CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA and DATA POLICY

 

 

As a legal entity that processes personal data due to its activities, Servet Terziler Sağlık Hizmetleri A.Ş. and its affiliated clinic Dr. TERZİLER EXCLUSIVE HAIR CLINIC attach great importance to the protection of your data. Our legal entity, in its capacity as data controller, obtains, collects and processes your personal data in accordance with the Law No. 6698 on the Protection of Personal Data and the relevant sub-regulations.

 

 

This Text, which provides information about the processing and protection of personal data, gives details on:

 

-The source from which personal data are obtained,

-The legal grounds for obtaining and processing personal data,

-The purposes for which personal data are obtained and processed,

-Whether personal data are transferred and to whom and for what purposes they may be transferred,

-The legal rights of those whose personal data are processed,

 

 

PERSONS WHOSE DATA WE PROCESS

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC, in its capacity as data controller, processes personal data limited to the following groups of persons.

 

1-Employees.

2-Employee Candidates (including reference persons declared by job applicants)

3-Interns.

4-On-the-Job Training Trainees.

5-Patients.

6-Prospective Patients (Persons who are interviewed and contacted for the purpose of diagnosis, treatment or receiving such a service, persons whose name, surname and telephone information are received and interviewed as a result of fair or stand promotion activities)

7-Patient relatives and companions.

8-Parties to all kinds of commercial activities or persons with whom we cooperate or will cooperate due to commercial activity or authorized or employees of such companies (Supply, advertising, promotion, support, marketing, transportation, reference sources, etc.).

9-Attorneys and consultants or authorized persons or employees of consultancy companies.

10-Visitors.

11-Legal representatives, parents, guardians or custodians of all data subjects.

12-Persons who are parties to legal proceedings and their legal representatives.

13-Third parties who have been contacted even though they have no commercial or legal connection.

 

 

 

 

PERSONAL DATA WE PROCESS

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC, in its capacity as data controller, processes the following personal health data, general and special categories of personal data in accordance with the principles of „lawfulness“, „necessity“, „fitness for purpose“ and „limitation“.

 

Identification Data

 

All data related to the identity of the persons whose data will be processed, such as name-surname, nationality, Turkish ID number, passport number and information or temporary Turkish ID number, place and date of birth, marital status, gender information.

 

Personally Identifiable Data

 

A person’s handwriting or signature is personally identifiable data.

 

Communication Data

 

All contact data such as residential address, business address, correspondence address, telephone or mobile phone number, e-mail address.

 

Audio-Visual Data

 

The images taken by the Company’s security cameras with a closed circuit camera system for security purposes, the data taken with the special written permission (consent) of the patients for promotion, research, persuasion processes, confirmation and proof that the medical procedure has been performed or for the promotion of the medical procedure to other prospective patients, the data taken for visuals (photographs or video recordings) in order to reveal the developments in the treatment result are the data within this scope.

 

Personal Data

 

Data received in accordance with the law or labor contract regarding the personal transactions of the employees such as the date of employment, wage, number of working days per month.

 

Education Data

 

Data on the educational status and educational certificates of employees, employee candidates, interns or on-the-job training trainees or other relevant persons.

 

Job and Occupational Data

 

All data relating to the job or occupation in respect of employees, employee candidates, interns or on-the-job training trainees or other relevant persons. (including data on professional experience, diplomas, courses).

 

 

 

Comment and Complaint Data

 

Comment and complaint data transmitted to our Company through the website or other channels by giving consent and consent in order to evaluate the services provided.

 

Address or Location Data

 

Address or location data transmitted by persons in any way and with their consent.

 

Transaction Security Data (IP Data and Cookies)

 

IP address, browser information, website login and exit and password information, (Mac ID, IP address information, website login and exit and password information) are within this scope.

 

Legal Data

 

All data relating to individuals as plaintiffs, defendants and enforcement data. Data about employees and any person who has a lawsuit or enforcement proceedings with the company.

