Privacy Policy

HealthcareCyprus.com / TedaviKibris.com
Cyprus Healthcare Travel Council
Last Updated: July 14, 2025

Important Notice: HealthcareCyprus.com cares for your personal data and does everything possible to protect it. This Privacy Notice helps you understand what personal data is collected, stored and processed when you use our Website.

1. Purpose & Overview

This Notice explains what data is collected in connection with the Website, how we use that data, where we store it, and how we protect it.

Key Points:

  • We need to process some of your data for you to use our Website and services
  • We will not share your data for third party advertising purposes
  • We explain your rights in relation to your personal data

You may generally browse our Website without providing us with your information. However, if you want to use the full functionality of our Website and services, you will need to provide some of your data.

2. Controller Information

Item Details
Controller Cyprus Healthcare Travel Council
Address Bedrettin Demirel Caddesi, No:4, Girne, North Cyprus
General Email [email protected]
Privacy Email [email protected]

Privacy Roles:

  • HealthcareCyprus is the controller for personal data of Visitors, Clients, and Partners
  • Regarding Representatives’ personal data, HealthcareCyprus is a processor
  • We act as a business associate under HIPAA regulations

3. User Categories & Data Collection

For your convenience, we divide our users into 4 categories:

User Type Description
Visitor Anyone who visits the Website
Client End-user to whom we provide our services
Partner Legal entity that provides medical care
Representative User whose data we receive from Partners (clinics, hospitals)

Important: We process medical and health data that is sensitive data. Processing of sensitive personal data (medical and health) is necessary to provide you Service (legal basis: performance of the contract).

3.1 Automatically Collected Data

Category Description Legal Basis
Website Interaction Your interaction with the Website, features used, pages viewed, actions taken Legitimate interest
Device & Connection Data Operating system, browser type, IP address, device identifiers, geolocation Legitimate interest
Cookies & Similar Technologies Analytical purposes, website preferences Legitimate interest / Consent

3.2 Data You Provide to Us

Visitor Data

Purpose Data Collected Legal Basis
Customer Support Name, surname, email, phone, country, request details, documents (if applicable) Performance of contract

Client Data

Purpose Data Collected Legal Basis
Account Registration Name, email address, phone number Performance of contract
Account Customization Profile picture, age, country, social media profile, messenger preferences Performance of contract
Comments & Rating Name, email, comment content, user ID Performance of contract
Request Submission Medical data, trip data, guardian data, bank statements, passport data Performance of contract / Consent
Consultation Call records, name, age, location, medical data Performance of contract

4. How We Use Your Data

We process your data for seven basic purposes:

  1. Provision of Website features
  2. Provision of our Services
  3. Providing information about our Services
  4. Research and analysis purposes
  5. Complying with security obligations
  6. Complying with legal obligations
  7. Sending marketing communications
Processing Purpose Description Legal Basis
Website Features Create and update accounts, enable Website use, process service requests Performance of contract
Service Provision Provide medical facilities, verify identity, arrange trips Performance of contract
Communication Answer questions, resolve issues, inform about updates Performance of contract / Legitimate interest
Research & Analysis Testing, analysis, product development, safety enhancement Legitimate interest
Safety & Security Prevent fraud, detect abuse, comply with legal requests Legitimate interest
Legal Compliance Operate business, comply with legal obligations Legal obligation
Marketing Send marketing communications (Representatives only, with consent) Consent

5. Cookies

We use cookies for analytical purposes. Cookies generally do not permit us to personally identify you. We use session cookies that expire when you close your browser.

Cookie data may include:

  • The website that referred you to us
  • Web pages you viewed on our Website
  • Advertisements viewed and clicked
  • Browser preferences such as language

6. Data Sharing & Disclosure

We may share your personal data under these conditions:

Sharing Category Description
Authorized Third Parties Service providers who help us operate our business
Safety & Legal Purposes Law enforcement, legal compliance
Business Transfers In case of merger, acquisition, or sale
With Your Consent When you explicitly agree
Medical Partners Partners you choose for medical care (acting as independent controllers)

Data Transfer: We transfer personal data to contractors in Ukraine using Standard Contractual Clauses approved by the EU Commission as safeguards. We store data on servers in Germany with encryption and security measures.

7. Data Security & Retention

Security Measures:

  • Encryption: Industry-standard encryption for data protection
  • Access Control: Limited access to authorized employees only
  • Vendor Security: All third parties undergo security audits
  • Contractual Safeguards: Standard Contractual Clauses with partners

Data Retention: We retain personal data for as long as necessary to fulfill the purposes described in this Notice, unless otherwise required by law. Some data may be kept longer for legitimate business interests including fraud prevention and legal compliance.

8. Minors

We do not knowingly collect personal data directly from children under 16. We may process a child’s data only upon parent or guardian request and after verification of identity and authority.

9. Your Rights

European Economic Area and United Kingdom Residents

Right Description
Right to Access Request information about personal data processing
Right to Rectification Change inaccurate or incomplete data
Right to Erasure Request deletion of personal data
Right to Restrict Processing Limit how we process your data
Right to Data Portability Request data transfer to another controller
Right to Object Object to processing based on legitimate interest
Right to Withdraw Consent Withdraw consent at any time
Right to File Complaint Submit complaint to regulatory body

United States Residents

Right Available In
Right to Access California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia
Right to Correct California, Colorado, Connecticut, Delaware, Indiana, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Virginia
Right to Delete California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia
Right to Opt Out of Sales California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia

HIPAA Rights

Right Description
Right to Request Privacy Protection Request restrictions on certain uses and disclosures of PHI
Right to Access Request inspection and copy of your PHI
Right to Amend Request corrections to medical records
Right to Accounting Access accounting of PHI disclosures over past 6 years
Right to Breach Notification Be notified of any breach of unsecured PHI
Right to File Complaint File complaint with provider or Health and Human Services

10. California Privacy Rights

Do Not Sell My Personal Information

We do not sell your personal information to anyone nor use your data as a business model. California residents can opt out of any future sale of their personal information by contacting us.

Do-Not-Track Requests

We currently do not have the ability to honor do-not-track requests. We may modify this Privacy Notice as our abilities change.

11. Updates to This Notice

Applicable law and our practices change over time. If we decide to update the Privacy Notice, we will post the changes on our Website. If we materially change how we process your personal data, we will provide prior notice or request your consent where legally required.

12. Contact Information

Contact Us

Privacy Requests: [email protected]
General Questions: [email protected]
Phone: +90 (392) XXX XX XX
Address: Bedrettin Demirel Caddesi, No:4, Girne, North Cyprus

© 2025 Cyprus Healthcare Travel Council – HealthcareCyprus.com / TedaviKibris.com

This policy is prepared in English and Turkish. In case of conflict, the English text prevails.