DR. GONUL ATEŞSAÇAN EXAMINATION

PERSONAL DATA

CONSERVATION AND PROCESSING POLICY

1.     LOGIN

Dr. GÖNÜL ATEŞSAÇAN Clinic (“ Dr. GÖNÜL ATEŞSAÇAN ”) attaches utmost importance to protecting the fundamental rights and freedoms of individuals, in particular the privacy of private life regulated in Article 20 of the Constitution, in the protection and processing of personal data. In this context, Dr. GÖNÜL ATEŞSAÇAN pays attention to the legal protection and processing of personal data in accordance with the Law on the Protection of Personal Data No. 6698 (“ KVKK ”) and the European Union General Data Protection Regulation (“ GDPR ”), and acts with this understanding in all its planning and activities.

Ensuring the security of personal data of individuals. It is one of the priority targets of GÖNÜL ATEŞSAÇAN . For this reason, in order to process the Personal Data of individuals securely and to prevent any unlawful access or leakage to this data, necessary security measures are taken by Dr. It is taken by GÖNÜL ATEŞSAÇAN.

1.1 PURPOSE OF THE POLICY

Personal Data Protection and Processing Policy (“ Policy ”) is to protect and process personal data, which is fully or partially automated or non-automatic, provided that it is part of any data recording system, in accordance with the purpose of KVKK and GDPR . To inform Personal Data Owners about GÖNÜL ATEŞSAÇAN's obligations and the procedures and principles it will comply with. For the purpose of the Policy , Dr. It is aimed to ensure full compliance with the legislation in the protection and processing of personal data carried out by GÖNÜL ATEŞSAÇAN and to protect the right of privacy and data security of Personal Data Owners.

1.2 SCOPE OF THE POLICY

This Policy; It has been prepared for Customers, Employees, Employee Candidates and Visitors provided that they are natural persons and will be implemented within the scope of these specified persons. Dr. The purpose of publishing this Policy on the website by GÖNÜL ATEŞSAÇAN is to inform the Data Owners about the protection and processing of personal data and data security. This Policy will not apply to legal entities in any capacity.

This Policy applies to the above-mentioned Data Owners, who collect their personal data in whole or in part by automated means or by non-automatic means provided that they are part of any data recording system. It will be applied if it is processed by GÖNÜL ATESSAÇAN. If the data is not included in the scope of "Personal Data" in the scope specified below, or Dr. This Policy will not be applied if the personal data processing activity carried out by GÖNÜL ATEŞSAÇAN is not carried out in the above-mentioned ways.

1.3 DEFINITIONS

this Policy have the following meanings:

Open Consent

It is the consent of a particular subject, based on information and expressed with free will.

Lighting Obligation

It is the obligation of the data controller to inform the persons whose personal data they are processing about, by whom, for what purposes and on what legal grounds, and to whom it can be transferred, for what purposes.

Related User

Except for the person or unit responsible for technical storage, protection and backup of the data, they are the persons who process personal data within the organization of the data controller or in line with the authorization and instruction received from the data controller.

Destruction

It refers to the deletion, destruction or anonymization of personal data.

Processing of Personal Data

Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using Personal Data in whole or in part by automatic or non-automatic means provided that it is a part of any data recording system. It is any operation performed on the data, such as blocking.

KVK Board

It is the Personal Data Protection Board.

Personal Data Owner

Refers to Patients, Clients, Employees, Employee Candidates and Visitors whose Personal Data (including sensitive personal data) is processed.

Personal Data

Any information relating to an identified or identifiable natural person.

Institution/ Control Mechanism

It is the Personal Data Protection Authority consisting of the Board and the Presidency.

Automatic Data Processing

Computer, phone, clock etc. It is a processing activity that takes place spontaneously without human intervention within the scope of algorithms prepared in advance through software or hardware features, performed by devices with processors.

Special Qualified Personal Data

Data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data are special data.

