Oteo Health & Information Technologies

Privacy Policy

OTEO’s Online Privacy Statement

At OTEO, www.oteo.com.tr, and www.oteohealth.com, we are firmly committed to protecting your privacy. You can navigate most of our websites without giving us any personal information about yourself. However, sometimes we need additional information about you to provide the information or services you request.

Your privacy is important to us. To protect your privacy, we provide this notice explaining our online information practices and the choices you can make about how your information is collected and used.

Scope

This Policy applies to Personal Information that is Processed by OTEO on OTEO websites (each a “Site”), mobile applications, and other online offerings (together with all future online offerings) operated by or on behalf of OTEO (the “Services”). “Personal Information” is information about an identified or identifiable natural person.  This Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

What information do we collect about you?

1-We may collect the following types of Personal Information from you through this website: name, title, and contact details, including e-mail address and telephone numbers. We also may collect additional information when you register to access services available through our network of websites.

2-On some pages, you may opt to provide us information about yourself, for example, if you are interested in (a) an employment opportunity at OTEO; or (b) having OTEO participate in your event. The information requested from you will be based on your area of interest.

3-On occasion, OTEO may request that you voluntarily participate in a survey or poll, such as feedback on website content or services. Your responses will be anonymous unless you opt into being contacted by e-mail to provide further information regarding the survey.

4-In order to improve the design and content of our website, to enable us to personalize your user experience better, and for other purposes outlined in this Policy, we may collect certain technical information about our visitors when you visit our website pages, such as the IP address or the type of browser you are using, the type of operating system you are using, the domain name of your Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through the use of the Services such as preferences.

5-We may receive information about you from other sources, including through third-party services and organizations to supplement your intake. This supplemental information allows us to verify the information you provided and enhance our ability to provide you with information about our business, products, and Services. For example, suppose you access third-party services, such as Facebook or Twitter, to login to the Services or to share information about your experience with OTEO. In that case, we may collect information from these services.

6-From time to time, we may provide Services specifically designed to be compatible and used on mobile devices. OTEO will collect certain information (including Personal Information) that your mobile device sends when you use such Services, like a device identifier, user settings, and the operating system of your device. Mobile versions of OTEO’s Services may require that users log in with an account. In such cases, information about using mobile versions of the Services may be associated with user accounts. In addition, we may enable you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to OTEO to enable you to access user accounts and to enable us to track the use of these tools. Some of these tools may allow you to e-mail reports and other information from the instrument. OTEO may use Personal Information or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement, and as otherwise described in this Policy or other notices OTEO provides.

The way we use your information

We acquire, hold, use, and process Personal Information based on the legal grounds and for the legitimate business purposes outlined in this Policy or as otherwise clearly identified at the point of collection. Our legitimate business purposes for processing Personal Information include the following:

  • To provide products, Services, and information requested: We use your Personal Information to enable you to receive access to our products and services online, obtain information about our products and services and receive updates, participate in surveys or questionnaires posted on our website, provide you with opportunities to learn about our other products, programs, or services that we believe may be of interest to you, and to enable us to respond to your requests.
  • For administrative purposes: We also may use your Personal Information for our administrative purposes, such as to measure interest in and develop our services, ensure internal quality control, comply with regulatory requirements, prevent potentially prohibited or illegal activities, and enforce the OTEO Terms and Conditions of Use. We may also share the personal information of our customers’ employees for our customers to evaluate our Services.
  • To market our products and Services: Our use of Personal Information may also include providing you with materials about offers, products, and Services that may be of interest, including new content or Services. OTEO may provide you with these materials by phone, postal mail, facsimile, or e-mail, as permitted by applicable law.
  • For research and development: OTEO may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with data obtained from other sources to help us optimally deliver our existing products and Services or develop new products and Services. From time to time, OTEO may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of our products and services. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and promotional activities. If you participate in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
  • For marketing purposes: Individuals who provide us with Personal Information or whose Personal Information we obtain from third parties may receive periodic e-mails, newsletters, mailings, or phone calls from us with information on OTEO’s or our business partner’s products and services or upcoming special offers/events we believe may be of interest. In some cases, we may only contact you with your permission, and we always offer the option to decline these communications at no cost to the individual by following the instructions below.
  • Other purposes: OTEO may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information and with your consent.
  • To create anonymous and aggregated information: OTEO may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access OTEO’s Services, or other analyses we create. Anonymized and aggregated information is used for various functions, including measuring visitors’ interest in and using multiple portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in several ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within OTEO and with third parties for our or their goals in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
  • Information you submit via the Services: You agree that OTEO is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose, including developing, manufacturing, and marketing goods or Services. OTEO will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you permit us to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Do we share your information?

