INFORMATION TEXT ON PERSONAL DATA PROTECTION

INFORMATION TEXT OF AYDINLAR SAĞLIK HİZMETLERİ A.Ş. IN ACCORDANCE WITH THE LAW ON THE PROTECTION OF PERSONAL DATA

In accordance with the Law on the Protection of Personal Data No. 6698 (hereinafter to be referred as “KVKK”), your personal data can be processed by Aydınlar Sağlık Hizmetleri A.Ş. (hereinafter to be referred as “Company”) under the title of Data Supervisor and limited to our commercial activities through recording, archiving, updating, transferring and/or classifying as explained below in order to carry out medical health services, to ensure maximum customer satisfaction, and to resolve your questions and problems quickly; limited to our commercial activity.

We would like to point out that in accordance with the laws and regulations prepared to protect the fundamental rights and freedom of individuals, personal data and especially the privacy of private life, our Company takes all necessary technical and administrative measures by providing the maximum level of security in order to prevent unlawful processing of your personal data, to avoid unlawful access to your personal data and ensuring its protection.

The personal data that we will process under the title of Data Supervisor are, included but not limited to, below.

METHODS OF OBTAINING YOUR PERSONEL DATA

Using certain parts of while browsing our Company’s web site
Filling of certain forms
Information sharing by yourselves while reaching our Company via telephone or e-mail address on our web site.
Your personal data are obtained for the purpose of applying the existing Company policies and procedures by methods like (including but not limited to) using our website or sharing data with our Company via e-mail or mobile applications. However, the methods mentioned are just examples and the methods of obtaining your data are not limited to these.

YOUR PERSONEL DATA PROCESSED BY OUR COMPANY

Your personal data which is processed by our Company under the title of Data Supervisor and considered as personal data with regards to KVKK (the Law on the Protection of Personal Data No. 6698) are shown below. However, the mentioned data are not limited to these.

Your identity data such as your name, your surname, Turkish Republic (TR) ID Number, your passport or temporary TR ID number in case you are not a Turkish citizen, place and date of birth, marital status, gender and photocopy of your TR ID Card, Passport or Driver’s License,
Your contact data such as address, phone number and e-mail,
Your data such as profession, bank account number or IBAN,
Your private health insurance and Social Security Institution data for the purpose of financing and planning your healthcare services,
Browsing data, IP address and browser information obtained during the use of our Company web site and mobile application.

In addition to your personal data listed above, your sensitive personal data which are listed below but not limited to them are also processed by our Company.

Your health data obtained during the execution of medical diagnosis, treatment and care services such as test results, examination data and prescription details
Images recorded by our closed-circuit camera system during your visit to our clinics
Oral and Dental Before and After photos
Panoramic X-ray and tomography images
Your Anamnesis Information and Treatment Planning

OUR PURPOSE OF PROCESSING YOUR PERSONAL DATA AND LEGAL BASES

Your personal data are processed for the purpose of

Informing you about your appointment,
Confirming your ID,
Confirming your relationship with the contracted institutions
Financing of your health services, covering of your examination, diagnosis and treatment expenses, sharing your requested information with private insurance companies,
Billing,
Making analysis for the purpose of improving our healthcare services, training our employees,
Performing quality improvement activities,
Responding to all your questions and complaints regarding health services,
Taking all necessary technical and administrative measures within the context of your data security
Participating in the campaigns and providing campaign information
Measuring, increasing, and researching patient satisfaction

within the framework of the Law on the Protection of Personal Data No. 6698 (KVKK), The Basic Law of Health Services No. 3359, the Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates, Private Hospitals Regulation, the Regulation on the Processing of Personal Health Data and Protection of Privacy, the Regulations of the Ministry of Health and other related legislation provisions.

Your healthcare data, which is under the scope of private personal data, is processed by our physicians who are under confidentiality obligation for the purpose of protecting public health, carrying out preventive medicine and medical diagnosis, treatment, and care services.

Our Company processes your data primarily based on the explicit consent it receives from you. However, in cases where explicit consent is not mandatory and according to cases listed under Article 5 of the KVKK Law No. 6698, your data can also be processed without your special consent.

Data like individual’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, costume and clothes, association, foundation and union membership, health, sexual life, criminal conviction, and security measures as well as biometric and genetic data all sensitive personal data. Sensitive personal data are limited to these. Your personal data with sensitive nature mentioned above cannot be processes without your explicit consent. In cases listed under the Article 6 of the KVKK Law No. 6698 can also processed without your special consent.

METHOD OF COLLECTING AND STORING YOUR PERSONAL DATA

Your personal data that you share with our Company can be collected through offices, branches, website, verbally, in writing or electronically, by automatic and non-automatic methods. Your personal data will be stored in electronic and/or physical platforms. The design of the necessary business processes and technical security infrastructure improvements are implemented by our Company to make sure that your personal data obtained and stored by our Company are not exposed to unauthorized access, are not manipulated, are not lost and damaged in the platforms where they are stored.

Your personal data will be stored and processed by taking all necessary security measures provided that they are not used outside the purposes and content notified to you and also will be stored and processed during the legal storing period, or if such a period is not foreseen, during the period required by the processing purpose. When this period is over, your personal data will be removed from our Company’s data flows by deleting, destructing, and anonymizing.