 

Financial Data

 

Data such as bank account number and IBAN number of individuals. Data requested and processed in terms of employees working in the company and patients receiving services from the company.

 

Health Data relating to Patients

 

All kinds of health data obtained during the execution of medical diagnosis, treatment and care services such as laboratory and medical imaging results, medical test results, blood type, examination data, prescription information, which must be followed for legal reasons in medical files or processed with the consent of the person within the scope of the health service received. In addition, the health report and other medical documents in the personnel file of the employees are also within this scope.

 

Health Data relating to Employees

 

Data contained in medical reports and medical documents received from workers to be kept in the personnel file in accordance with labor legislation, employment contract and occupational health and safety legislation.

 

Customer Transaction Data

 

Patient’s credit card, mail order, advance receipt, payment receipt, invoice, promissory note, check, receipt, order information, request information, etc. are data within this scope.

 

Appearance Data

 

Body data such as fixtures, uniforms, materials and shoe size etc. are included in this scope.

 

 

Biometric Data

 

This includes palm data, fingerprints, retinal scans, facial recognition, etc.

 

Physical Location Security Data

 

Entry and exit registration information of employees and visitors, security camera records are data within this scope.

 

III. PROCESSING OF PERSONAL DATA

 

A.OBTAINING OF PERSONAL DATA

 

1.Through Which Channels and How Personal Data is Collected

 

Your Personal Data may be obtained by:

 

1.1.From our website belonging to Servet Terziler Sağlık Hizmetleri A.Ş.;

 

*Requesting name, telephone number and e-mail information in the „Contact“ section,

*Requesting name, phone number and e-mail information in the „Contact Us“ section,

*Getting contact and obtaining information through the phone numbers 02129860772 in the contact section,

*Transmitting personal data of the patient or prospective patients through the JİVOCHTA program from the „Get Free Consultancy and Price Quote“ section

 

Personal data provided by patients or prospective patients in ways such as above may be obtained through the following channels:

 

1.2.Communication and appointment calls via phones in the use of clinical assistant staff or via applications such as SMS or WhatsApp,

1.3.In case you apply to our clinic, face-to-face interviews with the relevant medical team,

1.4.Consultation and examination service, examination, diagnosis or treatment received at the clinic,

1.5.Personal data being included in the contracts and other commercial activity documents and communication platforms of the person and company officials or employees with whom the company has a business relationship as required by the commercial activity,

1.9.Personal data being included in the contracts and other commercial activity documents and communication platforms of our consultants, lawyers and advisors or authorized or employees of consultancy companies,

1.10.Applications made through panels such as „contact us“ or „get information“ through the promotion and advertisement of the clinic on social media,

1.11.Requesting personal data required by the legislation in order to connect to the broadcast and mobile phone number for encryption in the wireless network (Wi-Fi) broadcast special for guests within the scope of wireless Internet service,

1.12.Obtaining data from logins to the website by recording the MAC ID (Device Identification Information),

1.13.Personal data being available on the communication platforms of third parties with whom we communicate or if we are contacted even though we have no commercial or legal connection with the clinic

1.14.Similarly with other legal means of data retrieval,

 

 

 

B. PURPOSES AND LEGAL GROUNDS OF THE PROCESSING OF PERSONAL DATA

 

1.Purposes of Collection and Processing of Personal Data

 

Your personal data mentioned above and your sensitive personal data will be processed for the following purposes.

