MyMeds Privacy Policy

CONFIDENTIALITY AND DISCLOSURE STATEMENT 

MyMeds is an application provided by RealWorks Teknoloji Anonim Şirketi (hereinafter referred 
to  as  "we",  "us"  or  "our")  RealWorks  Teknoloji  Anonim  Şirketi  is  the  data  controller  of  the 
MyMeds  Platform.  We  have  created  this  Privacy  and  Disclosure  Statement  to  make  sure  you 
understand how we collect and use your personal information. 

RealWorks  Teknoloji  Anonim  Şirketi  aims  to  process  the  personal  data  of  MyMeds  users  in 
accordance with international data protection provisions and the provisions of the Personal Data 
Protection Law No. 6698 ("KVKK") and other legislation. 

RealWorks  Teknoloji  Anonim  Şirketi  as  the  "Data  Controller"  of  your  personal  data  that  you 
have  provided  /  will  provide  and  /  or  obtained  externally  in  any  way  due  to  your  being  a 
MyMeds user:

For the purpose for which the processing is necessary and in a relevant, limited and

•
proportionate manner,
•
RealWorks Teknoloji Anonim Şirketi,
•
the KVKK and international data protection provisions.

Maintain the accuracy and most current status of such personal data as provided by you to

We hereby declare that it will be processed in compliance with the conditions stipulated in

In case of any change in the purpose or legal grounds for processing your personal data, this 
Privacy and Disclosure Statement Text will be updated and re-published by us. 

MyMeds allows you to track and analyze your health data to provide you with detailed health 
services. 

This Statement explains the following: 

What Personal Data Do We Collect About You? 

We will only collect and use your personal data for the following purposes set out in this notice. 
Personal data refers to all information that allows us to identify you as a user. 

Through  this  platform,  we  obtain  and  maintain  information  about  you  in  various  ways.  In  this 
context, we will collect and process the following data: 

1.1.  Personal  profile  information:  Account  information  (such  as  account  identifier,  profile 
picture, username, gender, date of birth, height, weight, email address, phone number, location, 
zip code and country). 

1.2. Health data: During the use of our application, your health data will be processed by sharing 
your health data with Apple Health and you within the scope of your explicit consent within the 
scope of this "Privacy and Clarification Text" and the analysis results and reports of this data will 
be processed and medications and medication tracking, health measurements, sleep patterns and 
sleep  tracking  data,  respiratory  rate,  heart  rate  data,  pulse,  body  temperature,  body  fat,  body 
resistance, nutrition, weight, body fat, oxygen saturation, blood data, blood oxygen level, blood 
sugar level, blood pressure level, activity status and levels and other health data provided will be 
processed for the purpose of providing services. Your health data to be processed with your use 
of  our  application  will  be  anonymized  and  used  for  the  purpose  of  training  our  algorithm  and 
using it in scientific studies. 

Data  such  as  Cycle  Schedule,  Stress  test,  Arterial  Stiffness  Detection,  vascular  data  (such  as 
pulse  wave  velocity,  pulse  waveform  diagram,  pulse  wave  conduction  velocity,  PPG, 
measurement  time  and  vascular  elasticity  result  and  degree),  ECG  data  (such  as  ECG 
measurement time, result, waveform, average heart rate and symptoms), Sleep Breath Awareness 
(sleep  time,  heartbeat  interval  and  blood  oxygen  saturation  level)  will  be  processed  for  the 
purpose of providing services. None of the Services are medical firmware and the data should be 
used for reference only, not for medical study, diagnosis or treatment. 

In  the  case  of  a  wearable  device,  the  device  will  synchronize  with  MyMeds  when  it  is 
connected to  MyMeds. Data about  and from  third-party devices and  apps that  you choose to 
connect to MyMeds, such as third-party device manufacturer, model, and identifiers, and third- 
party  app  identifiers,  including  social  media  identifiers,  health  and  fitness-related  data, 
movement  and  nutrition-related  data,  including  information  from  such  devices  and  third-party 
app identifiers including social media identifiers, will be synced to your MyMeds app.

Including  when  it  is  stored.  As  described  above,  when  using  MyMeds,  we  encourage  you  to 
read the privacy and disclosure statements of the third-party applications and third-party devices 
you  choose  to  connect  to  MyMeds,  in  particular  Apple  Health,  to  which  your  data  will  be 
provided. 

If  you  upload  medical  results  and  tests  to  MyMeds,  we  are  able  to  provide  a  reference 
evaluation service for  the  test  you  have uploaded through  our  service provider OpenAI  (OpenAI 
Inc.,  3180  18th  St,  San  Francisco,  California, USA;  disclosure  text:  https://openai.com/api-data- 
privacy) located  abroad.  OpenAI  servers are  located  in  the United  States  of America.  If  there  is 
any  information  in  your  uploaded  images  that  can  be  matched  with  you  (such  as  name  - 
surname),  this  information  will  also  be  transferred  to  OpenAI  since  we  do  not  have  the 
opportunity to intervene in the image. 

