Personal Data Protection Law (KVKK) Information Text

Regarding the Processing/Protection of Personal Data

INFORMATION TEXT

Tansan Private Health Services and Trade Ltd. Co. (Tansan Private Polyclinic) attaches great importance to the processing and storage of all general and special personal data of all individuals, especially our valued patients who choose us, in accordance with the Law No. 6698 on the Protection of Personal Data (the Law). In order to provide our services, we may need to learn your personal and health information and record and store it within the limits required by the service to be provided.

Within the scope of this responsibility, our company, as the "Data Controller" as defined in the Law, may obtain, record, store, maintain, update, modify, reorganize, transfer to third parties to the extent permitted by law, share, classify, anonymize, and process your personal and sensitive personal data only within the framework and scope described in the Law and within the limits stipulated by legal regulations as stated below.

This privacy notice has been prepared by Tansan Private Health Services and Trade Ltd. Co. (Tansan Private Polyclinic) to fulfill its "Information Obligation" under the relevant Law towards personal data owners, and its purpose is to provide information on the protection of personal data.

Data Controller

In accordance with the Law No. 6698 on the Protection of Personal Data, your personal data may be processed by Tansan Özel Sağlık Hizmetleri ve Tic. Ltd. Şti. as the data controller.

2. Data Processed, Collected, and Used

Personal data collected for the purpose of providing you with services, including but not limited to personal and sensitive personal health data, such as your name, surname, Turkish Republic Identity Number (or passport number or temporary Turkish Republic Identity Number if you are not a Turkish citizen), place and date of birth, marital status, gender information, various identification documents that can identify you, your address, telephone number, email address, your contact information, your medical history, reports, information showing your medical history, examination and diagnosis data in your polyclinic file, data relating to the procedures performed on you, doctor's analyses and comments, prescription information, appointment information, photographs, all kinds of images, audio/camera recordings and images obtained from the camera recordings that are constantly recorded in our polyclinic, laboratory and imaging results, test results, and all kinds of data relating to health and sexual life obtained during the performance of medical examinations, diagnoses, treatments and care services, data relating to private health insurance and Social Security Institution data, etc., are considered personal data. Your personal data is collected directly from you in physical or electronic environments during the provision of healthcare services, through your communications via telephone or email, your visits to our website, or while you are at our clinic.

Your personal data may be processed in a manner that is relevant and proportionate to the purposes stated in Article 3 below, and may be transferred to the individuals, institutions, and organizations specified in Article 4, with your consent or for reasons stipulated by law.

3. The Purpose for Which Personal Data is Processed

At Tansan Private Health Services and Trade Ltd. Co., your personal data may be processed for the following purposes:.

– To fulfill our legal obligations and the requirements of the requested services as stipulated in the Basic Law on Health Services No. 3359, the Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Regulation on Private Health Institutions Providing Outpatient Diagnosis and Treatment, the Law No. 6698 on the Protection of Personal Data, the Regulation on the Processing of Personal Health Data and Ensuring Privacy, and other relevant legislation.,

– Identity verification and authentication to prevent your personal data from being accessed by others,

– Protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing,

– Planning and management of the internal workings of our polyclinic and daily medical activities,

– Providing personalized medication, medical supplies and equipment, and implementing customized treatment methods.,

– If you have an appointment, we can inform you about your appointment, provide information and/or remind you of your appointment.

– Meeting emergency and response requirements,

– Fulfillment of legal and regulatory obligations,

– Sharing and responding to information obtained with the Ministry of Health, judicial authorities, and other public institutions and organizations in accordance with legal provisions,

– To inquire about your eligibility with institutions/organizations that have agreements with our polyclinic, or to reach a financial agreement with these institutions regarding the health services provided to you.,

– Sharing information and verifying identities requested by contracted institutions/organizations, primarily private insurance companies, within the scope of financing healthcare services.,

– To enable your payments to be processed, to carry out e-invoicing, e-archive invoicing, and, if necessary, to process refunds, changes and corrections, and to issue invoices for the services we provide,

– Taking all necessary technical and administrative measures within the scope of data security for our polyclinic's systems and applications,

– To analyze your use of healthcare services, store your health data, and respond to your questions and complaints regarding medical diagnoses, tests, examinations, laboratory services, treatments, and other healthcare services, for the purpose of implementing, developing, and improving the healthcare services provided to you.,

– Implementing risk management and quality improvement activities,

– Sharing information with you via your preferred communication channel regarding treatment and services, and identifying procedure details,

– Providing necessary information in accordance with requests and inspections from regulatory and supervisory institutions and official authorities,

– To maintain your health data that must be kept in accordance with relevant legislation,

– Compliance with company internal policies and principles,

-Measuring and improving patient satisfaction following your access to healthcare services,

– Enabling us to forward and track your complaints and requests to our company,

– If you have given your permission for communication, we may contact you to conduct promotional and informational activities tailored to you, to carry out marketing and campaign activities, to send newsletters/brochures, and to inform you about our services, including data analysis and research.,

– Backing up/archiving, storing and preserving transaction records, complying with information retention, reporting and notification obligations in accordance with relevant legislation and fulfilling our legal obligations,

In accordance with the relevant legislation, your personal data obtained and processed may be transferred to the physical archives and/or information systems of Tansan Özel Sağlık Hizmetleri ve Tic. Ltd. Şti. and kept under custody both digitally and physically for the period specified in Article 5.