Record

Data Controllers Registry .

Dr.GÖNÜL ATEŞSAÇAN

Dr. Heart Firescatter It's the clinic .

Data Processor

It is the natural or legal person who processes Personal Data on behalf of the data controller, based on the authority given by the data controller.

Data Recording System

It refers to the recording system in which Personal Data is processed and structured according to certain criteria.

Data Category

It is the personal data class belonging to the data subject group or groups in which personal data are grouped according to their common characteristics.

Data Subject Group

It is the group of persons whose personal data the data controller processes.

Data Controller

It is the natural or legal person who determines the purposes and means of processing Personal Data and is responsible for the establishment and management of the data recording system.

 

1.4 ENFORCEMENT OF THE POLICY

Dr. Policy principles, which were arranged by GÖNÜL ATEŞSAÇAN and entered into force on 01.04.2021, were prepared by Dr. It is published on the corporate websites of GÖNÜL ATEŞSAÇAN and made available to the Data Owners.

2.     PROTECTION OF PERSONAL DATA

2.1     SECURITY OF PERSONAL DATA

Dr. GÖNÜL ATEŞSAÇAN takes all necessary administrative and technical measures to ensure the appropriate level of security in order to securely store personal data and prevent unlawful processing and access of personal data in accordance with KVKK and GDPR. Administrative and technical measures taken regarding the security of personal data, Dr. It is regulated in detail in the Personal Data Retention and Disposal Policy of GÖNÜL ATEŞSAÇAN .

2.2     AUDIT

Dr. GÖNÜL ATEŞSAÇAN performs the necessary audits and has them done in order to establish the data security described above and to ensure the regularity and continuity of the measures taken.

Dr. The technical measures taken by GÖNÜL ATEŞSAÇAN are supervised by authorized persons in semi-annual periods, and the administrative measures are carried out by Dr. It is supervised by people authorized by GÖNÜL ATEŞSAÇAN .

2.3     SECURITY

Data Processor not to disclose the personal data he has learned within the scope of his duty, contrary to the provisions of KVKK, GDPR and Policy, and not to use it for purposes other than processing. All necessary administrative and technical measures are taken by GÖNÜL ATEŞSAÇAN. In this context, information and training activities are carried out for workplace employees about KVKK, GDPR and the Policy, and confidentiality agreements are signed as part of the recruitment processes of the relevant employees. Confidentiality Commitments are received by communicating the policies to Suppliers and Data Processors who also provide outsourced services.

2.4     UNAUTHORIZED DISCLOSURE OF PERSONAL DATA

Dr. In case the personal data processed by GÖNÜL ATEŞSAÇAN is obtained by others illegally, Dr. GÖNÜL ATEŞSAÇAN carries out the necessary procedures to notify the Data Owner and the KVK Board of this situation within the periods determined by the KVK Board. If deemed necessary by the KVK Board, this situation is announced on the website of the KVK Board or by another method deemed appropriate by the KVK Board.

2.5     PROTECTING THE LEGAL RIGHTS OF RELATED PERSONS

Dr. GÖNÜL ATEŞSAÇAN observes all legal rights of the persons concerned regarding the implementation of the Policy and the Law and takes all necessary measures to protect these rights.

2.6     PROTECTION OF PRIVATE PERSONAL DATA

Data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are of special nature. is personal data. Dr. GÖNÜL ATEŞSAÇAN is aware of the fact that Special Quality Personal Data is data that may cause the Data Owner to be victimized or exposed to discrimination if learned by others, and therefore takes adequate measures determined by the Board sensitively for the protection of such personal data processed in accordance with the law. In this context; It has a separate policy (Private Personal Data Security Policy) that is systematic, clearly defined, manageable and sustainable.