 

1-Fulfillment of legal obligations and execution of all kinds of works within the scope of activity within the legal framework,

2-Fulfillment of the provisions of the contract,

3-Provision of Health Services (Medical diagnosis, examination, treatment and all kinds of care services)

4-Commercial activity and business management requirements,

5-Sectoral (health) requirements;

5.1. Carrying out medical diagnosis, treatment and care services,

5.2. Sharing the information requested by the Ministry of Health and all other relevant official institutions and organizations in accordance with health legislation,

5.3.Financing your health care services, covering the costs of examinations, diagnostics and treatment,

5.4. Informing patients about appointments,

5.5.Confirming the patient’s identity,

5.6.Measuring, increasing and researching patient satisfaction by hospital management, patient rights, patient experience departments,

5.7. Invoicing by patient services, financial affairs, marketing departments,

5.8. Being able to respond to all kinds of questions and complaints regarding our health services by the clinic management,

 

6. Technical requirements;

 

6.1. Planning and management of internal functioning by the clinic management,

6.2. Research and analysis conducted to improve service delivery quality, patient experience and quality of health services,

6.3. Providing training to employees by the clinic management,

6.4. Monitoring and prevention of unauthorized transactions by the clinic management,

6.5. Fulfillment of risk management and quality improvement activities,

6.6. Taking all necessary technical and administrative measures within the scope of data security by the clinical management,

6.7. Providing the necessary communications by the relevant personnel of the data controller in order to provide transportation, accommodation and hospitality services within the scope of health tourism when necessary,

6.8. Providing campaign participation and campaign information, designing and communicating special content, tangible and intangible benefits on web and other mobile channels and social media,

6.9. Fulfillment of training and activities by educational institutions with which the clinical management cooperates,

 

2.Legal Grounds for Collection and Processing of Personal Data

 

Your personal data mentioned above and your sensitive personal data will be processed under the following legal grounds.

 

-Basic Law No. 359 on Health Services,

-Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Organizations,

-Regulation on Private Health Institutions for Outpatient Diagnosis and Treatment

-Regulation on Processing and Protection of Privacy of Personal Health Data

-Law No. 6698 on the Protection of Personal Data,

-Law No. 1774 on Identity Notification,

-Labor Law No. 4857,

-Law No. 5510 on Social Security and General Health Insurance,

-Law No. 6331 on Occupational Health and Safety.

 

 

 

As stated in Article 6, paragraph 3 of the Law No. 6698 on the Protection of Personal Data, personal data relating to health and sexual life may only be processed by a person who has a confidentiality obligation and by authorized public institutions and organizations, for the purposes of protection of public health, execution of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services as well as their financing.

 

C. TRANSFER OF PERSONAL DATA

 

Your personal data may be shared within the framework of the following legal provisions and for the purposes described above;

 

-Basic Law No. 359 on Health Services,

-Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Organizations,

-Law No. 6698 on the Protection of Personal Data and all relevant sub-legislation,

-Regulation on Private Health Institutions for Outpatient Diagnosis and Treatment

-Regulation on Processing and Protection of Privacy of Personal Health Data

-Law No. 1774 on Identity Notification,

-Labor Law No. 4857,

-Law No. 5510 on Social Security and General Health Insurance,

– Property Ownership Law,

 

And may be shared with:

 

Ministry of Health, its sub-units and family medicine centers,

-Private insurance companies (health, pension, life insurance and similar),

-Social Security Institution,

-Ministry of Family, Labor and Social Policies,

-General Directorate of Security and other law enforcement agencies,

-General Directorate of Population and Citizenship Affairs,

-Other authorized official institutions and organizations,

-Turkish Pharmacists‘ Association,

-Judicial authorities, enforcement offices, mediators,

-Laboratories, medical centers, ambulances, medical devices and health service providers in Turkey or abroad with which we cooperate for medical diagnosis and treatment,

– The health institution to which the patient is referred or to which the patient himself/herself applies,

– Legal representatives, parents and guardians who have written authorization

– All real or legal third parties from whom consultancy services are received, including lawyers, accountants, financial advisors, tax consultants and auditors with whom we work within the scope of the contract,

-Regulatory and supervisory authorities and official authorities,

-Banks where the clinic, patients or our employees who are related to our company under any contract have accounts,

-Private pension companies with which we work within the scope of compulsory or voluntary BES (Private Pension System),

-Our suppliers, support service providers, archive service providers and business partners whose services we benefit from or cooperate with (for more detailed information, you can obtain information by applying to our hospital with a written application).

