Privacy Policy

ORTOHERO Aligner ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by ORTOHERO Aligner.

This Privacy Policy applies to our application ORTOHERO Aligner, together with our website/app and associated sub-domains (collectively, "Our Service"). By accessing or using our Service, you acknowledge that you have read, understood, and agree to the collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

To help explain things in this Privacy Policy as clearly as possible, whenever any of these terms are referenced, they are strictly defined as follows:

• Cookie: A small amount of data generated by a website and stored by your web browser. It is used to identify your browser, provide analytics, and remember information about you such as your language preference or login details.
• Company: In this policy, when "Company," "we," "us," or "our" is used, it refers to Seffaf Aparey Ortodonti ve Elektronik A.S. (Resatpasa Mah. ITU ARI 1 2/205 Sariyer Istanbul), which is responsible for your information under this Privacy Policy.
• Country: Where ORTOHERO Aligner or the owners/founders of ORTOHERO Aligner are located, in this case Turkey.
• Customer: Refers to the company, organization, or person that registers to use the ORTOHERO Aligner Service to manage relationships with your consumers or service users.
• Device: Any internet-connected device such as a phone, tablet, computer, or any other device that can be used to visit ORTOHERO Aligner and benefit from the services.
• IP Address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often identify the location from which a device connects to the Internet.
• Personnel: Refers to individuals employed by ORTOHERO Aligner or contracted to perform a service on behalf of either party.
• Personal Data: Any information that allows the identification or identifiability of a real person, directly, indirectly, or in connection with other information, including personal identification numbers.
• Service: Refers to the service provided by ORTOHERO Aligner as described in the relevant terms (if any) and on this platform.
• Third-Party Service: Refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we believe may interest you.
• You: A person or organization registered with ORTOHERO Aligner to use the services.

When you visit our website/app, register on our site, place an order, subscribe to our newsletter, respond to a survey, or fill out a form, we collect information from you.

• Name / Username
• Email Addresses
• Password

While these features are entirely optional, we also collect information from mobile devices for a better user experience:

• Camera (Images): Granting camera permission allows the user to upload any image directly from the platform. You can safely deny camera permissions for this platform.
• Photo Gallery (Images): Granting photo gallery access permission allows the user to upload any image from their photo gallery. You can safely deny photo gallery access for this platform.

ORTOHERO Aligner will collect the End User Data necessary to provide ORTOHERO Aligner services to our customers. End users may voluntarily provide us with information they make available on social media websites. If you provide us with such information, we may collect publicly available information from the social media websites you specify. You can control how much of your information social media websites make public by visiting those websites and changing your privacy settings.

We receive some information from third parties when you interact with us. For example, when you send us your email address indicating your desire to become an ORTOHERO Aligner customer, we receive information from a third party that provides ORTOHERO Aligner with automated fraud detection services. We also occasionally collect information that is publicly posted on social media websites. You can control how much of your information social media websites make public by visiting those websites. You can visit the websites and change your privacy settings.

We may share personal and non-personal information we collect with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we believe may interest you. We may also share it with our current and future affiliates and business partners, and if we are involved in a merger, asset sale, or other business reorganization, we may share or transfer your personal and non-personal information to the relevant successors.

We may contract with trusted third-party service providers to perform functions and provide services to us such as hosting and maintaining our servers and website/app, database storage and management, email management, storage marketing, credit card processing, customer service, and fulfilling orders for products and services you may purchase through the website/app. We will share your personal information and possibly some non-personal information with these third parties to enable them to perform these services for us and for you.

We may share some of our log file data, including IP addresses, with third parties such as web analytics partners, app developers, and advertising networks for analytical purposes. If your IP address is shared, it may be used to estimate other technographic information such as general location and connection speed, whether you visited the website/app from a shared location, and the type of device used to visit the website/app. They may collect information about our ads and what you see on the website/app, and then provide auditing, research, and reporting for us and our advertisers.

We may also, at our own discretion, disclose personal and non-personal information about you to government or law enforcement officials or private parties if we believe it is necessary or appropriate to respond to requests, legal processes (including court orders), to protect our rights and interests or the rights and interests of a third party, to ensure public safety or the safety of any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with applicable court orders, laws, rules, and regulations.