3.     PROCESSING AND TRANSFERRING PERSONAL DATA

3.1     GENERAL PRINCIPLES ON PROCESSING AND TRANSFERRING PERSONAL DATA

Dr. Personal Data is processed by GÖNÜL ATEŞSAÇAN in accordance with the KVKK, GDPR and the procedures and principles stipulated in this Policy. Dr. GÖNÜL ATEŞSAÇAN complies with the following principles when processing personal data.

a)    Compliance with the Law, Integrity Rules and the Principle of Transparency

Dr. GÖNÜL ATEŞSAÇAN processes personal data in accordance with the relevant legislation and the requirements of the honesty rule and uses them within these limits. In accordance with the principle of compliance with the rule of honesty, Dr. GÖNÜL ATEŞSAÇAN considers the interests and reasonable expectations of the persons concerned while trying to achieve its goals in data processing. It acts in a way to prevent the occurrence of results that the Data Owner does not expect and does not have to wait for. In accordance with the principle, it also ensures that the data processing activity in question is transparent to the data subject; acts in accordance with its lighting and warning obligations.

b)    Being Accurate and Up-to-Date When Necessary

Dr. GÖNÜL ATEŞSAÇAN ensures that the personal data it processes are accurate and up-to-date, taking into account the fundamental rights and legitimate interests of Data Owners. In this context, it carefully considers issues such as the sources from which the data is obtained, the confirmation of its accuracy, and the evaluation of whether it needs to be updated. Dr. GÖNÜL ATEŞSAÇAN always keeps channels open to ensure that the personal data owner's information is correct and up-to-date. Keeping personal data accurate and up-to-date, Dr. It is necessary to protect the fundamental rights and freedoms of the Data Owner as well as protecting the interests of GÖNÜL ATEŞSAÇAN .

c)    Processing for Specific, Explicit and Legitimate Purposes

Dr. GÖNÜL ATEŞSAÇAN clearly and precisely determines the purpose of data processing and ensures that this purpose complies with the law. For the purpose to be lawful, Dr. It means that the personal data processed by GÖNÜL ATEŞSAÇAN is related to and necessary for the health service in which it operates. Dr. GÖNÜL ATEŞSAÇAN does not process data for purposes other than those stated. In this respect, it shows sensitivity in compliance with the principle of certainty and clarity in legal transactions and texts in which the purposes of personal data processing are explained.

d)    Relevant, Limited, Moderate and Necessary for the Purpose for which they are Processed

Dr. GÖNÜL ATEŞSAÇAN pays attention to the fact that the processed personal data is suitable for the realization of the determined purposes and avoids the processing of data that are not related to the realization of the purpose or that are not needed. Dr. GÖNÜL ATEŞSAÇAN does not collect or process personal data for purposes that do not exist and are thought to be realized later. It also limits the processed data only to what is necessary for the realization of the purpose. Within the scope of the principle of proportionality, it establishes a reasonable balance between data processing and the intended purpose.

e)    Retention for as long as required by the relevant legislation or for the purpose for which they are processed.

Dr. GÖNÜL ATEŞSAÇAN complies with these periods if there is a period stipulated in the relevant legislation for data storage; otherwise, it retains personal data only for as long as is necessary for the purpose for which it was processed. Dr. In the event that there is no valid reason for further storage of personal data by GÖNÜL ATEŞSAÇAN, the said data is deleted, destroyed or anonymized. Procedures for storage and destruction of personal data. It is regulated in detail in GÖNÜL ATEŞSAÇAN's Personal Data Retention and Disposal Policy .

f)     Compliance with Integrity and Confidentiality Principles

Dr. Personal data is processed by GÖNÜL ATEŞSAÇAN by taking the necessary technical and administrative measures in order to ensure adequate security against loss, destruction, damage or protection of personal data.

g)    Compliance with the Principle of Accountability

Dr. GÖNÜL ATEŞSAÇAN has fulfilled its obligation in accordance with the rules of protection of personal data in its processing activities, and in case of any complaint or ex officio examination, it will be able to submit documents proving that these measures have been taken.