-Outsourcing service providers (limited to subject and purpose)

-Cargo or courier companies,

-Air, land or sea passenger transportation companies.

 

 

 

IV.OUR MEASURES and COMMITMENTS FOR THE PROTECTION OF PERSONAL DATA

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC, in its capacity as the data controller, protects your personal and sensitive personal data mentioned above in its own physical and electronic environments with great sensitivity and in full compliance with the provisions of the legislation, by taking all kinds of administrative and technical measures.

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC has taken all kinds of administrative and technical measures to protect your personal data.

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC is committed to protecting all personal data. In order to prevent unlawful processing and access to personal data and to ensure the protection of personal data, technical and administrative measures to ensure the appropriate level of security are carried out using various methods and security technologies.

 

 

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC will not disclose the personal data it obtains to anyone else in violation of the provisions of the Personal Data Protection Law No. 6698 and will not use it for purposes other than processing.

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC has prepared and ensured the signing of all notice or consent statements and undertakings for the cases where it is mandatory and necessary to share (transfer) personal data with outsourcing service providers and suppliers, consultants or lawyers, and has implemented the necessary multi-faceted audit activities.

 

V. PROCESSING OF PERSONAL DATA COLLECTED VIA COOKIES

 

Dr. TERZİLER EXCLUSIVE HAIR CLINIC does not position cookies on its website. During the use of our website and mobile application, IP address, browser information (Mac ID, IP address information, website login, logout and password information) are not received.

 

VI.YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

 

Pursuant to Article 11 of the Law on the Protection of Personal Data, you may exercise your rights regarding the processing and protection of your personal data, provided that you prove your identity by applying to Dr. TERZİLER EXCLUSIVE HAIR CLINIC as Data Controller in the following ways.

 

A.YOUR RIGHTS REGARDING YOUR PERSONAL DATA

 

1.To learn whether your personal data is being processed, 2.To request for information regarding this, if your personal data has been processed, 3.To learn the purpose of processing your personal data and whether it is used appropriately for its purpose,

4. To know the third parties at home or abroad to whom your personal data is transferred, 4.To request for correction of the personal data if it is incomplete or incorrectly processed,

6.To request the erasure or destruction of personal data,

7.In the event that your personal data has been transferred to third parties, if your personal data is incomplete or incorrectly processed, to request that they be corrected and that the deletion or destruction of personal data be notified and communicated to the relevant third party,

8.To object to any unfavorable result that they suffer due to analysis of processed data only by means of automatic systems,

9.To request for compensation in the event that you suffer damage due to unlawful processing of your personal data.

 

 

 

You may request Dr. TERZİLER EXCLUSIVE HAIR CLINIC to have your personal data destroyed (deletion, destruction, or anonymization) within the framework of the conditions stipulated in Article 7 of the Personal Data Protection Law. However, by evaluating your destruction request, our company will evaluate which method is appropriate according to the conditions of the concrete case. In this context, you can always request information from Dr. TERZİLER EXCLUSIVE HAIR CLINIC about why we have chosen the destruction method we have chosen.

 

Personal data collected about persons under 18 years of age is limited to their name, surname, age and degree of closeness, and this data can only be given to us by the relevant adult (parent or guardian).

 

SITUATIONS EXCLUDED FROM THE SCOPE OF THE RIGHT OF APPLICATION

 

Pursuant to Article 28 of the Law on the Protection of Personal Data, the following cases are excluded from the scope of the Law on the Protection of Personal Data and therefore, it will not be possible for personal data subjects to assert their application rights:

 

-Procession of the personal data for such purposes as research, planning, and statistics in a way that they are to be anonymized by means of official statistics.

