Clarification Text on the Policy on the Protection and Processing of Personal Data in accordance with the Law on the Protection of Personal Data No. 6698
Dear visitor,
Knowledge has been among our most important assets throughout history and has been the greatest source of wealth, wisdom and most importantly technology. Information is sometimes stored on our desk, sometimes in books, sometimes on paper, and sometimes in specially designed systems. Most importantly, knowledge is in the minds of employees. Today, it has become inevitable to collect personal data for the continuation of the services provided by the institutions, for the effective public offering of public services, for the development, distribution and marketing of goods and services. Personal data collected for these reasons, on the other hand, must be properly protected in any environment.
The purpose of the clarification text on the Protection and Processing of Personal Data is to ensure that all personal data belonging to all real persons associated with our Practice, including our employees, employee candidates and business partners, who benefit from our practice's products and services or who contact our practice to benefit from them, are relevant. In accordance with laws and regulations, necessary measures are taken to prevent unlawful disclosure, unlawful access to personal data, transfer or any security deficiencies that may occur in accordance with Article 12 of the Personal Data Protection Law, in this context, as a data controller. In accordance with the published and/or to be published legislation, it takes administrative and technical measures to ensure the highest level of security for the protection of the personal data of the data subject, carries out inspections or has them made. Informing the person concerned within the scope of fulfilling the obligation to inform.
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Data Controller
In accordance with the Personal Data Protection Law No. 6698, the data controller for the processing of your personal data is “Fenerbahçe mah. Bagdat Cad. No:104/1 D:10 Kadıköy/Istanbul”, the owner of the practice registered with the Göztepe/Istanbul Tax Office with the tax number 5320479827, Otorhinolaryngology Specialist Assoc. Dr. Kerem is Sami Kaya.
In the capacity of data controller; Your personal data, which are directly and/or indirectly shared with us for the purpose of processing, limited and measured, requested by visiting our workplace and/or our website, by calling our call center or by calling our call center and/or to purchase products or services. , within the framework of the purpose that requires their processing; can be recorded, stored, preserved, rearranged, shared with the institutions that are legally authorized to request such personal data, can be transferred to third parties in the country or abroad, in the cases and conditions stipulated by the Law, can be transferred, classified, deleted at the request of the person concerned, and We declare that it can be processed in the ways listed in .
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Personal Data to be Processed
Your personal data to be processed by the data controller is your data, which means “any information relating to an identified or identifiable natural person” as defined in the KVKK. Again, within the scope of the same Law, special categories of personal data are defined as “race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, association, foundation or union membership, health, sexual life, criminal conviction and security. data on the measures taken, as well as biometric and genetic data”.
Our practice, with the consent of patients/visitors, may obtain, classify, save, and store personal or private personal data, in whole or in part, according to the purpose of obtaining the personal data or for the period stipulated by the provisions of the relevant law._cc781905-5cde-3194- bb3b-136bad5cf58d_
Accordingly, your personal data categories and their contents, including but not limited to the following, are as follows:
identity data
Name, surname, TR identity number, SGK registration number, signature, marital status, identity card serial and sequence number, date of birth, place of birth, identity, driver's license, photocopy of passport
communication data
Telephone number, e-mail address, residential address
financial data
Your bank account number, IBAN number, credit card information, billing information
Transaction security
IP, Mac ID, Access details
Insurance Data
Your private health insurance data and Social Security Institution data for the purpose of financing and planning health services.
Special categories of personal data
(Your health data)
Your laboratory results, test results, examination data, appointment information, check-up information, measurements, drawings, various patterns, prescription information, including but not limited to all kinds of health services obtained during or as a result of medical diagnosis, treatment and care services. and your personal data regarding sexual life.
Visual and audio recordings
Two and 3D photos and video recordings taken before, during and after the procedure.
Family and relative data
If necessary, patient's relatives name, surname, contact information, family health information if necessary for patient history
Physical space security
camera recordings
It is your responsibility to inform your family members about the personal data of your family members that you will share with us and to obtain their explicit consent if necessary.
