Privacy Notice
1.1. Scope
This Privacy Notice applies to all the products, services, websites and apps offered by Topuz & Partners LTD, except where otherwise noted. The services include Global Doctor Review subscriptions. We refer to these products, services, websites, and apps collectively as the “services” in this Privacy Notice. Unless otherwise noted in our contract, our services are provided by Topuz & Partners LTD inside the United Kingdom.
This Privacy Notice does not apply to personal information we collect from our employees or job applicants in their capacity as employees or candidates. Employees and candidates should refer to our Employee Privacy Notice or Candidate Privacy Notice, respectively.
2.1. What Do We Mean By “Personal Data”
References in this Privacy Notice to data, personal information, or information, are all references to Personal Data. Personal Data means information relating to a natural person (a “Data Subject”) who is, or can be, reasonably identified from the information, either alone or in conjunction with other information.
2.2. Who Do We Collect Data About?
Participating Organisations: Organisations that hold an account with a Topuz & Partners service (e.g., Global Doctor Review). Such organisations participate in our research by uploading submissions containing recent work highlights and a list of patients, peers, or clients (collectively “Referees”) we can contact to gather feedback on the quality of their services.
Referees: Referees are individuals who receive surveys from Topuz & Partners or invitations to participate in an interview to provide feedback on the Participating Organisation(s) that referred them.
Visitor: You are just visiting one of our websites.
2.3. Types of Personal Data We Collect
(a) Contact Information
You might provide us with your contact information (for example: name or email address), whether through use of our services, a form on our website, an interaction with our sales or customer support team, or a response to one of Topuz & Partners’ own surveys or forms.
(b) Cookie Information
We use first party and third party cookies and tracking services that employ cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes usage and user statistics. Emails sent by Topuz & Partners also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies in our Cookies Notice.
(c) Customer Support Information
We collect information submitted through our Customer Support portal, such as name, email, and message text. We also record the content of Customer Support, Customer Success, and Sales calls.
(d) Usage Information
We collect usage information about you whenever you interact with our websites and services. This includes which webpages you visit, what you click on, when you perform those actions, what language preference you have, what you buy and so on.
(e) Device and Browser Data
We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, browser type, and other device, network and browser signals. If you are on a mobile device we also collect the UUID for that device. We also infer your geographic location based on your IP address.
(f) Event Data
Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.
(g) Referral Information
If you arrive at a Topuz & Partner website from an external source (such as a link on another website or in an email) or have been invited to review a survey as a guest, we record information about the source that referred you to us.
(h) Integration Data
We collect information from third parties with whom Topuz & Partner enables integrations in order to allow you to use both services.
(i) Account Information
Registration information: You need an account before you can use Topuz & Partners’ services. When you register for an account, we collect your first and last name, username, password and email address.
Billing information: If you make a payment to Topuz & Partners, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g., a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder to determine the Topuz & Partners entity with whom you contract and the sales tax, if applicable, to be applied to your purchase.
Account settings: You can set various preferences and personal details on pages like your account settings page (or on your account settings page for our other products as applicable). These may include, for example, your default language, time zone and communication preferences (e.g., opting in or out of receiving marketing communications from Topuz & Partners).
(j) Address Book Information
We may allow you to import email addresses and other contact information into an Address Book so you can easily invite people to take your surveys or fill in your form via our collectors. We do not use this data for our own purposes or to contact anyone, except at your direction.
(k) Survey/Form/Application/Interview Data
We store survey/form/application data (questions and responses) to provide and develop our services and products.
(l) First Party Profile Information
When you sign up for our services you are asked to provide us with information about yourself and to give us more detailed insights into who you are.
(m) Third Party Profile Information
We may combine information about you from third party sources (such as LinkedIn, ZoomInfo, and other data brokers) with information we hold about you to create a user profile.