3.2     PERSONAL DATA PROCESSING CONDITIONS

Dr. GÖNÜL ATEŞSAÇAN does not process personal data without the explicit consent of the Data Owner . Personal data can only be processed without seeking the explicit consent of the Data Owner in the presence of one of the following conditions :

a)    Explicitly Provided in Laws

Dr. GÖNÜL ATEŞSAÇAN may process personal data without seeking the explicit consent of the Data Owner in cases expressly stipulated by the laws.

b)    Obligation of a Person Who Is Incapable of Expressing His Consent Due to Actual Impossibility or For whose Consent is Not Legally Validated for the Protection of Himself or Another Person's Life or Bodily Integrity

Dr. GÖNÜL ATEŞSAÇAN may process personal data without seeking explicit consent in order to protect the life or physical integrity of individuals in cases where consent cannot be disclosed or is not valid.

c)    Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract

Dr. GÖNÜL ATEŞSAÇAN may process the personal data of the Data Owner , limited to this purpose, as a requirement of the ordinary course of life, without seeking explicit consent, in case the personal data of the parties to the contract is required to be processed directly related to the establishment or performance of a contract.

d)    Dr. GÖNÜL ATEŞSAÇAN 's Obligation to Fulfill His Legal Obligation

Dr. GÖNÜL ATEŞSAÇAN may process the personal data of the Data Owner without seeking explicit consent when necessary in order to fulfill its legal obligations as a Data Controller.

e)    Relevant Person Made Public by Himself

Dr. GONUL ATEŞSAÇAN; It may process the personal data made public by the Data Owner himself, in other words, disclosed to the public in any way, for a limited purpose, since it is accepted that the legal benefit to be protected in the processing of such data, which has been made public by the Data Owner and thus becomes known to everyone, has disappeared.

f)     Requirement of Data Processing for the Establishment, Use or Protection of a Right

Dr. GÖNÜL ATEŞSAÇAN may process the personal data of the Data Owner without seeking explicit consent in cases where data processing is necessary for the exercise or protection of a legally legitimate right .

g)    Provided that it does not harm the Fundamental Rights and Freedoms of the Related Persons, Data Processing is Mandatory by our Company for its Legitimate Interests

Dr. GÖNÜL ATEŞSAÇAN may process the personal data of the Data Owner in cases where it is necessary to process the personal data in order to ensure its legitimate interests, provided that it does not harm the fundamental rights and freedoms of the Data Owner protected under the KVKK, GDPR and the Policy . Dr. GÖNÜL ATEŞSAÇAN, to comply with the basic principles regarding the protection of personal data and to Dr. GÖNÜL ATEŞSAÇAN and personal data owners show the necessary sensitivity to observe the balance of interests. What is meant by legitimate interest; It is a legitimate, effective, specific and already existing interest that can compete with the fundamental rights and freedoms of the Data Owner . Dr. GÖNÜL ATEŞSAÇAN takes additional protective measures in order not to harm the rights of the Data Owner . A reasonable balance is maintained between the interests of our company and the fundamental rights and freedoms of the person concerned.

3.3     PROCESSING CONDITIONS OF SPECIAL QUALITY PERSONAL DATA

Dr. GÖNÜL ATEŞSAÇAN does not process sensitive personal data without the explicit consent of the Data Owner . Special categories of personal data can only be processed without seeking the explicit consent of the data subject in the presence of one of the following conditions:

·         Explicitly Provided in Laws

Private personal data of the Data Owner, other than his health and sexual life, may be processed without the explicit consent of the Data Owner, in cases expressly stipulated by the laws .