We may share your Personal Information as described in this Policy (e.g., with our third-party service providers to comply with legal obligations; to protect and defend our rights and property) or with your permission.

  • Vendors and Service Providers: We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; iv) customer service activities; and (v) in connection with the provision of the site. OTEO has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
  • Business Partners: OTEO may share Personal Information with our business partners and affiliates for our affiliates’ internal business purposes or to provide you with a product or service you requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services or whose products or services we believe may interest you. In such cases, our business partner’s name will appear, along with OTEOs. OTEO requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of the Personal Information they maintain on our behalf and not to use it by any means or for any purpose other than the means and purpose for which we provided it. Further, OTEO may share with its customers the names of a customer’s employees who utilize OTEO services if and to the extent necessary to enable the customer to evaluate our Services.
  • Displaying to Other Users: The content you post to the site may be displayed on the site if you submit a review. In such a case, other site users may be able to see some information about you, such as your name. We are not responsible for the privacy practices of the other users who will view and use the posted information.
  • Marketing, Interest-Based Advertising, and Third-Party Marketing: Through our Services, OTEO may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share de-identified information and selected Personal Information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) to deliver targeted advertisements when you visit non-OTEO-related websites within their networks. This practice is called “interest-based advertising” or “online behavioral advertising.” Subject to applicable law, we may allow access to other data collected by the site to facilitate the transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you. If you prefer that we do not share your Personal Information with third-party advertising partners, you may opt out of such sharing at no cost by following the instructions below.
  • Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures): We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce OTEO policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies to identify users in connection with their investigation of unauthorized activities.

  • Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and contract. Should such an event occur, OTEO will endeavor to direct the transferee to use Personal Information in a manner consistent with the Policy in effect at the time such Personal Information was collected and will comply with any legal or regulatory additional requirements applicable to those transfers.

We do not share personally identifiable information with unrelated third parties who are not covered by this privacy statement without your prior permission, except to the extent reasonably necessary to: (i) correct technical problems and malfunctions; (ii) protect the security and integrity of our website; (iii) protect our rights, interests and property and the rights, interests, and property of others; (iv) comply with laws or to respond to judicial process; or (v) provide information to law enforcement agencies or for an investigation of a matter as applicable, or otherwise as required or permitted by law.

Our commitment to data security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have established appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the Internet cannot be guaranteed 100% secure, and we cannot ensure or warrant the security of any information you provide. We do not accept liability for unintentional disclosure.

By using the site or providing Personal Information, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your site use. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on the site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

Cookies, log files, and other technologies

We receive IP addresses in the ordinary course of the operation of our website. An IP address is a number assigned to you by your Internet service provider so you can access the Internet.

Third parties that provide content, advertising, or other functionality on our Services and we may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to collect information through the Services automatically. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record specific pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

  • Cookies: A cookie is a piece of data or file a website can send to your browser, which may then be stored on your computer system. Most browsers allow you to block and delete cookies. However, if you do that, the site may not work correctly, or you may not be able to receive personalized content. OTEO may use cookies on our website to:
  • Provide access to our content: for example, allow you to personalize your experience by keeping you logged in, accessing information, products, and services relevant to your areas of interest,
  • Show adverts that are more relevant to you: for example, with your consent, we use tracking technologies to remember content that has interested you and retain content that has engaged you. Cookies will also help limit the number of times you see an ad, measure the effectiveness of advertising campaigns, and help us and others track whether ads have been correctly displayed so we can pay for this. We also allow other organizations to use tracking technologies for these advertising purposes.
  • Analyze and improve your browsing experience: for example, track your session on our website, so we can learn what content interests you. We will also use cookies to understand general information about users, such as areas of interest. We also check for bugs and glitches in the content and
  • Prevent duplication: for example, when voting or participating in surveys.
  • Pixel tags/Web beacons: A pixel tag (also known as a web beacon) is a piece of code embedded on the site that collects information about users’ engagement on that web page. Using a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a specific advertisement.
  • Social Media Features: Our website includes social media integrations such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address and which page you visit on our site and set a cookie to enable the feature to function correctly. These social media features are hosted by a third party or hosted directly on our site. The company’s privacy policy governs your interactions with these features.

