Updated on August 13, 2022
Welcome to the AFA Limb Lengthening’s website, mobile app, and related sites and digital and online services (“AFA Limb Lengthening Site,” the “Site,” or “Sites“), an online e-commerce, information, and communications service provided by AFA Limb Lengthening and all affiliates (“AFA Limb Lengthening” or “We” or “Us“).
This Privacy (Confidentiality) Policy applies to all Sites where it is posted. Other AFA Limb Lengthening online properties may have their own privacy policies that apply to those sites. You should review those privacy policies in connection with your use of those sites.
What information we collect
Information you give us: We respect the right to confidentiality of all visitors to the AFA Limb Lengthening Sites. We receive and store some information that you enter on our Sites or that you provide to us through the Sites in any other way.
The information we collect or that you provide on or through our Sites or by using our services includes:
- Data that may personally identify you, including your name, postal address, billing address, shipping address, e-mail address, home, work and mobile telephone numbers, age, date of birth, social security number, insurance policy number, physical characteristics that may personally identify you, sexual orientation, IP address, national origin, ancestry, veteran or military status, medical conditions, race, citizenship, information about any physical or mental disabilities you may have, information related to your religious or philosophical beliefs, political opinions, information regarding your gender at birth and how you currently express your gender identity, information related to your sex life, such as pregnancy, child birth and related medical conditions, any history of criminal convictions, biometric information (such as fingerprints, exercise data, psychological characteristics, face prints, gait patterns, genetics, behavioral characteristics, voice, sleep data, and iris/retina scans), and genetic information (including familial genetic information) (collectively, “Personal Data“);
- Information that you provide by filling in forms on our Sites, such as appointment request forms or product ordering forms. It also includes information you provide when you register to use our Sites, purchase products, or use services available through the Sites or facilities. We may also ask you for information when you report a problem with our Sites. Some forms collect sensitive information, such as health information, necessary for us to provide our services to you;
- Records and copies of your correspondence (including email addresses), if you contact us;
- Your responses to surveys that we might ask you to complete for research, development, and marketing purposes; and
- Details of transactions you carry out through our Sites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Sites.
You also may provide information to be published or displayed (hereinafter, “Posted“) on public areas of the Sites or transmitted to other users of the Sites or third parties (collectively, “User Contributions“). Your User Contributions are Posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information we collect automatically: We collect information about you automatically as you navigate through or use our Sites. Information collected automatically may include usage details, IP addresses, session replay and recording technology (recording your movements, clicks, etc. on our Sites), and information collected through cookies, web beacons, pixels tags, and other tracking technologies. As you navigate through and interact with our Sites, we may use automatic data collection technologies (such as session replay and tracking technologies referred to above) to collect certain information about your equipment, browsing actions, and patterns, specifically:
- Usage Details. Details of your visits to our Sites, such as traffic data, location, logs, referring/exit pages, date and time of your visit to or use of our Sites, error information, clickstream data, and other communication data and the resources that you access and use on or in the Sites.
- Device Information. Information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and App version information.
- Location Data. Information about your location collected through Geolocation technology.
The information we collect automatically may include Personal Data or we may maintain or associate information we collect with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Sites and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- improve our product and services offering;
- store information about your preferences, allowing us to customize our Sites according to your individual interests; and
- recognize and/or authenticate you when you return to our Sites.
The technologies we use for this automatic data collection may include:
- Pixels and Web Beacons. Pages on our Sites, or our e-mails, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Sites statistics (for example, recording the popularity of certain Sites content and verifying system and server integrity).
- Facebook Pixel. We use Facebook Pixel, a web analytics and advertising service provided by Facebook Inc. (“Facebook“) on our Platform. With its help, we and our customers can keep track of what users do after they see or click on a Facebook advertisement, keep track of users who access our Platform or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel is also saved and processed by Facebook. Facebook can connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel https://www.facebook.com/settings/?tab=ads#_=_.
- Do Not Track Signals. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals; although, we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services for any purpose, including advertising.
Email communications, newsletter, and related services
Our Sites provide you with the opportunity to receive communications from us or third parties.
Email communications that you send to us via the email links on our Site may be shared with a customer service representative, employee, medical expert, or agent that is most able to address your inquiry. We make every effort to respond in a timely fashion once communications are received. Once we have responded to your communication, it is discarded or archived, depending on the nature of the inquiry. Note, that email communications that you send us via the email links on our Site are not automatically encrypted, and it is possible that unencrypted email communications with us may be accessed or viewed by another internet user while in transit to us.