·         For the Protection of Public Health, Preventive Medicine, Medical Diagnosis, Execution of Treatment and Care Services, Planning and Management of Health Services and Financing

Persons or authorized institutions and organizations that are under the obligation to keep confidential personal data of the Data Owner regarding his health and sexual life for the purpose of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing. can be processed by

3.4     TERMS OF TRANSFER OF PERSONAL DATA

Dr. GÖNÜL ATEŞSAÇAN can transfer personal data to third parties based on one or more of the following personal data processing conditions, in accordance with Articles 8 and 9 of the KVKK and Articles 45 and 49 of the GDPR , by taking the necessary security measures :

·         Having the explicit consent of the Data Owner ,

·         There is a clear regulation in the law regarding the transfer of personal data,

·         Data Owner or someone else, and the data subject is unable to express his or her consent due to actual impossibility or the consent is not legally valid,

·         It is necessary to transfer the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

·         Dr. Personal data transfer is mandatory for GÖNÜL ATEŞSAÇAN to fulfill its legal obligation,

·         The personal data has been made public by the Data Owner,

·         It is necessary to transfer personal data for the establishment, exercise or protection of a right,

·         Provided that it does not harm the fundamental rights and freedoms of the Data Owner , Dr. Personal data transfer is mandatory for the legitimate interests of GÖNÜL ATEŞSAÇAN .

Special categories of personal data, on the other hand, can be transferred based on one of the following conditions and on a limited basis, provided that adequate measures are taken:

·         Having the express consent of the person concerned,

·         If there are sensitive personal data other than the health and sexual life of the person concerned, there is a clear regulation in the law regarding the transfer of this data.

·         In the case of sensitive personal data regarding the health and sexual life of the person concerned, these data are used by persons or authorized institutions under the obligation to keep confidential, for the purpose of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing. transferable by organizations.

 

4.     PERSONAL DATA CATEGORIES AND GROUPS OF DATA SUBJECTS

4.1     Personal Data Categories

Personal data It is processed by GÖNÜL ATESSAÇAN by categorizing it as follows :

 

Identity

Name-Surname , TR Identity Number and/or Passport Number and/or Temporary TR Identity Number, place and date of birth, marital status, gender, profession , signature and other identification data that can identify real persons

Communication

Address ( residence , workplace), phone number (reported home/workplace fixed and/or mobile phone numbers), e-mail address, social media accounts, IP address and other contact data

 

Personnel

Curriculum vitae, title information; employment entry-exit document records; social security/retirement information, payroll information and other personal data

Physical Space Security

Security camera footage and other physical location security data

finance

Dr. Personal data, bank account information, credit card information, and other financial information processed regarding information, documents and records showing the result of any financial relationship that GÖNÜL ATEŞSAÇAN has established with personal data owners

Audio and Audio Recordings

of photographs, cameras and audio recordings taken outside the scope of physical space security of personal data owners

Communication Records

Dr. Communication data obtained through GÖNÜL ATEŞSAÇAN's communication and information systems: Corporate phone call records, corporate mail and e-mail records and their contents, etc.

Customer Transaction

Satisfaction information about the patients of our practice, Invoice, receipt information, etc.

PRIVATE PERSONAL DATA

Health Information

Blood type, allergies, chronic diseases, data on previous applications/operations, drugs used continuously, analysis and imaging results, prescription information, body analysis and measurement information, medical history, skin analysis information, hormonal tests, venereal disease information , Information on Covid-19 disease, medical treatments and other health data

Biometric Data

Image, audio, video data

 

4.2     Data Subject Groups

Only natural persons can benefit from the protection of this Policy and the Law. Personal data owners within this scope are grouped as follows:

Employee Candidate

They are real persons who have applied for a job in our practice by any means or have opened their CV and related information to our practice.

Customer

Patients or clients who come to our practice.

Worker

 

Dr. GÖNÜL ATEŞSAÇAN They are the individuals working in his practice.

Visitor

They are all natural persons who enter the physical campus of our practice for various purposes or visit our websites for any purpose.

