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Personal Data Protection Law

General Information on the Personal Data Protection Law

The Law on the Protection of Personal Data No. 6698 (hereinafter referred to as “KVKK”) was adopted on March 24, 2016, and published in the Official Gazette No. 29677 on April 7, 2016. ÖZEL EVA DİŞ AĞIZ VE DİŞ SAĞLIĞI POLİKLİNİĞİ (PRIVATE EVA DENTAL AND ORAL HEALTH CLINIC) processes personal data in compliance with the procedures and principles prescribed by KVKK and other relevant laws.

Under Article 10 of KVKK, data subjects must be informed before or at the time personal data is obtained. ÖZEL EVA DİŞ AĞIZ VE DİŞ SAĞLIĞI POLİKLİNİĞİ has prepared this disclosure statement to fulfill its obligation to inform. This statement includes information on the purposes for which personal data will be processed, to whom it may be transferred and for what purposes, and the rights of the data subject.

For the provision of medical diagnosis, examination, treatment, care, and similar healthcare services, the personal health data collected for this purpose, as well as other personal data subject to processing, are listed below:

• Personal Identity Information: Name, surname, date of birth, country of birth, city of birth, gender, marital status, nationality, Turkish Republic ID card details (e.g., TR ID number, serial number, wallet number, father’s name, mother’s name, birthplace, province, district, neighborhood, volume number, family order number, individual order number, household number, page number, registration number, issuing authority, reason for issue, date of issue, previous surname), copies of identity card/driving license/passport.
• Contact Information: Address, phone number, email address.
• Health Data: Health records, blood type, body measurements (height, weight, head, chest), laboratory and imaging results, test results, examination data, prescription information obtained during medical diagnosis, treatment, and care services, consent forms.
• Financial Data: Bank account numbers, IBAN numbers.
• Feedback and Opinions: Responses and comments shared for evaluating our services.
• Audio/Visual Data: Camera recordings during visits to our facilities, audio recordings during communication with our call center.
• Insurance and Social Security Data: Data related to private health insurance and social security institutions for financing and planning healthcare services.
• Digital Data: Browsing information, IP address, browser information, medical documents submitted voluntarily, surveys, forms, and location data obtained through the use of our website and mobile application.

Legal Basis for the Collection of the Above-Listed Personal Data

The legal basis includes:

• The Personal Data Protection Law No. 6698,
• The Basic Law on Health Services No. 3359,
• Decree-Law No. 663 on the Organization and Duties of the Ministry of Health and Its Affiliated Institutions,
• The Regulation on Private Hospitals,
• The Regulation on the Processing of Personal Health Data and Protection of Privacy,
• Regulations of the Ministry of Health and other relevant legislation.

The personal data processed by ÖZEL EVA DİŞ AĞIZ VE DİŞ SAĞLIĞI POLİKLİNİĞİ is stored in compliance with the law and principles of honesty, ensuring accuracy, and, when necessary, updated for legitimate and specific purposes only for the duration required by the relevant legislation or for the purposes for which they are processed. The explanations provided in this Disclosure Statement regarding personal data also cover special categories of personal data.

Recipients of Your Personal Data

Personal data may be shared with:

• The Ministry of Health, its sub-units, and family medicine centers;
• Insurance companies for private insurance-related transactions (health, retirement, life insurance, etc.);
• The Social Security Institution;
• Law enforcement agencies and other security forces;
• The Population Directorate;
• The Turkish Pharmacists’ Association;
• The Chamber of Dentists;
• The Turkish Medical Association;
• Judicial and administrative authorities;
• Laboratories, medical centers, ambulances, medical devices, and other healthcare service providers collaborating for medical diagnosis and treatment, both domestically and abroad;
• Healthcare institutions to which the patient is referred or personally applies;
• Your authorized legal representatives;
• Legal advisors, tax consultants, and auditors we work with;
• Regulatory and supervisory authorities and official bodies;
• Suppliers, service providers, archive service providers, and business partners.

Purposes of Processing Personal Data

The purposes include:

• Protecting public health, preventive medicine, medical diagnosis, treatment, and care services;
• Sharing requested information with the Ministry of Health and other public institutions and organizations under relevant regulations;
• Fulfilling legal and regulatory requirements;
• Financing healthcare services, performing eligibility checks, and sharing information with private insurance companies;
• Informing you about appointments via our Call Center and Digital Channels;
• Verifying your identity through Patient Services, Patient Rights, and Healthcare Professionals;
• Planning and managing internal operations;
• Conducting analyses to improve healthcare services;
• Monitoring and preventing unauthorized transactions;
• Performing risk management and quality improvement activities;
• Billing for services rendered and confirming agreements with affiliated institutions;
• Responding to inquiries and complaints about healthcare services;
• Taking necessary technical and administrative measures for data security;
• Providing information on campaigns and designing personalized content;
• Measuring and improving patient satisfaction.

Additionally, as stated in Article 6, paragraph 3 of KVKK, health-related personal data may be processed without explicit consent for protecting public health, preventive medicine, medical diagnosis, treatment and care services, and planning and managing healthcare services and their financing, by persons or institutions under the obligation of confidentiality.

Rights of the Personal Data Subject Under KVKK

Under Article 11 of KVKK, data subjects have the right to:

• Learn whether personal data is processed,
• Request information if personal data has been processed,
• Learn the purpose of processing and whether it is used in accordance with its purpose,
• Know the third parties to whom personal data is transferred domestically or abroad,
• Request correction of personal data in case of incomplete or incorrect processing,
• Request deletion or destruction of personal data under certain conditions,
• Object to unfavorable results due to automated analysis,
• Seek compensation for damages arising from unlawful processing of personal data.

Definitions and Abbreviations

Key terms include:

• Explicit Consent: Freely given, specific, and informed consent.
• Destruction: Deletion, destruction, or anonymization of personal data.
• Personal Data: Information related to an identified or identifiable individual.
• Processing of Personal Data: Any operation performed on personal data.
• Anonymization: Rendering personal data impossible to link with any identifiable individual, even by combining with other data.
• Deletion of Personal Data: Making personal data inaccessible and unusable for relevant users.
• Destruction of Personal Data: Making personal data permanently inaccessible and irretrievable.
• Special Categories of Personal Data: Includes sensitive data such as health, biometric, and genetic information.
• Data Subject: The individual whose personal data is processed.
• Data Controller: The entity responsible for determining the purposes and means of data processing.

We hereby declare that the personal and special categories of personal data listed above will be stored securely and in compliance with the law by ÖZEL EVA DİŞ AĞIZ VE DİŞ SAĞLIĞI POLİKLİNİĞİ as the “Data Controller” under KVKK.

Sincerely,