4. To Whom and for What Purpose Personal Data May Be Transferred

By ensuring that all necessary technical and administrative measures are taken to provide an appropriate level of security in accordance with the Personal Data Protection Law and related legislation, your personal and sensitive data may be processed for the purposes stated in the third section; to individuals, institutions and/or organizations permitted by the provisions of the Law No. 3359 on Basic Health Services, Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, Regulation on Private Health Institutions Providing Outpatient Diagnosis and Treatment, Law No. 6698 on the Protection of Personal Data, Regulation on the Processing of Personal Health Data and Ensuring Privacy, and other relevant legislation. Depending on your preferred payment method, your personal data may be transferred to the relevant banks, online payment systems, insurance companies (if you have received services under insurance, foundations, or funds), foundations, funds, and intermediary institutions; to the infrastructure provider to resolve your complaints and provide you with better service; to the relevant institutions, organizations, and infrastructure providers within the scope of e-invoicing and e-archiving processes; to the server hosting, archiving, storage, and software service providers we work with for the backup, storage, archiving, and archiving of transaction records; to our company employees, company partners and business partners, legal, financial, and tax advisors, auditors, and all private legal entities and public institutions and organizations permitted by law, for the resolution of your complaints or any problems that may arise, or for the fulfillment of our legal obligations. When your personal data is transferred to the third parties mentioned in this clause, only the necessary and relevant transfers will be made.

Please note that your personal data may be shared with the competent authorities only in a limited and proportionate manner, and only in cases where the privacy of personal medical records needs to be restricted for the protection of public health, such as the obligation to report infectious diseases to the competent authorities as stipulated in Article 58 of the Public Health Law No. 1593, or in cases of legal obligation such as the obligation to report a crime, or may be shared with another physician for consultation (exchange of views) regarding your health condition.

5. Method of Collecting Personal Data and Retention Period

Your personal data is collected by Tansan Private Health Services and Trade Ltd. Co., specifically the Tansan Private Polyclinic, during, before, or after your visit, through verbal, written, visual, or electronic means via telephone, SMS, and similar telecommunication methods; online through the Social Security Institution system; from records shared when utilizing private insurance companies and/or from records of other health institutions and organizations if you provide them; from emails you send; from call center call records; from our website; from test results, examinations, films, X-rays, graphs, MRI results, prescriptions, camera recordings, photographs, etc., obtained at our polyclinic; and through written, printed, and similar channels such as magazines and subscription forms, as well as through audio and video recordings made for security purposes, automatically or non-automatically, in written, verbal, or electronic form, and stored in physical and digital environments for the purposes stated in section 3.

Your personal data will be stored in accordance with the provisions of the Law No. 6698 on the Protection of Personal Data, relevant legislation, and other applicable legislation, for any prescribed periods; if no such period is prescribed, it will only be stored for the duration necessary for the healthcare service to be provided to you and for the purpose for which it was processed. In accordance with Article 7/1 of the KVKK (Law on the Protection of Personal Data), your personal data will be deleted, destroyed, or anonymized when the purpose requiring its processing ceases to exist and/or when the retention periods we have mandated for processing your data under the legislation expire.

6. Data Subject's Rights and Exceptions

Pursuant to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (Council of Europe Convention No. 108), Article 8 of the European Convention on Human Rights, Article 20 of the Constitution, and Law No. 6698 on the Protection of Personal Data;

You may request access to your Personal Data by applying to our company in writing or through other methods determined by the Personal Data Protection Board;

– To find out if it has been processed,

– The right to request information about the scope of your personal data being processed, to access and obtain samples of this data if it has been processed,

– To learn the purpose for which your personal data is processed and whether it is being used in accordance with its purpose,

– To know the third parties to whom your personal data is transferred, domestically or internationally,

– Requesting the correction of your personal data if it is incomplete or inaccurate.,

– Requesting that changes to your personal data be notified to the individuals or organizations with whom the data has been shared.,

– Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the KVKK (Law on Protection of Personal Data),

– Requesting that third parties to whom your personal data has been transferred be notified of the aforementioned processes,

– You have the right to object to an outcome that is detrimental to you, resulting solely from the analysis of your personal data by automated systems, and

– You have the right to claim compensation for damages if you suffer harm as a result of the unlawful processing of your personal data.