1.3.  Device  and  network  information:  Your  device  information  such  as  your  MAC  address, 
device  serial  number,  IMEI  or  other  device  identifier  (depending  on  your  mobile  system), 
firmware  version  including  mobile  advertising  identifiers,  operating  system  and  device 
identifiers,  your  device  type  and  personal  settings  will  be  collected  for  device  management, 
including establishing Bluetooth connections, managing device configurations, firmware updates 
and  viewing  the  source  device  of  data.  Your  IP  address,  network  type  and  network  connection 
will also be collected to improve your network connection experience. 

Other  data  necessary  to  use  MyMeds  services  or  features:  In  order  to  provide  services  to  you, 
MyMeds  needs  to  access  the  internet  and  obtain  the  following  permissions:  Physical  activity 
(to track steps and activity), Phone (to get phone status when receiving calls, rejecting incoming 
calls, and receiving incoming call information after pairing with the wearable), Storage (to store 
workout photos and read photos from local storage, for example, when setting the watch face of 
the  wearable),  Location  (to  map  workouts),  Microphone  (to  analyze  sleep  sounds),  Camera 
(workout photos, to identify and record nutritional values from photos of nutrition facts labels, or 
to take photos of medical test results and upload them to MyMeds so that the test results can be 
analyzed  and  referenced),  Contacts  (to  synchronize  your  contacts  with  your  wearable  device), 
Messaging  (to  sync  SMS  with  your  wearable),  Calendar  (to  sync  workout  plans  with  your 
calendar), Call logs (to sync calls with your wearable) and Apple Health (to provide and process 
data  with  read  and  write  permission).  You  can  manage  permissions  on  your  device  by  going  to 
App Permissions. 

2. 

How We Use Your Personal Data?

In order to provide you with MyMeds functionalities and to fulfill contractual obligations, this 
app needs to collect and process your data for customer relationship management, maintenance, 
software and system updates, user identification, as well as for diagnostic, development and 
repair purposes by healthcare professionals to whom you have given your consent. The 
processing of your personal data as described is based on your contract with us. Your health 
data, including sensitive information about you, will only be processed with your explicit 
consent for the purposes of the services RealHealt intends to provide to you and will be shared 
with healthcare professionals to whom you have given your consent. 

Your movement and health data will be stored by MyMeds and third-party health professionals 
that you consent to within MyMeds and will not be processed for any purpose other than 
making it accessible when you use the application. 

MyMeds supports the sharing of your health data with other and third-party health and 
movement apps or with the relevant healthcare professional or organization. Such data sharing 
will only take place based on your prior authorization. 

We use the information collected for the following purposes: 

•

Identify and verify your identity so that you can use MyMeds;

To allow you to interact, engage and connect with third party healthcare professionals and 

•
to provide you with services in line with your intended use of MyMeds;

•
Delivering customized content, such as importing your exercise routine from another app 
into MyMeds, and making recommendations tailored to your interests and how you interact with
Commito;

Provide promotions and offers through direct marketing, communications and direct

•
marketing only where you have given us your separate consent;

Protect against, identify and prevent fraud and other criminal activities, claims and other 

•
liabilities to the extent permitted by legislation;

Comply with and enforce applicable legal requirements and our policies, including this 

•
Privacy Statement and the MyMeds Terms and Conditions.

information  we  collect  about  you 
With  your  consent,  we  use  and  combine 
through MyMeds  with  data  from  other  services  or  features  you  use,  your  devices,  and  other 
sources, such as when you associate MyMeds with a third party.

the 

n addition, our services and products may require MyMeds to request access to your Apple and 
Google data. In this case, your consent to the access request or your request to share it will mean 
that  you  give  your  explicit  consent  for  us  to  process  this  data.  Such  explicit  consent  will 
be collected by  Apple  or Google in  accordance  with  their  respective  privacy  policies  depending 
on  the  operating  system  of  your  device.  Providing  such  explicit  consent  is  in  no  way  a 
prerequisite for the provision of our products and services. However, we would like you to know 
that  if  you  do  not  provide  such  explicit  consent,  it  may  not  be  technically  possible  for  you  to 
access  certain  features  of  our  products  and  services  or  it  may  be  difficult  for  you  to  get  full 
efficiency from our products and services. However, we would like to remind you that the data 
in question will not be used for marketing and advertising purposes under any circumstances. 

RealWorks Teknoloji Anonim Şirketi processes personal information for the purposes described 
above. The legal basis for processing your personal information is summarized below: 

Your personal data is processed by automatic or non-automatic methods, limited to the use of the 
relevant  service/platform,  in  accordance  with  the  applicable  legislation,  the  Law  on  the 
Protection of Personal Data and international data protection provisions and; 

•

•

Based on your explicit consent for the purpose of processing health data;

In order to send you commercial electronic messages based on your explicit consent;

Pursuant to paragraph 2 of Article 5 of the LPPD, c) "In the event that it is necessary to

•
process the personal data of the contracting parties, provided that it is directly related to the
establishment or performance of the contract" and subparagraph f) If it is mandatory to process
personal data for the legitimate interests of the data controller, provided that it does not violate
the fundamental rights and freedoms of the data subject:

These  conditions  and  purposes  may  be  updated  in  line  with  our  obligations  arising  from 
legislation and company policies. In this case, we will inform you separately. Your personal data 
may  be  stored  for  a  reasonable  period  of  time  until  the  purpose  for  which  they  are  processed 
disappears  or  until  the  end  of  the  legal  periods  specified  in  the  relevant  legislation  and  in  any 
case until they expire. 

