ABBOTT PRIVACY POLICY -
TURKEY ONLY

For Turkish

Effective Date: 1^st of September, 2024

Our privacy notice is part of our approach to transparency and protection of your personal information.

This Privacy Policy describes how Abbott collects, uses, and shares your Personal Information when you use our products, visit our websites and apps, and interact with us offline controlled by Abbott Laboratories, as applicable (collectively, the “Services”). It also tells you about the rights and choices you may have with respect to your personal information.

Abbott Laboratories (“Abbott”) is the “Controller” for the processing of your personal data for the purposes mentioned below.

Abbott may offer certain products, programs or services that have unique or additional terms, privacy notices and/or consent forms that explain how Abbott processes information. For details on any product-specific features, notices or terms, please review the terms for those products and services.

How does Abbott define Personal Information?

“Personal Information” means information that identifies or relates to you as an individual or could be used to identify you and which is submitted to and/or collected and used by Abbott via its website. Personal Information includes “personal data” as that term is defined in applicable Turkey data protection laws. Personal Information also includes “Special Category Information” as defined below, except where otherwise noted. Personal Information may not include information that has been made anonymous, which means information that no longer identifies you individually or can be related to you as an individual, or has been de-identified, or aggregated. Examples of Personal Information include, but are not limited to, your name, email address, mailing address, phone number, date of birth, gender, online identifier or other identification number.

“Special Category Information” means Personal Information that is considered sensitive under the Turkey data protection law, and can include but is not limited to, genetic data, health data, trade union membership, racial and ethnic origin, political opinions, religious, philosophical or ideological convictions, data related to one’s sex or private life, tribal data, data relating to one’s criminal convictions or criminal behaviour, and biometric data.

How does Abbott collect Personal Information?

Abbott collects Personal Information online and offline in a few different ways:

• Personal Information that you provide. We may collect Personal Information and other information that you provide when you use our Services, attend Abbott programs or events, participate in research, and any other data that you may choose to submit or provide. With your permission, we may also collect data from another source like a device or social media account. Such information may include, but not be limited to, contact information (such as your name, postal address, e-mail address, telephone number, user ID, and password), date of birth, professional credentials, experiences, activities, skills, preferences, hobbies and interests.
• Personal Information from public or third-party sources. We may collect data from public sources including, but not limited to, social media and other websites that enable social sharing. We may also collect Personal Information from government agencies, public or third-party information sources, third-party service providers, or business partners. In addition, we also may collect information from industry and patient groups and associations or combine information we have collected from multiple sources. We may engage third-party service providers to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on our Services to assist you with your order and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.
• Personal Information collected from devices you use to connect with us or use our Services. Abbott collects data through our websites and apps and automatically from devices you use to connect to our Services. See our Cookie Policy to know more on how we use cookies and similar technologies in this website.
• Personal Information collected with business partners. We sometimes work with other organizations to provide you with our Services. When that happens, we require that information be protected.

If you choose to submit any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

From time to time, we may use or augment the Personal Information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online. To protect your privacy, you should not provide Abbott with any information that is not specifically requested.

You may also give us permission to access certain personal information maintained by other service providers. For example, you may link your social media or Google account to Abbott, which allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check those policies before granting Abbott access. You agree that we are not responsible for any acts or omissions by these social media service providers.

What Personal Information does Abbott collect, and how do we use it and share it?

This table offers an overview of what personal information does Abbott collect, and how do we use it and share it. This is not an exhaustive list and only some parts would apply depending on the type of user, the case, and the processed information. Abbott may offer certain products, programs or services that have unique or additional terms, privacy notices and/or consent forms that explain how Abbott processes information. For details on any product-specific features, notices or terms, please review the terms for those products and services.

Your personal data may be collected, processed and transferred in the light of the principles set forth in Article 4(2) of the Law No. 6698 on the Protection of Personal Data ("LPPD"), by obtaining your explicit consent or without obtaining explicit consent in accordance with the legal bases set forth in Article 5(2) or legal bases set forth in Article 6(3) for Special Category Information. Your above-mentioned personal data will be gathered on our website by means of form submissions or through the use of technologies like cookies. In addition, any commercial electronic messages that Abbott will send you will be in line with your consent and the privacy notice for commercial electronic messages, including the legal requirement that Abbott register your contact address in a national Commercial Electronic Message Management System (MMS) established by the Ministry of Trade and register your email address with the Commercial Electronic Message Management System (MMS), which will be shared with the Ministry of Trade and the Union of Chambers and Commodity Exchanges of Turkey.

Abbott will share your personal information with a third party in connection with the sale or transfer of one of its product lines or divisions so that the buyer can continue to perform the processing of personal data for the purposes above mentioned, where applicable. Abbott will be required to disclose your personal information to respond to authorized information requests from government authorities or law enforcement agencies or when otherwise required by law. In certain cases, Abbott will also disclose your personal information to legal advisers and auditors, when required and legally permitted.