You can submit your requests regarding personal data, along with the necessary information to identify you and your explanation of the right you wish to exercise, to our company's address at “Teşvikiye Mah. Hakkı Yeten Cad. Doğu İş Merkezi No:15/8 Şişli/İSTANBUL” via registered mail, notary public, or hand delivery, in the form of a written petition in Turkish. Our company will process your requests free of charge within a maximum of 30 days. However, if the process requires additional costs, a fee may be charged according to the tariff determined by the Board. Our company has the right to accept or reject the request, explaining the reasons, and to notify the relevant person of its response in writing or electronically. If the request is accepted, our company will fulfill your request. If any fee has been charged due to an error on our part, the fee will be refunded to the relevant person. In cases where the application is rejected, the response is deemed insufficient, or no response is given within the specified time, the relevant person reserves the right to file a complaint with the Board within 30 days from the date they learn of our company's response, and in any case within 60 days from the date of the application. According to Article 14/2 of the KVKK (Law on Protection of Personal Data), complaints cannot be filed with the Board without first exhausting the application process with our Company, which is the data controller. Those whose personal rights have been violated retain the right to compensation under general provisions.

According to Article 28/2 of the KVKK (Law on Protection of Personal Data), Article 11 regulates your rights, excluding the right to claim compensation for damages;

1. a) The processing of personal data is necessary for the prevention of crime or for criminal investigation,
2. b) Processing of personal data that has been made public by the data subject themselves,
3. c) When the processing of personal data is necessary for the performance of supervisory or regulatory duties by authorized public institutions and organizations, as well as professional organizations with the status of public institutions, based on the authority granted by law, or for disciplinary investigations or prosecutions,
4. (d) We state that the processing of personal data shall not apply in cases where it is necessary for the protection of the economic and financial interests of the state in relation to budgetary, tax and financial matters.
5. Situations in which Personal Data May Be Processed Without Explicit Consent According to the KVKK (Turkish Personal Data Protection Law)

In accordance with Article 5 of the KVKK (Law on Protection of Personal Data), your personal data may be processed without your explicit consent in the following cases:

– In cases explicitly provided for in the laws,

– If you are unable to express your consent as a data subject due to factual impossibility, or if your consent is not legally valid, and the processing of your personal data is necessary for the protection of your or another person's life or physical integrity,

– The processing of your personal data belonging to the parties to the contract is necessary provided that it is directly related to the establishment or performance of the contract,

– It must be necessary for the fulfillment of a legal obligation.,

– Your personal data has been made public by you,

– Data processing is necessary for the establishment, exercise or protection of a right,

– Data processing by Tansan Private Health Services and Trade Ltd. Co. is necessary, provided that it does not harm your fundamental rights and freedoms,

– In addition, your personal health data may be processed by persons or authorized institutions/organizations bound by an obligation of confidentiality, without seeking the explicit consent of the data subject, for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and planning and managing health services and their financing.

For disclosure, use, and transfer of information to individuals/institutions that may request this information in order to fulfill our company's legal obligations arising from applicable legislation and/or due to legal requirements, explicit consent is not required.

Trade Name: Tansan Private Health Services and Trade Ltd. Co.

Contact Address: Teşvikiye Mah. Hakkı Yeten Cad. Doğu İş Merkezi No:15/8 Şişli/ISTANBUL

Mersis No: 0822002958300010

Contact Phone: 0212 225 2756

Fax Number: 0212 225 2757

Email Address: tansan95@gmail.com

 

I have read and understood the Personal Data Disclosure Statement prepared by Tansan Private Health Services and Trade Ltd. Co. (Tansan Private Polyclinic), and I also acknowledge that I have been verbally informed about the matter.,

I have been informed about the purposes of processing my personal data, the methods and legal grounds for collection, my rights regarding the protection of my personal data, the circumstances under which my data may be transferred, mandatory circumstances, data security, and my rights of appeal, as detailed in the Personal Data Processing/Protection Information Text.,

I HAVE MY EXPLICIT CONSENT that all my personal data, including my health data, may be recorded, stored, and shared by Tansan Private Health Services and Trade Ltd. Co. (Tansan Private Polyclinic) and its employees within the framework of the principles stated above, and that they may contact me via the mobile devices I have specified below, via the internet, or by mail to my address, etc.

 

*In accordance with the Patient Rights Regulation; one copy of the form will be given to you. If you do not receive the form, please inform the person who obtained your consent.

Patient's Name and Surname…………………………………………………

Address:

E-mail:

Wire:

 

Signature:…………Date: ……./……./………Time:…..

 

 

If the patient is under 18 years of age or unconscious:

 

Patient's Relative's Name and Surname:………………………………………..

 

Signature:…………Date: ……./……./………Time:…..

 

Relationship: …………………………..

 

Write "I understood what I read" in your own handwriting: …………………………………………………………………..

 

INTERPRETER (IF AVAILABLE) (If the patient has language/communication problems)

 

In my opinion, the information I translated was understood by the patient/patient's relative.

 

Translator's Name and Surname:………………………….…….

 

Signature: …………Date: …../……./……… Time:……