TRANFERING YOUR DATA WITHIN THE COUNTRY AND ABROAD

Within framework of the Law on the Protection of Personal Data No. 6698 (KVKK), The Basic Law of Health Services No. 3359, the Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates, Private Hospitals Regulation, the Regulation on the Processing of Personal Health Data and Protection of Privacy, the Regulations of the Ministry of Health and other related legislation provisions and in line with the purposes explained above, your personal data can be shared with:

The Ministry of Health, sub-units affiliated with the Ministry and Family (Primary) Healthcare Centers,
Private insurance companies (healthcare, life insurance and etc.)
Social Security Institution
General Directorate of Security and other law enforcement authorities
General Directorate of Population
Turkey Pharmacists Association
Judicial authorities
Laboratories, medical centers, medical device and health service institutions, within Turkey or abroad, that we cooperate with for medical diagnosis and treatment
Health institutions that you applied, or you are referred to in case of referral
Your authorized legal representatives
Regulatory and Supervisory institutions and official authorities
Your employer in case the billing will be made to your employer
Your suppliers, support service providers and business partners whose services you benefit from or cooperate with.

Your personal data cannot be transferred into third parties within the country, without your explicit consent. However, it can be transferred without your consent if one of the conditions mentioned in the third clause of the Article 6 of KVKK Law No. 6698, provided that sufficient measures are taken according to second clause of the Article 5 of same law.

The personal data can be transferred abroad if you provide your explicit consent. It cannot be transferred without your consent. However, the personal data of the related person can be transferred abroad without explicit consent; based on the existence of one the conditions mentioned in the second clause of Article 5 and third clause of Article 6 of the KVKK Law No.6698 and also, provided that a) there is adequate protection in the foreign country where the data will be transferred b) (when there is no adequate protection) Data Supervisors in Turkey and the relevant foreign country undertake the responsibility of adequate protection in writing and along with the approval of the Council.

YOUR RIGHT IN ACCORDANCE WITH THE ARTICLE 11 OF KVKK NO. 6698

By contacting our Company, you have the rights to acquire below information regarding your personal data.

Learning whether it has been processed or not,
Requesting information if it is processed,
Learning the purpose of processing and whether it is being used appropriately,
Knowing the third parties, within Turkey and abroad, to whom it has been transferred,
Requesting the correction of missing or incorrect processing,
Requesting its deletion or destruction with regards to conditions mentioned in the 7^th Article of KVKK,
Requesting the third parties to be notified of the transactions made in line with the above-mentioned clauses (e) and (f),
Objecting the emergence of a result against yourself that due to exclusive analysis by the automatic systems,
Demanding the compensation of damage in case you suffer any damage due to unlawful processing.

According to the 1st clause of the Article 13 of KVKK Law, you can submit your request to use your above-mentioned rights to our Company in writing or by other methods determined by the Board of Personal Data Protection. To use your right mentioned above, you can apply to our Company using the necessary information confirming your identity and the contact information we present below.

Contact Information:

Title :Aydınlar Sağlık Hizmetleri A.Ş.

You can send your application by filling out the “Application Form in Accordance with the Law on the Protection of Personal Data” on the web address aydinlardental.com
By delivering in person to the physical address Bağdat Caddesi Kılıçoğlu Apt. No:451 K:2 D:6 34740 Kadıköy/İstanbul
By sending via notary or e-mail
By sending into info@aydinlardental.com address with secured electronic or mobile signature, via your registered e-mail address or your e-mail address registered in our system.

We will conclude your request submitted to our Data Supervisor Company via above-mentioned channels, free of charge and within 30 (thirty) days at the latest. However, if the transaction requires and additional cost, the fee in the tariff determined by the Board of Personal Data Protection should be paid by your side.

As the Data Supervisor we can accept your request or reject it by explaining the reason and notify you of our reply in writing or electronically. If the request in your application is accepted, we will fulfill the requirements as Data Supervisor. If your application is caused by a mistake of our Company as the Data Supervisor, the fee received for your application will be reimbursed, if any.

STORAGE PERIOD OF YOUR PERSONEL DATA

To fulfill the obligations arising from the nature of commercial activity between you and our company and to carry out the rules of the workplace, your personal data will be stored for the period required for the purpose for which they have been processed.

In addition to this, if the processed data is processed due to the result of work contract signed later, in case of any dispute arising from the business contract or commercial contract, limited to the purpose of making necessary defenses within the scope of the dispute and as per the relevant legislation, after the termination of business and trade relationship, the Company will be able to store personal data during 10 (ten) year limitation period.

THE PRINCIPLES WHICH OUR COMPANY PREDICATES WHILE PROCESSING YOUR DATA

Our Company observes the following principles while processing your data:

Processing your personal data in line with the law and righteousness
Correct personal data processing
Certain scope of data processing
Processing for legitimate purposes
Making sure that processing is limited and measured to the purposes for which the data was collected and reprocessed
Up-to-date personal data
Keeping your data for the period required for the purpose for which it has been processed.

OUR MEASURES AND COMMITMENTS RELATED TO DATA SECURITY

Our Company undertakes to protect your data, which it processes in accordance with the KVKK Law No. 6698, in a safe and reasonable manner. It carries out all technical and administrative measures through various technologies to ensure the adequate level of security technologies to avoid unlawful processing and access to your personal data and to ensure the protection of your personal data. Moreover, your sensitive personal data of are processed by the taking special measures stipulated by the Board.

The Company will not reveal the personal data it obtained to anyone in violation of this clarification text and provisions of KVKK Law No. 6698 and will not use it for purposes other than processing. The Company proclaims that in the event that your personal data is shared with outsource service providers in accordance with the provisions of this information text, the outsource service providers in question will also comply with the commitments under this article.

AYDINLAR SAĞLIK HİZMETLERİ ANONİM ŞİRKETİ (COMPANY)