International Data Transfer Notice

Effective Date: May 6, 2026

This notice explains why personal data processed through DocOnWay may sometimes be accessed from, stored in, or transferred to countries outside the user's own country or outside Turkiye and the EEA.

1. Purpose of this notice

The purpose of this notice is to explain the circumstances in which international data access or transfer may occur as part of the platform's operation, support, care coordination, communication, analytics, infrastructure, and security functions.

2. Why international transfer/access may occur

Because DocOnWay serves international travelers and uses digital services that may involve global support and infrastructure, some data may be processed or accessed outside the user's country. This may happen in connection with hosting, database management, AI-assisted intake, payment processing, communications, analytics, maps, support tooling, and other technical operations.

3. Categories of recipients

Recipients may include hosting and cloud service providers, database and infrastructure providers, AI and routing-support providers, payment service providers, communication providers, analytics and security providers, map/location service providers, support and CRM providers, and professional advisers where necessary.

4. Categories of transferred data

Depending on the service used, transferred or remotely accessible data may include identity and contact information, booking details, complaint summaries, location information, technical and usage data, support communications, payment references, and where applicable health-related information shared for coordination purposes.

5. Safeguards and legal mechanisms

DocOnWay aims to use contractual, organizational, and technical safeguards appropriate to the relevant transfer scenario. Depending on the jurisdiction and context, such mechanisms may include explicit consent where required, adequacy assessments, standard contractual clauses, contractual confidentiality measures, access controls, role-based restrictions, and related legal mechanisms recognized under applicable law.

6. Health data and special category data

Health data is treated with heightened care because it may constitute special category personal data under applicable data protection laws. Where such data is involved, DocOnWay aims to limit access to what is necessary for the relevant care coordination, safety, support, and legal purposes.

7. User rights

Subject to applicable law, users may have rights to request access, correction, deletion, restriction, objection, withdrawal of consent, and data portability where applicable. Users may also ask for general information about the safeguards used for cross-border access or transfer, to the extent lawfully possible.

8. Contact

For questions about international data access or transfer:
DocOnWay
Viofun Yazılım Anonim Şirketi
Address: Pınarbaşı Mah. Hürriyet Cad. Akdeniz Üniversitesi Antalya Teknokent
Ar-Ge 2 Uluğbey Binası No:3A/B178, Konyaaltı / Antalya, Turkey
E-mail: privacy@doconway.com