Privacy Policy
This privacy notice aims to inform you on the following, regarding collecting, processing and transferring of your personal data Hiwell Teknoloji A.Ş. (shall be referred to as “Hiwell” hereafter) having its registered office at Acıbadem Neighborhood, Çeçen Street, Akasya B Block No: 25 B Inner Door No: 32 Üsküdar/Istanbul:
- Which personal data is collected and processed by Hiwell,
- The purpose for which Hiwell collects and processes your personal data,
- With whom Hiwell shares your personal data with,
- Whether your personal data is transferred outside the UK,
- How Hiwell stores and protects your personal data, and
- The extent of your rights regarding your personal data.
Within the scope of this Privacy Notice,
- “Personal Data” means data on an identified or identifiable individual and
- “Processing” means actions such as collecting, revoking authorization, accessing, sharing, storing and destroying, in relation to Personal Data.
I. Processed Personal Data, Purpose of Processing and Data Processor
Hiwell processes your personal data listed in the table below for defined purposes, using defined units and limited in periods defined.
Your personal data described below will be processed in order to fulfill the legal obligations Hiwell is subject to and for the purposes of fulfilling our contractual obligations under the service agreement. We do not rely on your explicit consent when processing your personal data other than where we obtain your consent for marketing purposes. You are able to unsubscribe or withdraw your consent for marketing at any time.
| Personal Data | Purpose of Processing and lawful basis of processing | Storage Period |
|---|---|---|
| Name, Surname | For compliance with relevant legislation and fulfilling contractual obligations within the scope of the service agreement | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
| Telephone Number, E-mail address, Address | For compliance with relevant legislation and fulfilling contractual obligations within the scope of the service agreement as well as contacting in cases of emergency | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
| Age | To direct clients to suitable psychotherapists and to inform relevant psychotherapists on the clients. It is in our legitimate interest in providing you with access to the platform. | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
| Name and surname of the emergency contact | For compliance with relevant legislation and fulfilling contractual obligations within the scope of the service agreement as well as contacting in cases of emergency | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
| IP Information | For compliance with relevant legislation and fulfilling contractual obligations within the scope of the service agreement | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
| Device ID Information | For compliance with relevant legislation and fulfilling contractual obligations within the scope of the service agreement | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
| Case File (ID Information, address information) | For compliance with law and legal processes and measures in the context of legal action, to protect our legitimate interests in the event of uncollected product fees. Monitoring unlicensed software use in case one of the parties takes legal action in the context of a dispute | Ten (10) years following the finalization of the trial period |
| Case file (Subject of dispute and all related information and documents) | For compliance with law and legal processes and measures in the context of legal action, to protect our legitimate interests in the event of uncollected product fees. Monitoring unlicensed software use in cases one of the parties takes legal action in case of dispute | Ten (10) years following the finalization of the trial period |
Collection of Personal Data for our legitimate interest in improving our platform provided, to offer new products and services in line with customer satisfaction and needs and other commercial purposes.
| Personal Data | Purpose of Processing and lawful basis of processing | Storage Period |
|---|---|---|
| E-mail address | For our legitimate interest in improving the service provided, to provide new services in line with customer satisfaction and needs and for marketing purposes | During the service period |
| IP Information | For our legitimate interest in improving the service provided, to provide new services in line with customer satisfaction and needs and for marketing purposes | During the service period |
| Device ID Information | For our legitimate interest in improving the service provided, to provide new services in line with customer satisfaction and needs and for marketing purposes | During the service period |
Collection of special category personal data to enable the provision of psychological counseling by suppliers.
| Personal Data | Purpose of Processing and lawful basis of processing | Storage Period |
|---|---|---|
| Sex | To provide our service and fulfil our contractual obligations including to direct clients to suitable psychotherapists and to provide the requisite information to the relevant psychoterapists | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
| Mental Health Conditions | To provide our service and fulfil our contractual obligations including to direct clients to suitable psychotherapists and to relevant psychoterapists with the requisite information in relation to the clients | Stored until the end of the 10 (ten) year storage period following the expiration of service relation. |
When processing the above mentioned special category Personal Data we do so for the purposes of entering into a contract with you for the provision of services. When processing special category personal data, data protection laws require us to identify a special condition for that processing. The special condition we rely on is the provision of health care and can be found under Article 9 (2) (h) of the GDPR.
Your sensitive personal data such as sex and mental health conditions are collected by Hiwell and shared with contracted suppliers of the platform (this includes the psychoterapist that provides counselling and a third party call centre). Your Sensitive Personal Data will not, under any circumstance, be shared with third parties apart from the service providers via our platform.