(a) Purposes
When personal information is provided to us, we may use it for any of the purposes described below, or as stated at the point we collect it from you (or as may obvious to you from the context of collection), including to:
Contact doctors and their organisations or hospitals, other medical professionals, insurance professionals, medical tourism professionals and patients to follow up on submissions made to us by Participating Organisations to seek information from identified referees;
Review and organise personal information relating to individual medical private practitioners, doctors, medical professionals and other medical service providers, insurance providers as well as medical tourism service providers;
Interview and/or survey private practice medical professionals, representatives of organisations providing medical care, representatives of medical tourism providers and representatives of insurance providers to provide an accurate assessment of the medical care, medical tourism and medical insurance markets;
Rank doctors and their organisations, medical tourism agencies, and insurance providers based on several factors and considerations;
Send research participants a link to our website where the new Global Doctor Review Guide is available free of charge;
Contact doctors and organisations we have ranked, their business development professionals and others to explore marketing opportunities we think may be of interest to them;
Contact doctors and their organisations, medical tourism organisations, and insurance providers we have researched and interviewed and/or surveyed, their business development professionals and others to explore marketing opportunities we think may be of interest to them;
Conduct our activities as researches and analysts of Topuz & Partners, website and other publications;
Provide users of publications and other customers with the services or information that they have requested from us;
Promote, manage and administer our research and other business activities
Deal with requests and/or enquiries we receive from individuals or organisations, firms and companies they work for;
Provide information about us or our services when requested;
Perform contracts and keep a record of any communications and agreements with individuals;
For any other purpose in relation to an individual making contact with us;
Administer and manage or website;
And for any other purposes for which personal information has been provided to us, including any of the purposes given in the collection of personal information section above.
3.1. Participating Organisations
We rely on one or more of the following processing conditions:
(i) Perform our contractual obligations; and/or
(ii) Satisfy any legal and regulatory obligations to which we are subject; and/or
(iii) Satisfy our legitimate interests in the effective delivery of information and services and in the effective and lawful operation of our businesses; and/or
(iv) When we have consent to process personal information
We rely on your consent to process the following data elements:
(a) Cookies and Similar Technology
We or third party data and advertising platforms that we work with collect data from and advertising cookies, page tags, mobile identifiers and IP addresses. We use this data to infer users’ common identities across different services and multiple devices. We may do so, for instance, to tailor ads, personalize marketing, to enable us to determine the success of our advertising campaigns and to improve upon them. You can withdraw your consent at any time.
These third party data and advertising platforms may sometimes use data that we provide to them in order to improve their technologies and their ability to match common devices to users.
To learn more about interest-based advertising and how to opt-out of it, please see our Cookies Notice in Section 6. By clearing your cookies in your browser settings, you will no longer see personalized messages in this way but you continue to see ads over the internet that are not based on the information you provided to Topuz & Partners. Depending on your geographic location you can also withdraw your consent using our in-product cookie management tools.
(b) Contact Information
We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information. In jurisdictions where opt-in is required, we will only send you marketing materials based on your consent.
We collect and use the following data elements on the basis that we have to use this information in order to fulfil our contract with you:
(a) Account Information
We need to use your account information to run your account, provide you with services, bill you for our services, resolve disputes such as chargebacks and refund requests, provide you with customer support, and contact you or your organization about your service or account. These communications are of a transactional nature (e.g., service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You cannot opt out of these communications since they are required to provide our services to you.
We may also use billing information in aggregate to adjust or manage pricing at the individual level or across all service users.
(b) Customer Support Information
We will use information submitted through our Customer Support emails, chats, or phone calls, such as name, email, and message content, in order to provide you with customer support.
(c) Usage Information
We use data about how you use our services and how our services are performing to ensure that we’re meeting our service-level agreements (SLAs) or other contractual obligations to you.
(d) Device and Browser Data
We use device data both to troubleshoot problems with our service and to make improvements to it. We will also use this data to facilitate account verification and sign in and to enforce our password sharing and security policies. We collect this to help us improve your service experience through a specific device/browser by optimizing how the website looks in a particular browser, how your screen brightness affects your experience and to ensure the service operates optimally and as it should on different devices and browsers.
(e) Integration Data
We collect and use information from third parties and integration partners, where applicable to one of our services. To ensure you can sign-up to our service from a third party integration like Facebook, LinkedIn, Microsoft, Google/SSO;
Ensure you can use our service in conjunction with other services.
See further information here on our API partners – for other Topuz & Partners services see below or on the website for that service.
(f) Survey/Interview Questions and Responses
We use and professional tools provided by our partners (Microsoft, Zoho) machine learning techniques on survey data in order to provide users with useful statistics and more relevant insights from the data they have collected using our services.
(g) Aggregated or De-Identified Survey/Interview Questions and Responses
We use aggregated or de-identified information to provide users with useful benchmarking statistics and more relevant insights from the data they have collected using our services. We also use this data to enforce our agreements, where applicable.
