, you may see on our Platform.
• To contact you via email or through your account to notify you.
• To measure the performance of email marketing campaigns.
• To allow you to participate in interactive features on our Platform.
• To fulfill any other purposes for which you provide it.

OUR LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA 

It is not possible to collect or process your personal data without a legal basis. Our legal bases for the processing of your personal data cover the consents you have given to us, the Terms of Use you have made with us to benefit from the SurgBuddy Platform, services and its products and SurgBuddy’s legitimate interests that justify the data processing.

In cases where we process your personal data based on your consent, you have always right to withdraw and remove this consent at any time. You also have right to object where we process your personal data based on SurgBuddy’s legitimate interests.

DISCLOSURE POLICY 

We are committed to maintaining your trust. SurgBuddy does not sell personal information to third parties. However, we want you to understand that we provide personal information and non-personally-identifiable information to our subsidiaries, affiliated companies, or other businesses or persons for the purpose of processing such information on our behalf, including, but not limited to, providing analytics, monitoring our Platform, marketing, distribution of surveys or giveaway programs. We require that these parties agree to process such personal information in compliance with this Privacy Policy and any other appropriate confidentiality and security measures as well as for the sole purpose of providing the specific service to SurgBuddy. The third-party service providers are not permitted to share such personal information or use it for any other purpose. We share your information with:

• Service Providers and Business Partners

We share your personal information with service providers and business partners to help us perform business operations and for business purposes, including research, database maintenance, administering contests and special offers, technology services, deliveries, sending communications, advertising, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing and data processing.

• Legal Authorities

We may disclose any of the information we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries and to protect and defend the rights, interests, safety and security of SurgBuddy, the Platform, the Website, our affiliates, users, or the public. We may also share any of the information we collect to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law. However, in the light of our Privacy Policy and at our sole discretion, we may object to share your information where the request is too broad, unclear or disproportionate or where the necessary permissions for such a request have not been obtained. However, this does not mean that we have an obligation to object to information requests addressed to us.

• New Owner

If our company is sold to someone else or ownership or control of all or part of our service and products or their assets changes, we may transfer your information to the new owner. However, in this case, it is obligatory to continue using your information within the framework of this Privacy Policy.

• Your Consent

We may share your information for other pursuant to your consent or at your direction. If you choose to engage in public activities on the Platform, you should be aware that any information you share may be read, collected, or used by other users. Public information can be seen by anyone, on or off our products, including your username, any information you share with a public audience, information in your profile, and content you share. You should consider who you choose to share your personal information and submissions with, because people who can see your activity on our products can choose to share it with others on and off our products, including people and businesses outside the audience that you shared with. For example, when you share a post or send a message to specific accounts, they can screenshot or reshare that content to others across or off our products. Also, when you comment on someone else’s post or react to their content, your comment or reaction will be visible to anyone who can see the other person’s content, and that person will be able to change the audience later. People can also use our products to create and share content about you with the audience they choose. For example, people can share a photo of you, mention or tag you, or share information about you in their posts or messages. If you are uncomfortable with what others have shared about you on our products, you may report the content. 

• Cross-Border Data Transfers

SurgBuddy’s servers are located and operated in Turkey. However, in order to provide our products and services properly, such as the quality and speed of the services, SurgBuddy may need to transfer, transmit, process and store your information to data centers outside of the country. Countries where we process data may have laws which are different from, and potentially not as protective as or broader than, the laws of your own country. Through your continued to use of the SurgBuddy Platform, products and services, you consent to the transfer, transmit, process and store of your personal information to Turkey and other countries.

YOUR RIGHTS AND ACCESS 

You may not choose to provide personal information through our Platform, however, in that situation, SurgBuddy may not be able to provide certain services to you or respond to your requests. You can access, review and change your personal information by logging into your account on the Platform and visiting your account profile page. We recommend you keep your personal information up to date to access and use the Platform properly. If you no longer want to be a part of SurgBuddy, you can delete your account at any time you want. Once you choose to delete your account, we will retain your personal information for a reasonable time period in accordance with the privacy practices in this policy or if required to do so as a result of a legal obligation.