II. Method of Collecting Personal Data
Personal data listed here are collected directly from the data subject.
III. Storage Period
Your personal data will be stored for the period specified under the “Storage Period” title in the tables. Your Personal Data is deleted or destroyed at the first destruction period following the expiry of the said period.
IV. Transfer or Disclosure to Third Parties
Hiwell may transfer or disclose the above personal data to comply with contractual and legal obligations. Hiwell may share your personal data with:
(1) other relevant units within Hiwell, including technical support, third parties such as banks, audit companies, lawyers, law offices and financial advisors as well as third parties required by the business and/or service provider including psychotherapists, limited to the service acquired to fulfill be obligations and proportional to these purposes, and
(2) law enforcement, public organizations, relevant ministries and directorates and public bodies and institutions including Social Security Institution appointed by labor law and social security law, and other public bodies authorized by laws.
V. Transferring Personal Data Abroad
Hiwell shares,
(1) your personal data related to Device ID and IP address with Google Analytics residing at [1600 Amphitheatre Parkway, Mountain View, CA 94043] who provides web analysis services, and
(2) your personal data related to psychological support such as your answers at registration and messages between you and your consultant, with AWS Cloud and MongoDB residing at Frankfurt, Germany and providing server and cloud services.
Furthermore, Hiwell corporate e-mail network operates on Gmail (Google) software. In this case, all e-mail communication you perform over Hiwell business e-mail address is stored in Gmail (Google) servers abroad, with encryption. Hiwell will encrypt your personal data you will send attached to e-mails.
VI. Automated Decision Making
When assigning you a counsellor, our App uses automated decision making to ensure the most appropriate counsellor is selected based on your responses to some initial questions. This automated decision making does not have any legal or material impact on the rights and freedoms of users.
VII. Social Media
Our webpage may also use plug-ins from the social media platforms.
When you enter our website that contains a plug-in, your browser will create a direct link to the servers of the social media platforms. They may receive information about you, the fact that you have visited our website, your IP-address and whether you have interacted with their plug-in at our website. These data will be stored with the social media companies in the countries where they are located, including in the USA. The social media companies will receive the information whether you are a user on their social media platform or not.
You can prevent the social media plug-ins from loading by using a script-blocker add-on, which you can download for your browser.
We do not have any influence on the collection or processing of personal data that is carried out by social media platforms.
You can read more regarding how Facebook, YouTube, Instagram and Twitter process your data at the following link:
Twitter: https://twitter.com/en/privacy
Facebook: https://en-gb.facebook.com/privacy/explanation
Instagram: https://help.instagram.com/519522125107875/?maybe_redirect_pol=0
YouTube: https://www.youtube.com/howyoutubeworks/user-settings/privacy/
VIII. Your rights
If you are in the UK or the EU, you have rights over your personal data (just so you know, these are not absolute). Please ask us about any of these rights and we will be happy to help.
If you are in the UK or the EU, you may have the right to:
- find out what information we hold about you.
- ask us to provide you with a copy of your information.
- ask us to make changes to your information.
- ask us to correct, delete, limit or stop using your information.
- ask us to move your information to a third party.
- change your mind about us holding your information (or sending you marketing).
These rights are not absolute – if a right doesn't apply, or only applies to some of your information or some of the things we do with it, we'll let you know as part of our reply to you.
If you would like to exercise any of these rights over your information, you can contact us at hello@hiwellapp.com
Our Data Protection Officer is Ali Ozan Özçiçek. You can email them at: ozan@hiwellapp.com
If you have any concerns, you have the right to make a complaint to a data protection supervisory authority.
- If you are in the UK, the supervisory authority is the Information Commissioner's Office (ICO). You can visit their website at www.ico.org.uk.
- If you are in the EU, you can find your local data protection authority here.
You can submit the above demands to the email address hello@hiwellapp.com. Hiwell will conclude your demand at the shortest time possible and get most within 30 (thirty) days following the receipt of relevant documents.
Data Controller: Hiwell Teknoloji A.Ş.
Contact Number: +90 444 98 66
You can contact us at:
Address: Acıbadem Neighborhood, Çeçen Street, Akasya B Block No: 25 B Inner Door No: 32 Üsküdar/Istanbul
E-Mail: hello@hiwellapp.com
You can find our Privacy Policy at and our cookie policy at our website: www.hiwellapp.com