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Purpose of Processing Personal Data
Your personal data and in case of explicit consent, your personal data may be processed by the data controller for the purposes and legal reasons stated below, but not limited to these, and for similar purposes and reasons, if necessary, as specified in KVKK art.5 and article6. It is processed within the conditions and limited to the purposes and conditions in accordance with the principles and periods specified in the VERBIS registry of our practice.
In this context, the purpose of processing your personal data:
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Fulfilling our legal obligations,
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Confirming your identity as a service requirement provided by our practice,
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Protection of public health, preventive medicine, medical diagnosis, treatment and care services execution, planning and management of health services and financing,
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to share,
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Planning and managing the internal functioning of the practice and daily operations,
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Measuring, increasing and researching patient satisfaction,
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Supply of drugs and medical devices,
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Informing you about the appointment if you make an appointment,
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Analyzing and researching in order to improve health services,
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Participation in campaigns and giving campaign information by our practice,
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Designing special content, tangible and intangible benefits in web and mobile channels and being able to
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Invoicing can be listed under the headings.
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Personal Data Collection Method and Legal Reason
Your personal data can be collected verbally, in writing or electronically, including GSM technologies, through various methods based on Information Technologies, call center, website, social media channels, mobile applications and similar means._cc781905-5cde-3194-bb3b -136bad5cf58d_
In addition, for the purposes of processing personal data, based on and limited to at least one of the personal data processing conditions stipulated in Articles 5 and 6 of the Law, primarily the principles specified in Article 4 of the Law, and personal data are processed in accordance with the general principles and periods specified in the VERBIS registry of our company.
Mandatory Principles in the Processing of Personal Data
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Law and Integrity Processing
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Ensuring Personal Data is Accurate and Up-to-Date
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Processing for Specific, Clear, and Legitimate Purposes
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Related, Limited, and Measured to the Purpose for which They are Processed
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Preservation for the Time Established in the Relevant Legislation or Required for the Purpose for which they are Processed
Terms of Processing Personal Data
According to Article 5 of the Law, personal data cannot be processed without the explicit consent of the person concerned. The Explicit Consent of the Personal Data Owner should be related to a specific subject and should be disclosed with free will based on information. In the presence of one of the following conditions, it is possible to process personal data without seeking the explicit consent of the person concerned.
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a. Explicitly Prescribed in Laws
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b. Failure to Obtain Explicit Consent of the Related Person due to Actual Impossibility
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c. Direct Concern with the Establishment or Performance of a Contract
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D. Fulfilling Legal Obligation of Data Controller
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to. Relevant Person Made Public by Himself
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f. Mandatory Data Processing for the Establishment or Protection of a Right
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g. Obligatory Data Processing for the Legitimate Interest of the Data Controller
Processing of Private Personal Data
In article 6 of the Law, people's race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress and clothing, membership of associations, foundations or unions, health, sexual life, criminal conviction and security Data related to the measures taken and biometric and genetic data are defined as special quality personal data and it is also stipulated that the processing of sensitive personal data without the explicit consent of the person concerned is prohibited. According to this; Special quality personal data is processed by the data controller in accordance with the principles set forth in this Clarification Text, by taking all necessary administrative and technical measures, including the procedures and principles to be determined by the Board, and in the presence of the following conditions:
a. Special categories of personal data excluding health and sexual life: may be processed without seeking the explicit consent of the data owner, in cases expressly stipulated by the laws. In all other cases, the explicit consent of the data owner will be obtained in order to process the sensitive personal data in question.
b. Special categories of personal data regarding health and sexual life: only for the purpose of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, by persons or authorized institutions and organizations that are under the obligation of confidentiality. may be processed without consent.
Your personal data other than health and sexual life, which is considered as your private personal data, can only be transferred to the natural or legal persons listed above without your explicit consent, in cases stipulated by the laws. Your personal data related to health and sexual life, however, is the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, and the Law on Protection of Personal Data No. 6698, Health Services Basic Law No. 3359, 21.06.2019 In order to fulfill our legal obligations in the Regulation on Personal Health Data dated and other relevant legislation, it can be transferred to the natural or legal persons listed above without seeking your explicit consent. Electronic Medical Records and Electronic Health records are also within this scope.