3. How Long Do We Keep Your Personal Data?

We will not store your personal data for longer than is necessary for the purposes described in 
this notice. However, how long we keep your data (except for your health data) depends on the 
legal basis for processing  your data. However, the data we process requires us to keep it for the 
duration of your use of MyMeds in order to fulfill our contract with you. As long as you are an 
active user of MyMeds, we will store and process this data.

Data that we process to support our business interests, such as your use of MyMeds (excluding 
your  health  data),  is  retained  only  for  as  long  as  necessary  for  the  purposes  for  which  it  was 
collected.  This  data  may  be  collected  so  that  we  can  make  improvements  and  enhancements 
to  MyMeds  and  to  perform  analytics  or  process  it  to  improve  your  customer  service 
experience. We may also process your data based on your consent. 

4. How and with whom do we share your personal data?

MyMeds  supports  the  sharing  of  movement  and  health  data  from  your  device  with  third-party 
health  and  movement  apps  and/or  relevant  healthcare  professionals  or  organizations.  Such  data 
sharing  is  only  based  on  your  prior  authorization.  You  can  also  authorize  MyMeds  to  receive 
data from these apps.  If  you enable cloud data synchronization for  any  app, data from  that  app 
will  be  automatically  synchronized  to  the  MyMeds  cloud.  We  recommend  that  you  carefully 
read  the  privacy  statements/policies  of  third-party  apps/services  with  which  you  share 
your health app data. 

The procedures and principles to be applied to personal data transfers are specified in Articles 8 
and 9 of the KVKK, and the personal data and sensitive personal data of the data subject may be 
transferred to third parties in Turkey and/or abroad. 

Based on your preferences, explicit consent, establishment or fulfillment of the service, we will 
disclose  your  information  within  our  business  and  to  the  following  entities,  but  only  for  the 
purposes described above: 

Consultants Third-party healthcare professionals or healthcare organizations that you may 

•
choose to connect with MyMeds with your consent.

Service providers: a cloud service platform that holds data on our behalf. This platform is 

•
committed to protecting your information; your personal data collected by MyMeds will be 
stored abroad by Google Firebase, our service provider. (For Google Firebase's policies and 
procedures on personal data protection and data security: https://bit.ly/realfirebase )

5.

What are Your Rights and Options?

Pursuant  to  Article  11  of  the  LPPD,  you  may  apply  to  RealWorks  Teknoloji  Anonim  Şirketi 
(Data  Controller/Data  Processor)  regarding  your  personal  data  and  make  requests  on  the 
following issues: 

a. Learn whether your personal data is being processed.

b. To obtain information about the actions to be taken if your personal data has been processed.

c. To learn the purpose of processing your personal data and whether it is used for this purpose.

d. To obtain information about third parties to whom your personal data is transferred
domestically or abroad.

e. To request correction of whether your personal data is incomplete or incorrectly processed and
to request notification of the correction made within this scope to third parties to whom your
personal data has been transferred.

f. To request the deletion, destruction or anonymization of your personal data in the event that the
reasons for processing disappear, and to request notification of such deletion, destruction or
anonymization to third parties to whom your personal data has been transferred.

g. Object to the occurrence of a result against you as a result of the analysis of your processed
personal data exclusively through automated systems.

h. To demand compensation for the damages you have suffered due to unlawful processing of
your personal data.

In addition to the requests set forth above that you may make to RealWorks Teknoloji Anonim 
Şirketi, the following rights are also offered and automated by us for your use: 

•

•

•

•

Review of your data we collect (specific to the relevant
application).

Deleting your (app-specific) data in apps and services.

Update and delete your Commito Account information.

Exiting marketing communications.

6. 

How can you contact us?

Information on how to exercise your rights as a data subject can be found in Section 5. If you 
wish to exercise your rights as a data subject or if you have any questions, comments or 
suggestions about our processing of your personal data, you can contact us by sending a written 
request to the address below or by sending an e-mail to kvkk@realworkstechnology.com. 

Data Controller Address: 

Yıldız Mahallesi, Asariye Cami Çıkmazı, No.5, Beişkta/şISTANBUL 

7. 

Updates to be made

This Privacy and Disclosure Statement may be updated to update or inform you about changes in 
the  way  we  collect  and  process  your  information  at  MyMeds  or  changes  in  applicable  laws. 
We encourage you to periodically check for the latest version of this notice in the app settings.