 

5.     METHOD OF COLLECTING PERSONAL DATA AND LEGAL REASON

5.1     METHOD OF COLLECTING PERSONAL DATA

Your Personal Data, Dr. As a " DATA PROCESSOR " by natural or legal persons authorized by GÖNÜL ATEŞSAÇAN ; It is processed by taking verbal, written, camera and photographic recordings and keeping records in physical and electronic media, and by obtaining your explicit consent in cases stipulated by KVKK and GDPR .

·         job application forms,

·         Personnel information forms,

·         Dr. Various documents submitted to GÖNÜL ATEŞSAÇAN ,

·         Dr. Mail and e-mails forwarded to GÖNÜL ATEŞSAÇAN ,

·         corporate phones,

·         Photo/Video recordings,

·         Websites,

·         Security cameras,

·         Log Recorders (Firewall),

·         Patient Disclosure Forms,

·         Assay Results,

·         Health Information Forms, Service providers whose servers are abroad (whatsapp/instagram/facebook/messanger/linkedin/youtube/zoomus/Google/Hotmail/yahoo etc.).

5.2     LEGAL REASON FOR COLLECTING PERSONAL DATA

Dr. GÖNÜL ATESSAÇAN collects personal data based on one of the following legal reasons in accordance with Articles 5 and 6 of the Law and Articles 6 and 9 of the GDPR:

·         The express consent of the person concerned,

·         expressly provided for in laws;

·         The personal data has been made public by the person concerned,

·         Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract,

·         Data Owner has sensitive personal data regarding his health and sexual life, these data are for the purpose of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing,

·         Dr. It is mandatory for GÖNÜL ATEŞSAÇAN to fulfill its legal obligation,

·         Data processing is mandatory for the establishment, exercise or protection of a right,

·         Provided that it does not harm the fundamental rights and freedoms of the persons concerned, Dr. Data processing is mandatory for GÖNÜL ATESSAÇAN's legitimate interests.

 

6.     PURPOSE OF PROCESSING PERSONAL DATA

Matching the Data Subject Groups with the Purposes of Processing for Personal Data Categories

The mapping of the data subject groups, the definitions and scopes of which are given above , with the processing purposes related to the personal data categories is presented below:

·         Employee Candidate

Data Categories : Identity, Communication, Personnel, Professional Experience, Physical Space Security

Purposes of Processing : Execution of Emergency Management Processes, Execution of Information Security Processes, Execution of Employee Candidate Selection and Placement Processes, Execution of Application Processes of Employee Candidates, Ensuring Physical Space Security, Execution of Communication Activities

·         Patient/Client

Data Categories : Identity, Communication, Financial, Customer Transaction, Physical Space Security, Health Data, Biometric Data

Purposes of Processing : To be able to create a patient file, to apply examination, preventive medicine, medical diagnosis, treatment, weight loss protocols accompanied by medical evaluation, to carry out post-treatment care services , to perform health checks after medical diagnosis and treatment processes, to communicate with patients one-to-one, to manage the development of medical protocols, To be able to manage appointment processes, to perform patient satisfaction and demand management, to fulfill legal and contractual obligations, to keep the information about your health data, which must be kept in accordance with the relevant legislation, within the specified periods, to ensure the safety of the practice, to receive consultation from another relevant specialist when necessary in order to perform the treatments correctly. To be able to fulfill legal obligations in accordance with the legislation within the scope of health tourism, to provide transfer and accommodation services for patients/clients coming within the scope of health tourism. To plan medical procedures, to announce innovations regarding medical treatments and practices, to inform third parties about medical procedures, to carry out promotional and marketing activities regarding medical practices applied within the framework of the International Health Tourism Incentive legislation, to plan and manage health services and their financing , to communicate between the doctor and the patient. To be able to fulfill the responsibilities arising from the legal relationship established, to fulfill the financial and administrative obligations, to provide technical and commercial security and to fulfill public obligations.