 

-Procession of the personal data either for artistic, historical, literary, or scientific purposes, or within the scope of the freedom of speech, provided that national, defense, national security, public security, economical security, right of privacy, or personal rights are not to be violated.

 

-Procession of the personal data within the scope of the preemptive, protective, and informative activities being conducted by the public institutions and organizations respectively empowered by the Law to maintain national, defense, national security, public security, public order, or economical security.

 

-Procession of the personal data by the judicial or execution authorities in respect of investigation, prosecution, trial, or execution processes.

 

Pursuant to paragraph 2 of Article 28 of the Law on the Protection of Personal Data, except for the right to claim compensation for damages, it is not possible to assert rights in the following cases:

 

-Personal data procession is imperative either to prevent the perpetration of a crime, or to investigate a crime,

-Procession of personal data that have been publicized by the data subject him/herself,

-Processing of personal data is imperative for the auditing or regulating duties, as well as for disciplinary investigation or prosecution purposes to be carried out by the respectively commissioned and empowered public institutions and organizations, and by the professional organizations that serve as public organizations on the basis of the power respectively bestowed by the Law.

-Procession of personal data is imperative for the protection of the economic and financial interests of the State in respect of budget, tax, and financial affairs.

 

B.HOW TO CONTACT OUR COMPANY TO EXERCISE YOUR RIGHTS

 

You can exercise your rights under the Law on the Protection of Personal Data by;

 

1-Filling out the Application Form on the Protection of Personal Data to be provided by Servet Terziler Sağlık Hizmetleri A.Ş. at the address of Akat Mahallesi Ebulula Mardin Caddesi Park Maya Sitesi F-2B Blok No:20/1 Beşiktaş Istanbul and submitting it in person against signature,

2-Filling out the Application Form on the Protection of Personal Data and sending it via notary public,

3-Sending an e-mail to Dr. TERZİLER EXCLUSIVE HAIR CLINIC.

 

 

 

Depending on the nature of your request and your application method, Dr. TERZİLER EXCLUSIVE HAIR CLINIC may request additional verifications (such as sending a message to your registered phone, calling you) to determine whether the application belongs to you and thus protect your rights. For example, if you apply through your e-mail address registered with Dr. TERZİLER EXCLUSIVE HAIR CLINIC, we may contact you using another communication method registered with the Dr. TERZİLER EXCLUSIVE HAIR CLINIC and request confirmation of whether the application belongs to you.

 

Your requests in your application will be concluded free of charge, as a rule, within thirty days at the latest, depending on the nature of the request. However, if the transaction requires a separate cost for the Clinic, the fee not exceeding 100 (one hundred) TL in total may be requested as specified in the Communiqué on the Procedures and Principles of Application to the Data Controller published by the Personal Data Protection Authority in the Official Gazette dated 10.03.2018 and numbered 30356. In the event that it is understood that your application is resulted from Dr. TERZİLER EXCLUSIVE HAIR CLINIC error, the fee paid, if any, will be refunded to you.

 

In order to confirm that you are the right person in case of your application, Dr. TERZİLER EXCLUSIVE HAIR CLINICmanagement has the right to request some verifying information from you. Unless you cancel your application, you are deemed to have accepted these requests of Dr. TERZİLER EXCLUSIVE HAIR CLINIC management.

 

CONSENT and APPROVAL

 

When you read this Clarification Text, you are deemed to have accepted, declared and undertaken that you are fully and completely informed that Dr. TERZİLER EXCLUSIVE HAIR CLINIC performs a data processing process and that you have been informed about the processing of your personal data and that you consent to the processing of your personal data.

CONTACT DETAILS 

Servet Terziler Sağlık Hizmetleri A.Ş.

Akat Mahallesi Ebulula Mardin Caddesi Park Maya Sitesi F-2B Blok No:20/1 Beşiktaş İstanbul

 

Phone: 0(212)986 07 72

 

 

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