How we use the information we collect to protect your confidentiality
In addition to the uses described above, we use the information we collect for things like:
- Optimizing the performance and user experience of our sites;
- Operating, evaluating, and improving our business;
- Providing healthcare services;
- Fulfilling the requests for services;
- Delivering or installing products;
- Sending you emails;
- Conducting research and analysis;
- Communicating with you about your account, special events, and surveys; and
- Managing your requests and consultations with us.
We may combine this information with any other information we have about you, including, if you are a AFA Limb Lengthening patient, any PHI we have about you. If we combine this information with your PHI, we will treat all of that information as PHI and will only use or disclose that information as set forth in our Notice of Confidentiality Practices.
We will retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. You may request that we delete your data by contacting us as provided below. However, we may not be able to honor that request in all instances given the laws and regulations that apply to us. For example, under state and federal law, we may be required to maintain some data that is specific to you and that may identify you, such as your medical records or other information. We may also have a legal basis or obligation to maintain medical and other information about you to provide care and treatment or to comply with our professional, legal, and other obligations.
Disclosure of your information
We may share the information we collect about you with third parties who we have engaged to help us provide the Site, as well as the products and services available through our Site. In this regard, we may disclose your Personal Data to affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, advertising, marketing, and payment processing services. Advertising and marketing partners such as Facebook, Instagram, Google, and other advertising networks may receive and use your Personal Data to assist us with our advertising and marketing efforts. In each case, we will ensure that these third parties have agreed to safeguard your data.
We may provide third parties with aggregate statistics about our visitors, traffic patterns, and related site information. These data reflect site-usage patterns gathered during visits to our website each month, but they do not contain information that personally identifies you unless you have given us permission to share that information.
We may also disclose your Personal Data:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AFA Limb Lengthening, our patients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices about how we use and disclose your information
We strive to provide you with choices regarding the Personal Data you provide to us. We have created or you have available mechanisms to provide you with control over your Personal Data:
- Promotional Offers from AFA Limb Lengthening. If you do not wish to have your email address used by us to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or submitting a request to our Center. This opt-out does not apply to information provided to AFA Limb Lengthening as a result of a product purchase or your use of our services. If you wish to opt-out of such sharing, please email us at [email protected].
- Disclosure of Your Information to Affiliates. By purchasing our products, you consent to our sharing of your Personal Data with our affiliates for their promotional purposes. If you wish to opt-out of such sharing, please email us at [email protected].
Your rights regarding your information and accessing and correcting your information
For non-patient information, you can Contact Us through the Contact Information below to access and/or find out what information we have about you and to correct that information. You can also review and change your Personal Data by logging into our site and visiting either the Settings or Account Preferences sections. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot completely delete your personal information except by also deleting your account with us. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or if we have a legal basis or obligation to maintain it, or if it would cause the information to be incorrect.
Whether you are visiting the AFA Limb Lengthening Site or one of our clinic locations, we use reasonable security measures to protect the confidentiality of personal information under our control, and we appropriately limit access to it. We use a variety of information security measures to protect your online transactions with us. The AFA Limb Lengthening Site uses encryption technology, such as Secure Sockets Layer (SSL), to protect your personal information during data transport. SSL protects information you submit via our website, such as ordering information including your name, address, and credit card number. That being said, AFA Limb Lengthening cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We have taken reasonable steps to ensure the integrity and confidentiality of personally identifiable information that you may provide. You should understand, however, that electronic transmissions via the internet are not necessarily secure from interception, and so we cannot absolutely guarantee the security or confidentiality of such transmissions.
Complaints or concerns: You are welcome to raise any complaints or concerns to AFA Limb Lengthening by contacting AFA’s Data Protection Officer at [email protected] You also have the right to lodge a complaint with a supervisory authority.
Protecting children’s confidentiality
Other than our Patient Online Services, our Sites are not intended for users under 18 years of age. No one under age 18 may provide any information to or through the Sites. We do not knowingly collect Personal Data from users under 18. If you are under 18, do not use or provide any information on or in our Sites or on or through any of their features, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a user under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a user under 18, please contact us at the contact information below.
Our Patient Online Services is available to patients 18 years of age and older. It is also available to patients who are between the ages of 13 years old and 17 years old with the permission of their parents or legal guardians.
If you have a question or concern regarding your confidentiality, please contact AFA Limb Lengthening’s Confidentiality Officer using the contact information below:
- AFA Limb Lengthening Confidentiality Officer
- İstiklal Mah. Alemdağ Cad. No:186/20 Ümraniye/İstanbul
- [email protected]