·         Worker

Data Categories : Identity, Communication, Personnel, Finance, Visual and Audio Information, Physical Space Security,

Purposes of Processing : Execution of Emergency Management Processes, Execution of Information Security Processes, Fulfillment of Obligations Originated from Labor Contracts and Legislation for Employees, Execution of Benefits and Benefits Processes for Employees, Execution of Activities in Compliance with Legislation, Ensuring Physical Space Security, Execution / Audit of Business Activities, Organization and Event Management

·         Visitor

Data Categories : Physical Space Security

Processing Purposes : Execution of Emergency Management Processes, Execution of Information Security Processes, Providing Physical Space Security

6.2 Personal Data Processing Activities Performed in Physical Spaces

In order to ensure the security of our practice, entrances and exits are recorded and video surveillance is performed in common areas. In order to be able to monitor with the camera, the Data Owners, Dr. It was enlightened by GÖNÜL ATEŞSAÇAN.

6.3     Personal Data Processing Activities on the Website

 

Traffic information of online visitors visiting our website is automatically processed for the purpose of conducting information security processes. On the other hand, hosting providers have an obligation to record and store website traffic information pursuant to Law No. 5651 and other legislation.

6.4 Personal Data Processing Activities Performed Through Communication Channels

 

Phone, e-mail etc. communications via channels. It is audited and recorded by GÖNÜL ATEŞSAÇAN for the purpose of conducting/supervising business activities and following up requests/complaints.

Data Owners are required to use these channels only within the scope of their business activities.

7.     PURPOSE OF TRANSFERRING PERSONAL DATA AND THE PERSONS/INSTITUTIONS TO WHICH THE PERSONAL DATA IS TRANSFERRED

7.1     Purposes of Transfer of Personal Data

Dr. GÖNÜL ATEŞSAÇAN transfers personal data limited to the following purposes within the framework of the conditions specified in Articles 8 and 9 of the KVKK and Articles 45 and 49 of the GDPR:

·         Execution of weight loss protocols and care services accompanied by examination, preventive medicine, medical diagnosis, treatment, medical evaluation ,

·         Managing complication processes,

·         Monitoring and Execution of the Development of Treatment Protocols,

·         Getting consultation,

·         Fulfillment of obligations pursuant to Ministry of Health Legislation,

·         Fulfillment of obligations in accordance with International Health Tourism Legislation,

·         Meeting the transportation, accommodation and interpreter needs of health tourist patients,

·         Fulfillment of administrative obligations before Provincial Health Directorates and District Health Directorates,

·         Informing third parties about the health services provided, from a medical point of view,

·         Execution of Employee Candidate Selection and Placement Processes,

·         Execution of Application Processes of Employee Candidates,

·         Fulfilling Obligations Arising from Employment Contracts and Legislation for Employees,

·         Execution of Benefits and Benefits Processes for Employees,

·         Carrying out the Activities in Compliance with the Legislation,

·         Execution of Finance and Accounting Affairs,

·         Execution / Supervision of Business Activities,

·         Conducting Business Continuity Ensuring Activities,

·         Execution of Risk Management Processes,

·         Ensuring and controlling data security,

·         Execution of Contract Processes,

·         Providing Information to Authorized Persons, Institutions and Organizations.

 

7.2     Persons/Organizations to which Personal Data is Transferred

Dr. GÖNÜL ATEŞSAÇAN can transfer personal data to the following individuals and organizations by applying all kinds of administrative and technical security measures stipulated by the legislation, limited to the data subject groups and data required by the purpose of transfer:

·         To other specialist physicians for consultation,

·         To Insured Employees,

·         to its suppliers,

Ø  Financial Advisor, Tax and Financial Advisors and Auditors

Ø  Legal Advisor

Ø  Database (Server) Providers

Ø  “Clinical Management Software System” Service Provider

Ø  interpreters

Ø  Overseas Promotion Consultant

Ø  Data Protection Officer

Ø  IT Consultant

Ø  Tourism Agencies

·         Public Institutions and Organizations authorized within the framework of laws,

·         To the Judiciary.

