Definitions:

GDPR: General Data Protection Regulation (EU) 2016/679 (GDPR)

KVKK: Personal Data Protection Law

Personal Data: Information about a natural person whose identity can be directly determined. Personal Data includes information as well as opinions or statements of intent.

Data Controller / Controller: The organization that determines the purpose for which Personal Data will be processed. In this case, New Biotechnology Joint Stock Company.

VKG: Data Protection Officer is a person appointed to deal with all matters related to data. While creating this policy, our VKG is Emre MEMO. You can send all problems or questions about the data to this person at the following e-mail address: emrememo@yenibio.com

Processors: The personnel of the New Biotechnology Joint Stock Company are authorized to fulfill the responsibilities of the Data Controller.

“Staff members” – employees, contractors, consultants and anyone acting on behalf of our organization.

Users: Any person who browses the public website, is interested in our support, speaks to our staff, creates a profile, or uses our site, app, or test kit.

Personal Data Infringement: Loss, theft or unauthorized access, use or disclosure of Personal Data.

Privacy Policy: This document.

“Our website” or “Site” – www.yenibio.com or www.spermcell.net

“Our APP” – a downloadable mobile app – SpermCell™ is currently available on the Apple APP store and Google Play, and may be available on additional sites or stores in the future.

“Third parties” – Suppliers, business contacts, staff of our users and other people who may need to contact us.

Information We Collect and Store:

Personal Data means any information about a person that can determine the identity of that person. We currently collect and process the following information about some people in order to improve the SpermCell™ – Smartphone Applied Sperm Analyzer customer experience.

If you register for the APP or the site, you create a profile with the following data:

Profile Data (Optional): first name, last name, age and gender.

Contact Data: includes approximate location data, e-mail address, wi-fi name, internet connection details, connection speed.

Contact Data: includes your preferences and communication preferences for getting support from us.

When you log in to the site or application, we also collect the following data:

Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, operating system and other technologies on the devices you use to access this website.

Customer Support Data: includes feedback and survey responses. If you have participated in a web chat or have contacted us via email or live chat, we will keep a record of that conversation.

Usage Data: Contains information about how you use our application, website, products and services.

As described herein, there are limited circumstances when we collect data about your health, which is a special category of Personal Data called Protected Health Information (PHI) and entitled to increased protection.

In most cases, when you use the APP to load the test results, we don't know that the results belong to a specific person and we have no way to know. In these cases, although we have result data, they are completely anonymous.

However, in some cases, such as questions about optional account registration, support query, or test results, we may receive and store your results anonymously. In this case, we have both personally identifiable information, including the qualitative results of Sperm Concentration, Motility, Velocity, Volume and Semen Quality Reviews and a video recording, as well as the results of the user's semen analysis tested by our APP (SpermCell™).

We recognize the sensitivity of your health data and therefore we have implemented a policy aimed at never storing more data than we need, keeping such data only for the minimum required period of time and keeping it under strict security protocol and destroy it regularly. If you want to know more, please contact our VKG.

Except for the health data described above, we do not collect any Special Category Personal Data relating to you (including your race or ethnic origin, religious or philosophical beliefs, sexual orientation, political views, trade union membership, and genetic and biometric data) unless provided on a voluntary basis. We do not collect any information about criminal convictions and crimes.

How do we collect this information?

Most of the personal information we process is provided to us directly in the following ways/ways:

You create an account and give us your e-mail address

You upload the test results

When you create an account with us, you agree to disclose your personal data (especially your email address and location) to us.

When you upload your test results, you fill out a declaration and agree to allow us to access them for limited purposes.

What do we do with your information?

The information we receive from you is obtained for the following reasons:

We analyze the test results to check if the customer-reported issue is related to a software bug or another software issue. Then we use the email address to communicate with the customer and support the customer.

Geolocation data – we use this data to establish a Wi-Fi connection and recommend doctors near you.

Within the scope of the General Data Protection Regulation (GDPR), the legal bases we rely on to process this information are:

There are many justified reasons that allow the collection and processing of Personal Data under the GDPR. We mainly rely on:

Consent: Certain circumstances allow us to collect your Personal Data, for example when you create an account and provide us with your email or upload your test results and authorize us to receive that data. Thus, you allow us to receive, retain and process data.

Contractual Obligations: We may request certain information from you to fulfill our contractual obligations and to provide you with the promised service.

Legal Compliance: As required by law, we are required to collect and process certain types of data, such as fraudulent activities or other illegal acts.

Legitimate Benefit: We may need to collect certain information from you in order to be able to meet our legitimate interests – this includes areas that may be reasonably expected as part of conducting our business, which will have no material impact on your rights, freedoms or rights. Examples can be your geolocation, so the APP can physically recommend doctors or other service providers near you.

We rely on explicit consent for the collection of special category data (Protected Health Information).

We may share this information with:

We may share your Personal Data with subcontractors (only when necessary and with your consent) or with affiliates or for the purpose of additional clinician advice or doctor referral (subject to privacy obligations, to use only for the purposes we disclose to the user) and according to our instructions).

Or in connection with the licensing of our technology, we may also share it with the relevant parties.

In the event of the sale or sale or transfer of Yeni Biyoteknoloji Anonim Şirketi, we may, in our sole discretion, sell or transfer your Personal Data and Protected Health Information to a third party as part of such transaction. Upon this transfer, the data privacy policy of the acquisition organization may govern the subsequent use of your Personal Data. In such a case or in connection with the licensing of our technology, we may also share it with relevant parties.

In all other cases, your data will continue to be protected in accordance with this Data Privacy Policy (as modified from time to time).

We may share your Personal Data Protected Health Information at any time for legal reasons or if necessary to enforce our Terms of Use/Terms of Service or this Data Privacy Policy for our Site.

Our APP or Site may contain links to third-party websites, plugins and applications. Clicking on or enabling these links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our app or Site, please review the privacy policy of each website you visit.

How to store your information

Your information is stored securely in PostgreSQL. We store data in secure cloud services operating in Helsinki, Finland. PostgreSQL is fully compliant with the model items for data transfer between the EU and Turkey GDPR, which has earned it a strong reputation in terms of reliability, feature reliability and performance. We recommend that you read their statements and policies in full.

We do not usually delete information that we hold for the benefit of our users who may want to use our services in the future, but if we request result data that is special category data, we will make every effort not to delete it. we will keep it for more than a year and we will do so by completely anonymizing any result data we receive so that it cannot be associated with a specific person. You can also request the deletion of the data referring to you by contacting the company.

We have implemented a security concept by design and we constantly implement strict data protection measures to ensure the security of your data.

We take at least the following measures:

We protect databases with a unique password (the database can be accessed from a password-protected website)…