OZEL DEMIDERM POLIKLINIGI
CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA
This clarification text has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) contained in the Turkish Legal legislation and the General Data Protection Regulation of the European Union (“GDPR”) in order to inform the data subjects about the procedures and principles related to the processing of Personal Data belonging to patients/advisees who have applied to DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ. (“OZEL DEMIDERM POLIKLINIGI”).
One of OZEL DEMIDERM POLIKLINIGI’s highest priorities is ensuring the security of patients’/advisees’ personal data. As a result, in order to securely process the Personal Data of patients/advisees and prevent any unauthorized access or leakage of this data, OZEL DEMIDERM POLIKLINIGI implements the necessary security measures in accordance with applicable legislation.
DATA SUPERVISOR
Your Personal Data will be processed by the DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ. -owned OZEL DEMIDERM POLIKLINIGI, which operates at the address “Kültür Mah. Ali Çetinkaya Blv. No:22 K:4 D:8 Alsancak/İzmir/Turkey” within the scope of KVKK No. 6698. DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ. with the Mersis number 0274046496200015 is considered to be the “DATA CONTROLLER” within the scope of KVKK and the “DATA SUPERVISOR” within the scope of GDPR.
OZEL DEMIDERM POLIKLINIGI has signed an agreement with a law firm with Personal Data Protection Expertise as a “Data Protection Officer” within the scope of the GDPR, and the Compliance Process regarding the Protection of Personal Data within the scope of the KVKK and GDPR within the OZEL DEMIDERM POLIKLINIGI has been carried out with the advice and guidance of an expert law firm.
PERSONAL DATA TO BE PROCESSED
Your Personal Data mentioned below will be processed by the OZEL DEMIDERM POLIKLINIGI in accordance with the basic principles stipulated by Article 4 of the KVKK and Article 5 of the GDPR, Articles 5 and 6 of the KVKK and Articles 6 and 9 of the GDPR for the Purposes and Conditions of Personal Data Processing specified in the OZEL DEMIDERM POLIKLINIGI will be processed by the OZEL DEMIDERM POLIKLINIGI in accordance with the basic principles set forth in the GDPR Article 5 and GDPR Article 9 and in accordance with the law, in connection with the purposes of processing, limited and measured, in accordance with the principle of fairness and transparency, in an accurate and up-to-date manner, in order to ensure data security by taking all kinds of technical and administrative measures required by the legislation in order to remain within the scope of the purposes contained in this Clarification Text.
1- PERSONAL IDENTIFYING INFORMATION: Your name, surname, Republic of Turkey Identification Number and/or Passport Number and/or Temporary Republic of Turkey Identification Number, identification information, passport information, place and date of birth, marital status, gender, profession, signature and other identification data that may identify you.
2- CONTACT INFORMATION: Your address (residence/ work), phone number (home/ work fixed and/or mobile phone numbers you have provided), e-mail address, IP address, social media accounts and other contact data.
3- HEALTH INFORMATION: Your blood type, laboratory and imaging results, tests, allergies, chronic diseases, venereal diseases, infectious diseases, data on previous surgeries / operations, medications you use continuously, information about Covid-19 disease, medical treatments, prescription information, skin analysis data, body measurement analysis data, health habits and other health data necessary for treatment and applications to be applied to you.
4-YOUR VOICE RECORDING WITH YOUR PHOTOS AND VIDEO IMAGES: Your image and audio recording data contained in photos and/or videos recorded before, during and/or after a medical procedure, as well as your image data recorded by security cameras located under closed circuit recording to ensure workplace security.
5- FINANCIAL INFORMATION: Your bank account number, IBAN number, credit card information, billing information and other financial data.
6- TRANSFER AND ACCOMMODATION INFORMATION: If you are an International Health Tourist, your transfer information, round-trip flight ticket information, and hotel accommodation information will be provided.