ORTOHERO Aligner will collect the personal information you send to us. We may also receive personal information about you from third parties as described above.

Any of the information we collect from you may be used in one of the following ways:

• To personalize your experience (your information helps us better respond to your individual needs)
• To improve our website/app (we continually strive to improve our website/app offerings based on the information and feedback we receive from you)
• To improve customer service (your information helps us more effectively respond to your customer service requests and support needs)
• To process transactions
• To administer a contest, promotion, survey, or other site feature
• To send periodic emails

By submitting your email address on this website/app, you agree to receive emails from us. You may cancel your subscription to any of these email lists at any time by clicking on the unsubscribe link contained in the respective email or other unsubscribe options. We only send emails to people who have authorized us to contact them, directly or through a third party. We do not send unsolicited commercial emails because we hate spam as much as you do.

By submitting your email address, you also authorize us to use your email address for customer audience targeting on sites such as Facebook. On these sites, we show specific ads to people who have opted in to receive communications from us. Only email addresses submitted through the order processing page will be used solely to send you information and updates about your order. However, if you have provided us with the same email through another method, we may use it for any of the purposes specified in this Policy. Note: If you wish to opt out of receiving future emails at any time, we include detailed opt-out instructions at the bottom of every email.

We keep your information only for as long as we need it to provide ORTOHERO Aligner to you and to fulfill the purposes described in this policy. This also applies to anyone we share your information with who performs services on our behalf. When we no longer need to use your information and are not required to keep it to comply with our legal or regulatory obligations, we will remove or anonymize it from our systems so that you cannot be identified.

When you place an order or enter, submit, or access your personal information, we implement various security measures to maintain the safety of your personal information. We offer the use of a secure server. All sensitive/credit information provided is transmitted through Secure Socket Layer (SSL) technology and is then encrypted into our payment gateway provider database, which is only accessible by authorized persons with special access rights to such systems, and they are required to keep the information confidential.

After a transaction, your private information (credit cards, social security numbers, financial information, etc.) is never stored on file. However, we cannot ensure or guarantee the absolute security of any information you transmit to ORTOHERO Aligner or that your information on the Service will not be accessed, disclosed, altered, or destroyed due to any breach of our physical, technical, or administrative security measures.

ORTOHERO Aligner is established in Turkey. Information collected through our website/app, through direct interactions with you, or through the use of our support services may be transferred from time to time to our offices, personnel, or third parties around the world, and may be viewed and hosted anywhere in the world, including countries that do not have generally applicable laws governing the use and transfer of such data. To the fullest extent permitted by applicable law, by using any of the above, you voluntarily consent to the cross-border transfer and hosting of such information.

We take measures to protect the security of your information. We have physical, electronic, and administrative procedures to help protect your information, prevent unauthorized access, maintain data security, and ensure correct use. However, neither people nor security systems, including encryption systems, are perfect. Additionally, people may intentionally commit crimes, make mistakes, or fail to comply with policies. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes a non-waivable duty to protect your personal information, you agree that the standard used to measure our compliance with this duty would be intentional misuse.

Your right to request an update or correction to the information ORTOHERO Aligner collects depends on your relationship with ORTOHERO Aligner. Personnel can update or correct their information as detailed in our internal employment policies.

Customers have the right to request that certain uses and disclosures of personally identifiable information be restricted as follows. You may contact us by canceling your account to (1) update or correct your personally identifiable information, (2) change your preferences for communications and other information you receive from us, or (3) delete the personally identifiable information we hold about you in our systems (subject to the following paragraph). Such updates, corrections, changes, and deletions will not affect other information we held or provided to third parties in accordance with this Privacy Policy prior to such updates, corrections, changes, or deletions. To protect your privacy and security, we may take reasonable steps to verify your identity before granting you profile access or making corrections (such as requesting a unique password). You are always responsible for maintaining the confidentiality of your unique password and account information.

You should be aware that it is not technologically possible to remove every record of information you provide us from our system. The need to back up our systems to protect against accidental data loss means that a copy of your information may exist in an irreversible format that would be difficult or impossible for us to locate and delete. Upon receiving your request, all personal information stored in actively used databases and other easily searchable media will be updated, corrected, modified, or deleted as quickly and to the extent reasonably and technically possible.

