Disclosure and Explicit Consent Text Regarding the Processing of Sensitive and Personal Data Including Patient Data

1. Data Controller Information

Data Controller: SEMBA LLC

Address: Büyükesat Mahallesi, Kaptanpaşa Caddesi, No 11, A 6, 06680, Çankaya/Ankara/Turkey

Contact: +90 553 903 2329 · info@sembainformatics.com

2. Categories of Personal Data to be Processed

• Identity data (name, surname, ID/passport no, date of birth, etc.)
• Contact data (phone, email, address, etc.)
• Health data (medical history, diagnosis, treatment information, lab results, imaging records, prescription information, etc.)
• Transaction security data (system access records, log records, etc.)

3. Purposes of Data Processing

• Planning and execution of healthcare service delivery processes
• Conducting diagnosis, treatment, follow-up and care processes
• Execution of communication activities such as appointment, notification, reporting
• Fulfillment of billing, payment, accounting and financial obligations
• Fulfillment of notification and retention obligations arising from legislation
• Monitoring legal processes, resolving disputes and protecting rights
• Training, development, and improvement of the performance and accuracy of AI models named Maverik, Morgaf and Galadriel
• Security, improvement and quality management of our systems

4. Domestic and International Data Transfer

Your personal data, including sensitive data such as patient data, may be transferred to our business partners, suppliers, consultants and service providers; cloud service providers, IT companies and technical support firms; and authorized public institutions and organizations, with appropriate security and confidentiality measures in accordance with applicable legislation.

Your personal data, including health data, may be transferred to servers located abroad for the purpose of training the Maverik, Morgaf and Galadriel AI models.

5. Collection Method and Legal Basis

Your personal data is collected and processed automatically or partially automatically through forms, contracts, and declarations completed during healthcare service delivery, as well as through patient record systems, our website, online platforms and mobile applications.

6. Maverik, Morgaf and Galadriel AI Models – Intellectual Property Rights

Your personal data and patient data may be used (anonymized where necessary) for the development of these models. All intellectual and industrial property rights over the Maverik, Morgaf and Galadriel AI models belong exclusively to SEMBA LLC.

You acknowledge that you will not claim any material or moral right, income, share, compensation, or similar claim over better performance, improved functions, new methods or inventions resulting from the use of your personal data in these models.

7. Marketing and Commercial Electronic Communication Consent

By approving this text, you grant explicit consent to receive informational and marketing messages via phone, SMS, email and similar electronic communication channels within the scope of our healthcare services. You may withdraw this consent at any time.

8. Your Rights Under Data Protection Law

Pursuant to applicable legislation, you have the right to:

• Learn whether your personal data is being processed
• Request information if it has been processed
• Learn the purpose of processing and whether it is used in accordance with that purpose
• Know the third parties to whom data is transferred domestically or abroad
• Request correction if processed incompletely or incorrectly
• Request deletion or destruction if conditions are met
• Object to results arising from automated systems that are detrimental to you
• Request compensation for damages arising from unlawful processing

For requests: info@sembainformatics.com