FOR WHAT PURPOSE IS YOUR PERSONAL DATA PROCESSED
Your Personal Data is processed by OZEL DEMIDERM POLIKLINIGI in accordance with the KVKK and GDPR for to be able to create a patient file, to carry out your examination, medical diagnosis, treatment and care services, to carry out your controls after medical diagnosis and treatment processes, to manage complications that may occur, to communicate with you face to face, to manage appointment processes, to perform patient satisfaction and demand management, to fulfill legal and contractual obligations, to be able to bring the information about your health data, which must be kept in accordance with the relevant legislation, to be able to keep the information about your health data within the specified periods, to receive consultation services from other relevant specialist physicians when necessary in order to carry out your treatment correctly, to fulfill legal obligations in accordance with the legislation within the scope of health tourism, to transfer patients/clients coming within the scope of health tourism, to be able to plan accommodation, interpreter services, to announce innovations regarding medical treatment and applications, to inform third parties about the applied medical procedure in medical terms. be able to inform, plan and manage health services and financing, ensure workplace safety, fulfill the responsibilities arising from the legal relationship established between the doctor and the patient, fulfill financial and administrative obligations, provide technical and commercial security and fulfill public obligations purposes.
Your Personal Data will be processed within the scope of KVKK and GDPR by OZEL DEMIDERM POLIKLINIGI in the following situations and conditions:
Your personal data mentioned above will be processed in accordance with the aforementioned purposes and legislation in order to carry out your medical treatment and to fulfill the obligations related to your treatment. If you do not provide your relevant personal data, the legal obligations imposed on OZEL DEMIDERM POLIKLINIGI, which will provide services for your medical treatment, will not be fulfilled as required and your treatment and/or recovery processes will not be carried out successfully.
METHOD OF COLLECTION OF PERSONAL DATA
Your Personal Data will be collected in the following ways depending on the health care provided by OZEL DEMIDERM POLIKLINIGI and will be processed in accordance with KVKK and GDPR in order to enable OZEL DEMIDERM POLIKLINIGI to fully and properly fulfill its contractual and legal obligations throughout the examination, medical diagnosis, treatment and care services:
THE PURPOSE, METHOD AND LEGAL REASON FOR PROCESSING YOUR PERSONAL DATA
Your Personal Data may be processed by natural or legal persons authorized by the OZEL DEMIDERM POLIKLINIGI as “DATA PROCESSOR / SUPERVISOR”, by taking oral, written, camera and photo records, keeping the necessary technical and administrative security measures together with physical and electronic records, as well as by obtaining your explicit consent in cases where the relevant provisions of the KVKK and GDPR are foreseen, and also by obtaining your explicit consent.
CASES WHERE YOUR EXPLICIT CONSENT MUST BE OBTAINED
In accordance with Article 6/1/a of the GDPR and article 5/1 of the KVKK, your Personal Data may be processed in the following cases only with your explicit consent:
CASES WHERE YOUR DATA CAN BE PROCESSED WITHOUT SEEKING AN EXPLICIT CONSENT STATEMENT:
In accordance with Article 9/2/h of the GDPR and Article 6/3 of the KVKK:
In accordance with Article 6/1/b of the GDPR and Article 5/2/c of the KVKK:
In accordance with Article 6/1/f of the GDPR and Article 5/2 / f of the KVKK in accordance with our legitimate interests:
Your Personal Data will be processed without your explicit consent in accordance with GDPR Article 6/1/c, KVKK Article 5/2/a and KVKK 5/2/ç in accordance with the legal obligations, in the following cases:
TRANSFER OF YOUR PERSONAL DATA AND TO WHOM FOR WHAT PURPOSE IT WILL BE TRANSFERRED
Your Personal Data collected in accordance with the terms and purposes set out in Articles 5 and 6 of KVKK No. 6698 and the Terms of Personal Data Processing set out in Articles 6 and 9 of the GDPR, In accordance with Articles 8 and 9 of the KVKK and articles 45 and 49 of the GDPR, can be transferred to the 3rd persons and institutions mentioned below by providing all administrative and technical security measures in accordance with the legislation by signing the necessary confidentiality agreements for the purposes of execution and development of examination, medical diagnosis, treatment and care services, obtaining consultation services from other specialist physicians when necessary, fulfilling administrative obligations regarding health tourism legislation, planning transfer, accommodation and interpreter services of patients arriving within the framework of health tourism, communicating with patients, control appointments processes, planning and managing health services and financing, fulfilling the responsibilities arising from the legal relationship between the doctor and the patient, fulfilling financial, legal and administrative obligations, ensuring technical and commercial security and fulfilling public obligations, promoting the medical services offered by OZEL DEMIDERM POLIKLINIGI and to the extent that it is sufficient for the realization of the purpose.