We retain most of your personal data for as long as you have an account on the Platform or necessary for us to provide you our products and services. Data retention also includes data that you or others give to us or that we provide or create from the use of our services.

We give you the opportunity to control and manage the personal information we have about you by providing options about deleting, correcting, changing your data, sharing settings and advertising and communication preferences regarding the collection, use and disclosure of your data.

About your personal data:

• You may control what personal data is retained by us, request detailed information about them and request a copy of your data in machine-readable format.
• You can request information about whether your personal data is used for the purpose of the collection and whether it is transferred to third-parties.
• You can change or/and correct your inaccurate and outdated personal data through your account, and in certain cases you can ask us to change, update or correct it.
• You can request from us to delete or remove all or some of your personal data. This will mean that you no longer want to use our services.
• If you have requests for data deletion or correction, you may request that the transactions made in line with your request be notified to the third-parties to whom your data has been transferred.
• If you have an objection about the accuracy or actualness of your personal data, you can request that we stop the use of your data partially or completely or restrict its use until its accuracy is confirmed or if you submit a data deletion request since that we do not have a legal right to use your personal data until this request is fulfilled.
• You can object to this situation if a result arises against you by analyzing your data processed by us exclusively through automated systems.
• You can object to the retain of your personal data for direct marketing purposes.
• If you suffer a loss due to unlawful processing of your data, you can request the compensation of the damage.

ACCOUNT CLOSURE AND DATA STORAGE

If you choose the delete your account, the visibility of your data within the Platform and our services will be stopped. We will delete the information of a closed account upon account closure, with the exceptions noted below. However, we will continue to retain your non-personal information after your account has been deleted. 

Even if you have closed your SurgBuddy account, we will continue to retain your personal information in case of fulfillment of our legal obligations, resolving disputes, ensuring the security, preventing fraud or any other abuse, implementation of our Terms of Use and similar requirements. 

Even if you close your account or delete that information from your profile and chat box, the information and messages you share with other people in your use of the Platform continue to be viewed by those people. You should know that we do not have the control the data those other users copy over the Platform and our services. In addition, the content and comments of closed accounts which were shared in groups on the Platform continues to appear as unknown. Also, your profile may continue to appear on other services (for instance, search engines) until they update their cache memories.

SECURTIY AND STORAGE

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. However, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. Also, you should know that you are solely responsible for maintaining the secrecy of your account password and information at all times. Do not share your account password and information with any other person or third party.

PRIVACY OF THE CHILDREN

Privacy of the children is highly important to SurgBuddy. For that reason, SurgBuddy does not knowingly collect or maintain personal information from persons under 18 years old, and no part of the Platform is directed to anyone under 18. If you are under 18 years old, then please do not use or access the Platform at any time or in any manner. If we detect that personal information of persons under the age of 18 has been collected, or anyone under 18 using or accessing the Platform, both the information and the account will be deleted immediately.

LINKS TO OTHER APPLICATIONS OR WEBSITES 

Our Platform may contain links to other websites or applications that are not operated, controlled and maintained by SurgBuddy. If you click on a third-party link, you will be directed to that third party’s application or website and this Privacy Policy does not cover any of the third party website or application. We strongly recommend you review privacy policy of the third-party websites and applications you visit.

CONTACT WITH US 

SurgBuddy Platform, products and services are provided and controlled by SB Bilişim ve Yazılım Hizmetleri A.Ş. SB Bilişim ve Yazılım Hizmetleri A.Ş., as ‘’data controller’’, will be responsible for the collection, use, disclosure and storage of your personal information. 

If you have any questions or complaints about the process, storage use or disclosure of your personal information, please contact with SurgBuddy via info@surgbuddy.com.