Abbott will also share and provide access to your personal information to vendors with whom Abbott contracts to carry out business activities on its behalf (e.g., customer support services, delivery services, online payment services and fraud detection services, cloud, or hosting providers, marketing activities, where applicable, etc.). If Abbott provides your personal information to vendors to assist us with our business activities, it is Abbott’s practice to require those vendors to keep your personal information confidential and to use your personal information only to perform functions following Abbott’s instructions, including its erasure or return upon termination of their services.

How long will Abbott keep my personal information?

We will keep your Personal Information in our records for as long as necessary for the purposes described in this Privacy Policy or otherwise authorized by law. This includes providing you with a service you have requested from us or to comply with applicable legal requirements. It also includes keeping your Personal Information for so long as there is any possibility that you or we may wish to bring a legal claim, or where we are required to keep your personal information for legal or regulatory reasons. We may also retain your personal information where such retention is necessary to protect your interests or the interests of another natural person. Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. Where we no longer require your Personal Information for any of the purposes described in this Privacy Policy, your personal information will be deleted from our systems and will no longer be available to us.

If you wish to receive further information regarding our record retention procedures, please contact us using the contact details provided under the “How Can I Contact Abbott?” section below.

Does Abbott transfer personal information to different jurisdictions?

Abbott may transfer your personal information to other jurisdictions different from the country where you are based, and where required, after having obtained your consent or complying with the other conditions stated in LPPD for cross-border data transfers. These countries may include the United States, where Abbott is headquartered, and other countries which may not guarantee the same level of protection of personal data as the one in which you reside.

To safeguard your personal information, we will only make such transfers as necessary to use your personal information as described in this policy and only transfer your personal data as permitted by Turkey’s privacy/data protection law.

Which are your Privacy Rights?

The applicable data protection law grants you comprehensive data protection rights to your personal information. Some or all of the following rights might be granted by the laws of your country or region. Your privacy rights are described under Article 11 of the LPPD:

• The right to require the erasure of your personal information;
• The right to rectify any wrong or incomplete personal data that Abbott holds about you;
• The right to opt out at any time of processing activities based on legitimate interest. This will be noted at the bottom of any email you receive from us;
• The right to access the personal data that Abbott holds about you;
• The right, in some cases, to object to the processing of your personal data on legitimate grounds;
• The right not to be subjected to automated decision making intended to evaluate certain personal aspects relating to you, such as analytics based on conduct. Please refer to the Cookies Policy for more information on how to exercise this right if it is indicated that cookies are being used;
• Where you have provided your personal data to us with your consent or as part of a contract, the right to the portability of that personal data to another person or, if it’s technically feasible for us to do so, to another company;
• The right to lodge a complaint with your national data protection supervisory authority or to receive compensation for any damage you suffer; and
• The right to withdraw your consent to Abbott’s processing of your personal data, without detriment or negative consequences (e.g., withdraw your consent for receiving marketing communications, if consent is the lawful basis for such processing).

Please note that these rights could be rejected or limited according to the applicable data protection regulations or may depend on additional requirements.

How does Abbott protect the privacy of children?

Abbott does not knowingly collect or use any personal information from children, except if explicitly indicated in the Privacy Notice. We do not knowingly allow children to order our products, communicate with us, or use any of our online services.

If you are a parent and become aware that your child has provided us with information, please contact us at the above email address, and we will work with you to address this issue.

How does Abbott keep Personal Information Secure?

It is Abbott’s practice to apply appropriate security measures to the processing of personal information, however, the confidentiality of personal information transmitted over the Internet cannot be guaranteed. Personal information can be accessed by a restricted number of Abbott employees. We train our employees about the importance of privacy and how to handle and manage customer data appropriately and securely. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. Abbott cannot guarantee that unauthorized third parties will not gain access to your personal information; therefore, when submitting personal information to Abbott Web Sites, you must weigh both the benefits and the risks.

We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health, where applicable.

We may provide links to websites and other third-party content that are not owned or operated by Abbott. You should check the privacy policies of any third-party sites different from this one before submitting personal information.

Personal information can be accessed by a restricted number of Abbott employees. We train our employees about the importance of privacy and how to handle and manage personal information appropriately and securely.

How can I contact Abbott?

You may direct any queries you have about our processing of your personal information or you may request any of the above rights by contacting emea-dpo@abbott.com

Please indicate the specific right that you want to exercise and for which Abbott product, website or business division, as applicable, in the subject line of the e-mail.

Whenever possible and applicable, please use the same email address used for the registration to make a request of a personal data right. We will do our best to respond to all reasonable requests in a timely manner.

How Will I Know Whether Abbott Has Updated This Policy?

Without prejudice to your rights under applicable law, Abbott reserves the right to amend this Privacy Policy without prior notice to reflect technological advancements, legal and regulatory changes and good business practices. In certain jurisdictions, registered users will be notified by email of any changes and relevant information will be posted on the Abbott Web Site.

If Abbott changes its privacy practices, an updated version of this Privacy Policy will reflect those changes and we will notify you of such changes by updating the effective date at the top of this Privacy Policy.