If you are an end user and wish to update, delete, or retrieve any information we hold about you, you may do so by contacting the organization you are a customer of.

If you are an ORTOHERO Aligner employee or applicant, we collect information you voluntarily provide to us. We use the collected information for Human Resources purposes, to administer employee benefits, and to screen applicants.

You may contact us to (1) update or correct your information, (2) change your preferences for communications and other information you receive from us, or (3) receive a copy of the information we hold about you. Such updates, corrections, changes, and deletions will not affect other information we maintain or information we have provided to third parties under this Privacy Policy prior to such updates, corrections, changes, or deletions.

In the event of the sale, merger, or other disposition of all or substantially all of the assets of ORTOHERO Aligner or any of its Corporate Affiliates (as defined below), or the sale, merger, or other disposition of the portion of the Service to which ORTOHERO Aligner or any of its Corporate Affiliates relates, or if we cease doing business or file for bankruptcy, reorganization, or similar proceeding, or if a petition is filed against us, we reserve the right to transfer information to a third party, provided that the third party agrees to comply with the terms of this Privacy Policy.

We may disclose information about you (including personal information) to our Corporate Affiliates. For the purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity that directly or indirectly controls, is controlled by, or is under common control with ORTOHERO Aligner, whether through ownership or otherwise. Any information about you that we provide to our Corporate Affiliates will be handled by such Corporate Affiliates in accordance with the terms of this Privacy Policy.

This Privacy Policy is governed by the laws of Turkey, without regard to its conflict of laws provisions. Except for individuals who may have the right to assert claims under the Privacy Shield or the Swiss-US framework, you accept the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy.

This Agreement and your use of the website/app shall be governed by the laws of Turkey, excluding its conflict of laws rules. Your use of the website/app may also be subject to other local, state, national, or international laws.

By using ORTOHERO Aligner or contacting us directly, you indicate your acceptance of this Privacy Policy. If you do not accept this Privacy Policy, you should not interact with our website/app or use our services. Your continued use of the website/app, your direct interactions with us, or your following of published changes that do not significantly affect the use or disclosure of your personal information in this Privacy Policy, will signify your acceptance of such changes.

We have updated our Privacy Policy to provide you with full transparency about what is set and how it is used when you visit our site. By using our ORTOHERO Aligner, registering an account, or making a purchase, you accept our Privacy Policy and agree to its terms.

This Privacy Policy applies only to the Services. The Services may contain links to other websites that are not operated or controlled by ORTOHERO Aligner. We are not responsible for the content, accuracy, or opinions expressed on these websites, and these websites are not investigated, monitored, or checked for accuracy or completeness by us. Please note that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your navigation and interaction on any other website, including those linked from our platform, is subject to that website's own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

ORTOHERO Aligner uses "Cookies" to identify the areas of our website/app that you visit. A cookie is a small piece of data stored on your computer or mobile device by your web browser. We use cookies to enhance the performance and functionality of our website/app, but their use is not strictly necessary. However, without these cookies, certain functions such as videos may not be available, or you may need to enter your login credentials every time you visit the website/app because we cannot remember that you previously logged in. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to properly access or use the functionality of our website/app at all. We never place Personally Identifiable Information in Cookies.

Wherever you are, you can set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website/app from functioning properly, and you may not be able to fully use all its features and services. You should also be aware that if you block cookies in your browser, you may lose some saved information (such as saved login details, site preferences). Different browsers offer you different controls. Disabling a cookie or cookie category does not delete the cookie from your browser; you will need to do this yourself from within your browser. For more information, you should visit your browser's help menu.

We use remarketing services. What is Remarketing? In digital marketing, remarketing (or retargeting) is the practice of serving ads to people across the internet who have previously visited your website/app. It makes your company appear to "follow" people online by serving ads on the websites and platforms they use most.

We do not target anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and are aware that your child has provided Personal Data to us, please contact us. If we discover that we have collected Personal Data from anyone under the age of 13 without verified parental consent, we will take steps to remove such information from our servers.