In this context, your Personal Data processed by the OZEL DEMIDERM POLIKLINIGI will be transferred to:
DURATION OF PERSONAL DATA PROCESSING
Your Personal Data will be stored by OZEL DEMIDERM POLIKLINIGI to the extent and for as long as it is legally obliged to store it. The documentation and storage obligations are due to local norms related to trade, tax and health legislation. The table shown below shows the storage periods of your Personal Data.
Your Personal Data |
Data Retention Periods |
Your Identity Information |
20 Years After the End of the Service Provided to the Person Receiving the Service |
Your Contact Information |
20 Years After the End of the Service Provided to the Person Receiving the Service |
Your Health Information |
20 Years After the End of the Service Provided to the Person Receiving the Service |
Your Photo and Video Information |
20 Years After the End of the Service Provided to the Person Receiving the Service |
Your Financial Information |
5 Years After the End of the Service Provided to the Person Receiving the Service |
THE AGE LIMIT OF THE DATA SUBJECT WITHIN THE FRAMEWORK OF LEGISLATION
Within the scope of KVKK, patients / advisees may personally consent to the processing of their personal data, provided that they are at least 18 years of age. The consent of patients/clients who are below this age limit must be given by their legal representatives.
Within the scope of the GDPR, citizens of European Union countries and patients/advisees residing in European Union countries can give their consent to the processing of their personal data personally, provided that they are at least 16 years old or within the age limit stipulated in their country. The consent of patients/advisees under this age must be given by their legal representatives.
WITHDRAWAL OF CONSENT
If you give your consent to OZEL DEMIDERM POLIKLINIGI regarding the processing of your Personal Data, we will inform you that you can withdraw your consent at any time in accordance with Article 6/1/a of the GDPR and Article 5/1 of the KVKK for the purposes mentioned above. Your consent will be revoked if you submit your consent revocation statement to our contact address specified below again as indicated below.
THE RIGHTS OF DATA OWNERS IN ACCORDANCE WITH THE GDPR
As a Data Owner, your Personal Data is also protected in accordance with the GDPR. In cases where the GDPR is included in the jurisdiction (citizens of the European Union or residents of European Union countries), the rights of Data Owners are as follows:
THE RIGHTS OF DATA OWNERS IN ACCORDANCE WITH KVKK
The rights of natural persons whose Personal data has been processed in accordance with Article 11 of the KVKK are as follows:
You can submit your written application personally by coming to the “Kültür Mah. Ali Çetinkaya Blv. No:22 K:4 D:8 Alsancak/İzmir/Turkey” address on OZEL DEMIDERM POLIKLINIGI’s corporate websites, You can send it through a notary public or send it to info@demiderm.com or “demiderm@hs01.kep.tr” e-mail addresses by signing with a secure e-signature or send it by other methods specified in the KVKK, with wet signatures and documents to prove your identity, in case there are rights or requests that you want to use from your rights listed above, the articles on data owner rights contained in the GDPR and the rights specified in Article 11 of the KVKK that you clearly and clearly specify which rights you want to use. The presence of the following elements in your applications: first name, last name, signature, Republic of Turkey Identification Number / Passport Number / temporary Republic of Turkey Identification Number, residence or workplace address, e-mail address, telephone and fax number, is mandatory in accordance with the “Communique on the Procedures and Principles of Applying to the Data Controller”.
OZEL DEMIDERM POLIKLINIGI will finalize the request for free as soon as possible and no later than thirty (30) days, depending on the nature of the request. However, if the transaction also requires a cost, the fee will be charged at the tariff set by the Personal Data Protection Board.
CONSENT AND APPROVAL
When you read and accept this Information Notice, you shall be deemed to have represented, accepted and undertaken that you have been fully informed about the data processing performed by OZEL DEMIDERM POLIKLINIGI, you have understood your rights specified in KVKK and GDPR and you have provided a consent based on your free will in connection with the PROCESSING of your Personal Data and Special Categories of Personal Data by OZEL DEMIDERM POLIKLINIGI in accordance with this Information Notice.
You have right not to accept the Information Notice upon reading it.
DEMİDERM MAKİNA-MEDİKAL VE GÜZELLİK MERKEZİ SAN. TİC. İTH. İHR. LTD. ŞTİ., reports as a “DATA CONTROLLER” within the scope of KVKK and as a “SUPERVISOR” within the scope of GDPR.
Best Regards.