In all other cases, the explicit consent of the data owner will be obtained in order to process the sensitive personal data in question. In the processing of personal data of special nature, it is also necessary to take adequate measures determined by the Board.
Deletion, Destruction or Anonymization of Personal Data
According to Article 7 of the Law, although it has been processed in accordance with the provisions of this Law and other relevant laws, personal data is deleted, destroyed or anonymized by the data controller, ex officio or upon the request of the data subject, in case the reasons requiring processing are eliminated. is brought. In this context, our practice retains personal data only for as long as it is mandatory and necessary for the purpose specified in the relevant legislation or for the purpose for which they are processed. In the event that the period expires or the reasons requiring its processing disappear, personal data will be destroyed by the destruction methods (deletion and/or destruction and/or anonymization) determined in accordance with the periodic destruction periods or the application of the data owner, if any. Personal data processing activities are carried out in accordance with the general principles specified in Article 4 of the Law No. 6698.
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Transfer of Personal Data
Regarding the transfer of personal data, regulations in parallel with the regulations on the Processing of Personal Data are stipulated in the Law. According to article 8 of the Law:
Personal data cannot be transferred without the explicit consent of the person concerned. Even without the explicit consent of the personal data owner, in case one or more of the following conditions are present Personal data may be transferred to third parties, with due diligence in our practice and by taking all necessary security measures with the methods prescribed by the Board. The relevant activities regarding the transfer of personal data are clearly stipulated in the laws,
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Establishment of a contract for the transfer of personal data by our Practice or be,
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The fact that the transfer of personal data is mandatory for our practice to fulfill its legal obligation ,
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Provided that the personal data has been made public by the data subject, limited to our examination room- transfer by,
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Mandatory for the establishment, exercise or protection of the rights of the owner or third parties of
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Provided that it does not harm the fundamental rights and freedoms of the data owner, personal data transfer is mandatory for the legitimate interests of our practice
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self-recognition of the person who is unable to express his or her consent due to actual impossibility or it is also mandatory to protect someone else's life or bodily integrity
According to Article 9 of the Law; Personal data cannot be transferred abroad without the explicit consent of the person concerned.
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Rights of Personal Data Owner
As a personal data owner within the scope of Article 11 of the KVKK;
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Learning whether your personal data is processed or not,
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If your personal data has been processed, requesting information about it,
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The purpose of processing your personal data and whether they are used in accordance with the purpose learning,
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Knowing the third parties to whom your personal data is transferred, in the country or abroad,
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Requesting correction of your personal data in case of incomplete or incorrect processing and requesting notification of the transaction made in this context to the third parties to whom the personal data has been transferred,
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Although it has been processed in accordance with the provisions of the Law No. 6698 and other relevant laws, in case your personal data is deleted or the reasons that require your personal data to be deleted are eliminated requesting the destruction of and the transaction made within this scope, to the third party to which your personal data is transferred requesting people to be notified,
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Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
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In case you suffer damage due to unlawful processing of your personal data, you have the right to demand that the damage be remedied.
As personal data owners, in accordance with paragraph 1 of Article 13 of the KVKK, you can submit your requests regarding your rights in writing or by other methods determined by the Personal Data Protection Board. You can access the application information text and the application form, which explains the channels and procedures to which you will submit your application, on our website or you can request it from us.
If the personal data owner submits his request regarding the rights to us in accordance with the procedure, he will conclude the relevant request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board. In cases where the application is rejected, the answer given is insufficient or the application is not answered in due time; You can make a complaint to the Personal Data Protection Board within thirty days from the date you learn our answer, and possibly within sixty days from the date of application.
Information and clarification for our visitors/patients, who are citizens of the European Union and other foreign countries, can be made with the help of an English translation of the text or an interpreter upon request.
The Clarification Text on the Processing of Personal Data, prepared in accordance with the current Law No. 6698 and other relevant legislation as of the date of publication, is submitted for your information.
Best regards.
Data Controller
Ear Nose Throat Diseases Specialist
Assoc. Dr. Kerem Sami Kaya