We may change our Service and our policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and our policies. Unless required by law, we will notify you before making changes to this Privacy Policy (for example, through our Service) and allow you to review them before they take effect. Thereafter, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not wish to accept this or any updated Privacy Policy, you may delete your account.

We may display, add, or make available third-party content (including data, information, applications, and other product services) or provide links to third-party websites or services ("Third-Party Services").

You acknowledge and agree that ORTOHERO Aligner will not be responsible for any Third-Party Service, including its accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality, or any other aspect thereof. ORTOHERO Aligner will not assume and shall not assume any obligation or liability to you or any other person or organization for any Third-Party Service.

Third-party services and links thereto are provided solely for your convenience, and your access to and use of them is entirely at your own risk and subject to the terms and conditions of the respective third parties.

Facebook Pixel is an analytics tool that allows you to measure the effectiveness of your advertising by understanding the actions people take on your website/app. You can use the Pixel to ensure your ads are shown to the right people. Facebook Pixel may collect information from your device when you use the service. Facebook Pixel collects information held under the Privacy Policy.

• Google Maps API: Google Maps API is a robust tool that can be used to create a custom map, searchable map, check-in features, live data display synchronized with location, route planning, or a mashup, to name a few. It may collect information from You and your Device for security purposes. Google Maps API collects information held under the Privacy Policy.
• Cookies: We use cookies to enhance the performance and functionality of our platform, but their use is not strictly necessary. However, without these cookies, certain functions such as videos may not be available, or you may need to enter your login credentials every time you visit the platform because we cannot remember that you previously logged in.
• Local Storage: Local Storage, sometimes also known as DOM storage, provides web applications with methods and protocols for storing client-side data. Web storage is similar to cookies but with a greatly improved capacity and supports persistent data storage with no information stored in the HTTP request header.
• Sessions: We use "Sessions" to identify the areas of our platform you visit. A session is a small piece of data stored on your computer or mobile device by your web browser.

If you are from the European Economic Area (EEA), we may collect and use information from you, and in this section of our Privacy Policy, we will explain exactly how and why this data is collected and how we protect it from being duplicated or improperly used.

GDPR is an EU-wide privacy and data protection law that regulates how the data of EU residents is protected by companies and increases the control of EU residents over their personal data.

GDPR applies not only to EU-based businesses and EU residents but to any company operating globally. Our customers' data is important regardless of where it is located, which is why we have implemented GDPR controls as the baseline standard for all our operations worldwide.

Any data relating to an identified or identifiable person. GDPR covers a wide range of information that can be used on its own or in combination with other pieces of information to identify a person. Personal data goes beyond a person's name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity.

Data Protection Principles include requirements such as:

• Personal data collected must be processed fairly, lawfully, and transparently, and used only in a way that a person would reasonably expect.
• Personal data must be collected only to fulfill a specific purpose and used only for that purpose. Organizations must state why they need personal data when collecting it.
• Personal data must not be kept longer than necessary for the purpose for which it was processed.
• Individuals covered by GDPR have the right to access their data. They can also request a copy of their data and ask for their data to be updated, deleted, restricted, or transferred to another organization.

GDPR adds some new requirements for how companies protect the data of individuals they collect and process. It also raises the bar for compliance by increasing enforcement and applying higher penalties for violations. Beyond these facts, it is the right thing to do. At ORTOHERO Aligner, we believe your data privacy is of paramount importance, and our robust security and privacy practices already in place go beyond the requirements of this new regulation.

We are committed to helping our customers meet GDPR's data subject rights requirements. ORTOHERO Aligner processes or stores all personal data on fully vetted, DPA-compliant providers. We retain all conversations and personal data for up to 6 years as long as the account is not deleted. In this case, we destroy all data in accordance with our Terms of Service and Privacy Policy, but we will not retain it for longer than 60 days.

If you work with EU customers, we understand that you need to be able to provide them with the ability to access, update, retrieve, and remove personal data. We understand you! We have been set up as self-service from the beginning and have always allowed you to access your data and your customers' data. Our customer support team is here to answer any questions you may have about working with the API.

If you have any questions about this Privacy Notice, please contact us at: info@orthero.com.tr