Informativa sulla privacy

Depending on how you interact with us, we may collect the following categories of information.

Contact and Identification Information

This may include:

• Name and surname
• Date of birth or age
• Country of residence
• Email address
• Telephone number
• WhatsApp number
• Preferred language
• Other contact information you voluntarily provide

Consultation and Health-Related Information

When you request a consultation, you may choose to provide information relevant to evaluating your request, including:

• Treatment or procedure you are interested in
• General health and medical history
• Previous treatments or procedures
• Current medical conditions
• Medications or allergies
• Dental information
• Photographs
• X-rays, scans, laboratory reports, medical records, or similar documents
• Information you include in consultation forms, messages, voice calls, or uploaded files

Health-related information may constitute sensitive or special-category personal data under applicable privacy laws and will be handled with additional safeguards where required.

Please provide only information reasonably necessary for your consultation.

We may collect information directly from you when you:

• Submit a consultation form
• Upload photographs, medical records, scans, or other documents
• Contact us through WhatsApp
• Call or receive a call from Avenia
• Communicate with our AI-assisted or human coordinators
• Send us an email
• Use our website or online services
• Request a quotation, consultation, appointment, transfer, accommodation, or other coordination service

We may also receive relevant information from an independent healthcare provider when necessary to coordinate a consultation or service requested by you.

Our website may automatically collect limited technical information such as IP address, device type, browser type, referring pages, approximate location derived from IP address, cookie identifiers, and website activity.

We may use your personal information to:

• Respond to your consultation request
• Understand the treatment or service you are interested in
• Connect you with appropriate independent healthcare providers
• Obtain preliminary assessments or proposed treatment information from healthcare providers
• Coordinate consultations and appointments
• Facilitate communications between you and healthcare providers
• Coordinate travel-related services such as airport transfers, accommodation, translation, and scheduling
• Contact you by telephone, WhatsApp, email, or other communication methods you have provided
• Provide follow-up coordination
• Maintain records of your requests and communications
• Improve our patient coordination services
• Protect against fraud, abuse, security threats, or unlawful activity
• Comply with applicable legal and regulatory requirements
• Establish, exercise, or defend legal rights where necessary

We will not use your health information for unrelated advertising purposes without an appropriate legal basis or consent where required by law.

To provide the consultation or coordination service you request, Avenia may share relevant information with independent physicians, dentists, surgeons, hospitals, clinics, laboratories, or other healthcare professionals involved in evaluating or providing your requested care.

Only information reasonably necessary for the requested consultation, treatment assessment, or coordination should be shared.

Independent healthcare providers are responsible for their own medical decisions, clinical records, privacy practices, and compliance with applicable healthcare and data protection laws.

Avenia does not control medical decisions made by independent healthcare providers.

Information concerning your health may receive heightened protection under applicable privacy laws.

Where required, we will obtain consent or rely on another legally permitted basis before processing or transferring sensitive health information.

By voluntarily submitting health information for the purpose of requesting a consultation, you are asking Avenia to use that information to facilitate your request and, where appropriate and legally permitted, to communicate relevant information to healthcare professionals who may assess your case.

Where separate explicit consent is required by applicable law, we will request that consent separately.

Avenia may communicate with you through telephone, WhatsApp, email, web chat, and AI-assisted communication systems.

Our virtual assistant may help:

• Answer general questions
• Collect consultation information
• Record your contact preferences
• Route requests to a coordinator
• Schedule follow-up
• Prepare summaries for our coordination team

AI-assisted systems do not provide medical diagnoses, medical advice, or treatment decisions.

Certain communications may be processed by technology service providers that support telephone, messaging, artificial intelligence, transcription, email, hosting, security, or customer relationship management services.

Where legally required, we will notify you before recording or transcribing telephone or voice communications.

Where permitted by applicable law and where appropriate notice or consent has been provided, calls or voice communications with Avenia may be recorded, transcribed, or summarized for purposes such as:

• Documenting consultation requests
• Quality assurance
• Staff training
• Service improvement
• Follow-up coordination
• Security and dispute resolution

We may retain transcripts or summaries instead of the original audio where appropriate.

If call recording is enabled, Avenia will implement any notice or consent mechanism required in the relevant jurisdiction.

If you communicate with Avenia through WhatsApp, your communications are also subject to the privacy and data processing practices of WhatsApp and Meta.

Messages, photographs, documents, voice messages, and other information you send through WhatsApp may be processed to respond to your request and coordinate your consultation.

You should avoid sending information through WhatsApp that is not necessary for your consultation.

We may use trusted third-party service providers to operate our services, including providers of:

• Cloud hosting
• Email
• Telephone services
• WhatsApp and messaging infrastructure
• Artificial intelligence and voice technology
• Data storage
• Website analytics
• Cybersecurity
• Customer relationship management systems
• Translation and communication tools

These providers may process information on our behalf according to their contractual responsibilities and applicable law.