Analytics

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and demographics on some of our Services and develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated using the Services by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

  • Operationally Necessary. We may use cookies, web beacons, or other similar technologies necessary to operate our sites, services, applications, and tools; this includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
  • Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
  • Functionality Related. We may use cookies, web beacons, or other similar technologies to offer enhanced functionality when accessing or using our sites, services, applications, or tools; this may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;
  • Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content on our or third-party sites, including ads relevant to your interests; this includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you want to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Your rights

You may be asked, in some cases, to consent to the processing of Personal Information. In any case, you can opt out of specific uses and disclosures of your Personal Information.

Where you have consented to OTEO’s processing of your Personal Information, you may withdraw that consent at any time and opt out of further processing by following the instructions in this Section. Even if you opt out, we may still collect and use non-Personal information regarding your activities on our Sites and information from the advertisements on third-party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.

IMPORTANT NOTE:  Subscribers may provide data to us for processing, and OTEO data providers may collect information from the web that you do not supply directly to OTEO.  Suppose you desire to correct, amend or delete personal information that was provided to us by such third parties (and not directly by you). You may contact us to access, correct, or remove your information from our files. However, we also recommend contacting the third-party website operators to whom you have provided such information under third parties privacy policies.

If you receive an unwanted e-mail from us, you can use the unsubscribe link at the bottom of the e-mail to opt out of receiving future e-mails. We will process your request within a reasonable time after receipt.  Note that you will continue to receive transaction-related e-mails regarding products or services you have requested. We may also send you certain communications regarding OTEO and our Services, and you cannot opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Policy).

We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists within 60 days after receipt or such shorter time as may be required by law.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in specific web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Rights of access, rectification, erasure, and other rights

You may inquire whether OTEO is processing Personal Information about you, request access to Personal Information, and ask that we limit, restrict, port, correct, amend, or delete your Personal Information. If you are an EU resident, you may have additional rights available to you, including the right to file a complaint with your local data protection authority, the right to object to your data being processed, and certain rights related to our use of any automated decision-making processes (to the extent applicable). Where otherwise permitted by applicable law, you may send an e-mail to info@oteohealth.com or use any of the methods set out in this Policy to request access to, receive (port), seek rectification, request the erasure of Personal Information held about you by OTEO, or exercise any other rights available to you under applicable law. Such requests will be processed in line with local laws.

Although OTEO makes reasonable faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which OTEO is unable to provide access, including but not limited to where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. Suppose OTEO determines that access should be restricted in any particular instance. In that case, we will explain why that determination was made and provide a contact point for further inquiries. To protect your privacy, OTEO will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Our commitment to children’s privacy

Protecting the privacy of the very young is especially important. Therefore, we do not intend to collect or maintain information on our website from those we know are under 13 years of age, and no part of our website is structured to attract anyone under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at info@oteohealth.com. Suppose we know that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16). In that case, we will promptly take steps to delete such information and terminate the child’s account.

Data retention

The information you provide to us may be archived or stored periodically by us according to backup processes and will only be retained for as long as is required for the purposes for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Other third-party websites

Our website may contain links to other third-party websites. You should carefully review other websites’ privacy policies and practices, as we cannot control or be responsible for privacy policies or practices of third-party websites that are not OTEO’s websites.

For links to other OTEO’s websites, please review their privacy terms, as they may differ from those on this website.

Marketing

We would be pleased to send you information about our products, services, and other companies in our group that may interest you. If you have consented to receive marketing, you may opt out later.

Notification of changes

We keep our privacy statement under regular review and will place any updates on this web page. If you continue to visit this website and use the services made available after such changes, you consent to the changes as a result. If there are any material changes to this Policy, OTEO will notify you by e-mail or as otherwise required by applicable law.  We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is published (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new drive and allow you to opt out. Where consent of the individual for processing Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.

Last update current Policy: May 16, 2023

How to contact us

info@oteohealth.com