We process your personal information in the following categories of data for legitimate interests pursued by us. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used.
(a) Contact Information
Where consent is not required, we use contact information to send you marketing information based on our legitimate interests for as long as you do not opt out. You can opt out of marketing communications at any time by clicking on the “unsubscribe” link in emails or changing the relevant setting in you account page. We retain your subscription data for as long as you remain subscribed. Your consent remains valid unless you withdraw it or we stop sending such communications
(b) Customer Support Information
We may use information provided to our Customer Support, Customer Success, and Sales teams such as name, email, and message content to train machine learning models to better predict customer support question type, provide answers, generate insights about customer support trends, and to improve our Customer Support for you. This data is de-identified where possible.
(c) Usage Information
We use information about how you use our services to improve our services for you and all users and to make recommendations to you and your organisation about our other services.
We may also use usage information such as levels and nature of activity in your account to personalise the features and services we highlight for you and your organisation in our Sites, improve user experience and to make recommendations to you and your organisation about our services through our sales and marketing efforts.
(d) Event Data
We use events contained in log data for many different business purposes to include:
– To create new services, features, content or make recommendations;
– To track behaviour at the aggregate/de-identified level to identify and understand trends in the various interactions with our services;
– To fix bugs and troubleshoot product functionality;
– To investigate security issues. For example: Your IP address is used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).
(e) First Party Information
We process other aspects of your account information (like the personal information you provide about your job, your job title, and your marketing preferences) as well as information obtained from public sources, to provide you with a personalized experience and relevant and useful marketing information as well as to make other product, feature and service recommendations to you and your organisation to optimize the use of the services we offer (where permitted by law).
You can object to us using your information as described above but in some cases, our ability to fully and properly provide our services to you may be impacted if you do not want us to collect or use the above data. Furthermore, if you are an account holder for a service or product by Topuz & Partners, your organisation controls some of the data which you include in your profile and they can also edit or remove that information through the primary administrator(s) of that account.
(f) Third Party Information
We combine information about you from third party sources (such as LinkedIn or your company webpage) with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve your service experience.
(g) De-Identified Device Data
We use aggregated or de-identified Device Data to extract usage patterns and to improve our services.
To respond to legal requests, we may need to disclose information we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
(a) To respond to legal requests, we may need to use and disclose information we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
(b) We may also use usage data, event data, and aggregated or (where possible) de-identified survey questions and responses:
(i) To enforce our agreements where applicable;
(ii) To investigate security issues;
(iii) To prevent or address potentially unlawful activities; and
(iv) To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud under our Acceptable Uses Policy.
3.2. Respondents/Referees
We Process Personal Data about you as a Respondent/Referee where:
(a) We have your consent
(b) We need to fulfil our contractual responsibility to deliver services to the person or entity that referred you to us;
(c) We have legitimate interests;
(d) We have a legal obligation
We rely on your consent to process the following data elements:
(a) Special Category Personal Data
As part of our research activities through surveys and interviews, we collect the following types of special category personal data under the GDPR:
(i) Personal data relating to health;
(ii) Personal data relating to ethnicity and nationality;
When we reach out to you via one of our surveys, we will ask for your valid, specific and informed consent before we let you proceed with filling out the survey. When our analysts arrange an interview with you, they will not start the interview prior to asking for your valid, specific and informed consent.
(b) Personal Data relating to your Sex and Age
We use personal data relating to sex and age in our surveys and phone calls for statistical analysis, demographic segmentation, and identifying healthcare disparities. However, given that such data may allow us to infer special category personal data even if it is not our intention (e.g., gender identity), we will ask for your explicit consent prior to collecting such data.
(a) Contact Information
We only use contact information (telephone numbers and email address):
(i) To reach out to you to participate in our research following a referral from a Participating Organisation. This is necessary for us to realise our contractual obligations with Customers (Participating Organisations) to conduct market research;
(ii) To respond to an inquiry on behalf of a Participating Organisation if you, as a Respondent/Referee, contact us;
(b) Cookies
We use Zoho to collect responses to our surveys. When you visit a survey page hosted by Zoho, Zoho may use cookies in accordance with their own Privacy Policy and Cookie Policy. We do not set cookies as part of this process.