We do not authorize service providers to use personal health information for their own unrelated purposes.

Avenia serves international patients and works with healthcare providers and technology providers in different countries.

As a result, your personal information may be processed or transferred outside the country in which you live, including to Türkiye and countries where our authorized technology providers operate.

Data protection laws may differ between countries.

Where required by applicable law, Avenia will use an appropriate legal mechanism for international transfers, such as consent, adequacy decisions, standard contractual clauses, contractual safeguards, or another legally recognized transfer mechanism.

Avenia does not sell personal health information to data brokers or third parties.

We do not sell consultation information, medical records, photographs, scans, or treatment enquiries for monetary consideration.

Where applicable privacy law defines “sale” or “sharing” more broadly, additional rights or disclosures may apply.

We may contact you regarding the consultation or service you requested.

Promotional or marketing communications will be handled separately where required by applicable law.

Where applicable, you may unsubscribe from promotional emails or request that we stop sending promotional communications.

Stopping marketing communications will not prevent us from sending messages reasonably necessary to manage an active consultation, transaction, request, appointment, or service.

Our website may use cookies and similar technologies necessary for:

• Website functionality
• Security
• Remembering preferences
• Measuring website performance
• Understanding how visitors use our website

Where required, non-essential analytics or advertising cookies will not be activated until appropriate consent has been obtained.

More detailed information may be provided through a separate Cookie Policy or cookie preference tool.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• Managing consultation requests
• Providing coordination services
• Maintaining appropriate business records
• Meeting regulatory or legal obligations
• Resolving disputes
• Preventing fraud or security incidents
• Establishing or defending legal claims

Different categories of information may have different retention periods.

When information is no longer reasonably required, we may delete, securely destroy, or anonymize it in accordance with applicable law.

We use reasonable administrative, organizational, and technical measures designed to protect personal information against:

• Unauthorized access
• Unauthorized disclosure
• Accidental loss
• Alteration
• Misuse
• Destruction

These measures may include access controls, authentication, encryption where appropriate, restricted employee access, secure hosting, audit controls, and contractual safeguards with service providers.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Depending on where you live and which privacy laws apply to your information, you may have rights that include:

• Requesting access to your personal information
• Requesting correction of inaccurate information
• Requesting deletion of certain information
• Requesting information about how your data is used
• Requesting information about parties to whom data has been disclosed
• Objecting to or restricting certain processing
• Withdrawing consent where processing is based on consent
• Requesting portability of information where applicable
• Opting out of certain forms of sale, sharing, profiling, or targeted advertising where applicable
• Filing a complaint with an appropriate privacy or data protection authority

These rights may be subject to legal exceptions.

We may need to verify your identity before processing certain requests.

If California privacy law applies to Avenia's processing of your information, California residents may have additional rights concerning access, correction, deletion, and certain disclosures or uses of personal information.

Avenia does not discriminate against individuals for exercising applicable privacy rights.

Avenia does not sell patient health information.

Where legally required, California residents may also exercise rights relating to the use or disclosure of sensitive personal information.

Where the GDPR or UK GDPR applies, Avenia will process personal information only where an appropriate legal basis exists.

Depending on the circumstances, this may include:

• Your consent
• Steps requested by you before entering into a contract
• Performance of a contract
• Compliance with legal obligations
• Legitimate interests that are not overridden by your rights
• Other legal grounds available for processing special-category information

Where explicit consent is legally required for health information, it will be requested separately.

Where Türkiye's Law No. 6698 on the Protection of Personal Data (“KVKK”) applies, personal information will be processed in accordance with applicable requirements concerning transparency, processing conditions, sensitive personal data, security, data subject rights, and international data transfers.

Health information and certain other information may constitute special-category personal data under Turkish law.

Where legally required, Avenia will obtain explicit consent or rely on another lawful processing condition and will implement appropriate safeguards.

Avenia's services are intended primarily for adults.

We do not knowingly request consultation information directly from children where parental or legal guardian authorization is required.

Where services concern a minor, information should be submitted by, or with the authorization of, the minor's parent or legal guardian as required by applicable law.

Our website may contain links to independent clinics, hospitals, healthcare providers, hotels, airlines, payment services, social media services, or other websites.

Their privacy practices are governed by their own policies.

Avenia is not responsible for the privacy practices of independent third-party websites or services.

We may update this Privacy Policy when our services, technology, legal requirements, or privacy practices change.

The current version will be published on our website with the updated effective date.

Where a material change requires additional notice or consent under applicable law, we will provide it.

For questions, privacy requests, or concerns regarding this Privacy Policy or your personal information, contact:

• Avenia Global
• Legal Entity: [FULL LEGAL COMPANY NAME]
• Email: [PRIVACY EMAIL]
• Address: [REGISTERED BUSINESS ADDRESS]

For privacy requests, please use the subject line:

Privacy Request – Avenia Global