We use Microsoft Teams to conduct interviews. When you join a Teams meeting, Microsoft may collect cookies or other technical data in accordance with their own Privacy Statement. We do not set or access any cookies during this process.
(c) Device and Browser Data
We use device data both to troubleshoot problems with our service and to make improvements to it.
We use your device and browser data to provide our services to Participating Organisations. For example: your IP address is used to ensure that you do not complete the same survey form, application or questionnaire twice to avoid ballot stuffing.
We use Calendly to schedule appointments. When you visit our Calendly booking page, Calendly may collect cookies and technical data in accordance with their own Cookie Policy. We do not set or access any cookies on Calendly-hosted pages.
(d) Inferred Geographic Location
We also may infer your geographic location based on your IP address. We use this feature to:
– Filter or analyse reviews based on country/regions to understand referee/respondent experiences across different regions;
– Identify regional trends, disparities or issues with organisations and individuals we research for the rankings;
– Compiling regional insights and location-based segmentation (e.g., comparing responses from the UK vs Germany);
– To prevent fraud and maintain the integrity of our research. The data helps us detect suspicious access patterns or spam/fake responses coming from unexpected places;
(e) Event Data
We use event data for many different business purposes including the following:
To create and improve services, features, content or make recommendations;
To track behaviour at the aggregate/de-identified level to identify and understand trends in the various interactions with our services; and
To fix bugs and troubleshoot product functionality.
(f) Survey Response Data
We use Zoho to send out surveys. Zoho may use first party machine learning or third party artificial intelligence tools on data around the type of survey we have sent you, the question type, survey responses (at an aggregated and de-identified/pseudonymised level only where possible), and device and event data associated with responses to fulfil their contract with us and provide us with useful and relevant insights from the data we have collected using Zoho’s services.
Specifically, Third use machine learning on survey data to help us by:
identifying trends in survey responses;
(i) ongoing training of models to optimise responses;
(ii) making product recommendations and providing guidance on which products and services work best in different scenarios;
(iii) Extracting and analysing usage patterns, for example, Zoho might identify when respondents prefer multiple choice versus open text questions and make predictive response suggestions when certain question types are selected. It might also use this data to help improve analysis of responses;
(iv) undertaking personalisation for us;
(v) improving user experience (for example, by collecting and using device and browser information from Respondents to improve how our survey service operates on those devices and in those browsers or by altering questions to match the responses being provided by a Respondent); and
(vi) identify insightful data trends (which do not disclose Personal Data) and make recommendations to Creators based on those trends.
We process your personal information in the following categories of data for legitimate interests pursued by us. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used.
(a) Usage Information
We use information about how you use our services to improve our services for you and all users and to make recommendations to our customers about usage of our services.
For example, we collect information about the types of questions you answer. This data will be aggregated and/or be de-identified where possible, so we can examine patterns in terms of respondent preferences when submitting responses. We collect and use all this data to help us improve our product so that questions are easier to answer and to help improve the completion rates on surveys/forms.
(b) Responses (in aggregated and/or de-identified form)
We use your responses to research the market, maintain our professional service offerings, and develop new features or services/products.
(c) Inferred geographic location
We may infer your geographic location based on your IP address to produce aggregated data around Respondent location trends. We will use this information to compare and look at trends on how our service operates and how you interact with surveys, on different browsers and devices. Note: we do not collect precise (GPS) location.
To respond to legal requests, we may need to disclose information we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We may also use usage data, event data, and aggregated or de-identified survey questions and responses:
(i) To enforce our agreements where applicable;
(ii) To investigate security issues;
(iii) To prevent or address potentially unlawful activities; and
(iv) To screen for and prevent undesirable or abusive activity . For example, we have automated systems that screen content for phishing activities, spam, and fraud under our Acceptable Uses Policy.
3.3. Visitors
We rely on one or more of the following processing conditions:
(i) Perform our contractual obligations; and/or
(ii) Satisfy any legal and regulatory obligations to which we are subject; and/or
(iii) Satisfy our legitimate interests in the effective delivery of information and services and in the effective and lawful operation of our businesses; and/or
(iv) When we have consent to process personal information.
In some cases, as a former website visitor, we may not have any personal information about you (for example if you have not interacted with our site or have cleared your cookies).
We rely on your consent to process the following data elements:
(a) Contact Information
We use contact information to respond to your inquiries or send you information about our services, either where you have agreed to this at the point of providing your information or where you operate in a business which may be interested in our services and for as long as you do not opt-out. opt-out of this marketing at any time.
(b) Cookies and similar technology
We or third party data and advertising platforms that we work with may use or combine multiple technologies, such as non-required cookies, page tags, mobile identifiers and IP addresses to infer users’ common identities across different services and multiple devices such as tablets, browsers, and mobile phones. We may do so to tailor ads to users, personalise marketing, to enable us to determine the success of our advertising campaigns and to improve upon them. We use this data to personalise online marketing campaigns to be relevant to you and your interests in our services.
You can withdraw your consent at any time on our Cookie Banner.
If you do not want Topuz & Partners to use this information to serve you targeted ads about our services, you may indicate your preferences at https://www.youronlinechoices.eu/. You may continue to receive ads over the internet that are not based on information you provided to Topuz & Partners.
These third party data and advertising platforms may sometimes use data that we provide to them in order to improve their technologies and their ability to match common devices to users.
Our website is built using WordPress.com, which may automatically set functional and performance-related cookies to ensure the site operates correctly. Additionally, certain third-party WordPress.com plugins which may use cookies or collect usage data, either directly or via their third-party integrations. We do not directly control the data collected by these plugins. We make reasonable efforts to review and disclose the use of non-essential cookies, and you may manage your cookie preferences through our banner or your browser settings.
Where applicable, we recommend visitors consult the privacy or cookie policies of those plugin providers (processors and sub-processors) for detailed information. You can access the data processors and sub-processors table on this page under “5. Data processors/ sub-processors table”.
(a) Device and Event Data
We use device data to fix bugs and troubleshoot problems with our service and to make improvements to it.
We also carry out the following processing for legitimate business interests pursued by us. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used.
(a) Third party profile information
Where permitted by law, we combine information about you from third party sources with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve our marketing/sales campaigns and website experience
(b) Usage information
We use information about how you have interacted with our websites to improve our website services for you and all users. Some examples relevant to you:
Examples: We collect information about the webpages you have visited and your activity on our sites at an aggregate level. We collect this information so that we can track the most visited and most useful parts of our website to identify what are our most popular services.
(c) Event data
We use event data for many different business purposes including the following:
(i) To monitor abuse and troubleshoot;
(ii) To track your preferences and create new services, features, content or make recommendations personalized for you;
(iii) To track behaviour at the aggregate/de-identified level to identify and understand trends in the various interactions with our services; and
(iv) To fix bugs and troubleshoot product functionality.
(d) Customer Support information
We may use information provided to our Customer Support, Customer Success, and Sales teams such as name, email, and message content to train machine learning models to better predict customer support question type, provide answers, generate insights about customer support trends, and to improve our Customer Support. This data is de-identified where possible.
(e) Referral information
We use referral information to track the success of our integrations and referral processes. For example, if you clicked on an advertisement for one of our brands, presented by one of our partners on the web, which brought you to one of our websites, we will record this information to help us track the success of advertising campaigns.
To respond to legal requests, we may need to disclose information we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We may also use event data:
(i) To enforce our agreements where applicable;
(ii) To prevent potentially illegal activities; and
(iii) To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud under our Acceptable Uses Policy.
We have appointed a Data Protection Officer (DPO). If you wish to contact our DPO you can do so via: info@globaldoctorreview.com
We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us and we’ll respond.
If you remain dissatisfied, you can make a complaint about the way we process your personal information to the Information Commissioner’s office (ICO), the UK supervisory authority (data protection regulator). Please follow this link to see how to do that.
We have appointed a Data Controller Representative in Turkey to comply with our obligations under the KVKK. You can reach out to the Data Controller Representative via:
privacy@globaldoctorreview.com; or
mahmutbatuhan.topuz@hs01.kep.tr
We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us and we’ll respond.
If you remain dissatisfied, you can make a complaint about the way we process your personal information to the Kişisel Verileri Koruma Kurumu (KVKK Board), Turkish supervisory authority (data protection regulator).
Should you have questions about our data processing practices in Turkey, you can access our VERBIS record here: https://verbis.kvkk.gov.tr
To make complaints to the KVKK Board, please follow the steps outlined here: https://www.kvkk.gov.tr/Icerik/5362/Veri-Ihlali-Bildirimi