8.     DISPOSAL AND STORAGE PERIOD OF PERSONAL DATA

8.1     Destruction of Personal Data

·         Without prejudice to the provisions regarding the destruction of personal data in other laws, Dr. GÖNÜL ATEŞSAÇAN, in accordance with the Personal Data Retention and Disposal Policy , in case the reasons for processing the personal data that it has processed in accordance with the provisions of the KVKK and other laws no longer exist. delete, destroy or anonymize ex officio or at the request of the person concerned.

·         Deletion of personal data refers to the process of making personal data inaccessible and non-reusable for the relevant users.

·         destruction of data; means the process of making personal data inaccessible, irretrievable and reusable by anyone in any way.

·         Anonymization of data, masking of personal data, variable extraction, generalization, etc. means the process of making it impossible to be associated with an identified or identifiable natural person under any circumstances, even if it is matched with other data using techniques.

8.2     Retention Periods of Personal Data

Dr. GÖNÜL ATEŞSAÇAN stores personal data in accordance with the periods stipulated in the laws and other legislation. If there is no storage period stipulated in laws and other legislation, personal data, Dr. In accordance with GÖNÜL ATEŞSAÇAN's Personal Data Retention and Disposal Policy , that personal data is kept for the period required for the purpose of processing , then it is deleted, destroyed or anonymized within the framework of periodic destruction periods.

9.     RIGHTS OF PERSONAL DATA OWNER ACCORDING TO KVKK AND GDPR

9.1     DATA SUBJECT'S RIGHTS ACCORDING TO GDPR

As the Data Owner, your Personal Data is also protected in accordance with the GDPR. The rights of Data Subjects (European citizens or residents of Europe) in the jurisdiction of GDPR are as follows;

·         Right of Access (GDPR article 15): The data subject, Dr. Confirmation by applying to GÖNÜL ATESSAÇAN , GDPR m. It has the right to learn the details in 15 .

·         Right of Rectification (GDPR article 16): Data Owner, Dr. GÖNÜL ATEŞSAÇAN has the right to have the personal data in its possession corrected at any time by applying to us.

·         Right to Erase (GDPR article 17): Data Owner, Dr. GÖNÜL ATEŞSAÇAN has the right to request the deletion of the personal data held under his responsibility. If the matters set out in article 17 of GDPR occur, Dr. Your personal data will be deleted by GÖNÜL ATEŞSAÇAN without delay.

·         Right to Restriction of Processing (Article 18 GDPR):

Ø  If the Data Owner objects to the up-to-dateness of the Personal Data, Dr. Until the accuracy of the Personal Data is confirmed by GÖNÜL ATEŞSAÇAN, the Data Owner has the right to request the restriction of the use of the data.

Ø  If the Personal Data processing is illegal and the Data Owner objects to the deletion of the Personal Data, the Data Owner has the right to request the restriction of the use of the data.

Ø  Dr. Although we no longer need your personal data by GÖNÜL ATEŞSAÇAN, if we want to establish and enforce your rights, the Data Owner has the right to request the restriction of the use of the data.

Ø  Dr. Until it is verified whether GÖNÜL ATEŞSAÇAN's legitimate reasons outweigh the Data Owner 's legitimate reasons, the Data Owner has the right to request the restriction of the use of the data, if he or she objects to the processing in accordance with Article 21/1 of GDPR.

·         Right to Data Portion (GDPR article 20): Data Owner, if technically possible, Dr. GONUL ATEŞSAÇAN reserves the right to request the transfer of the Personal Data held in its custody to another controller at any time by applying to us. However, you can exercise this right when data processing is based on your consent or when required by the contract.

·         Right of Appeal (GDPR article 21):

Ø  The Data Owner has the right to object to the processing of Personal Data, including profiling, within the scope of clauses (e) or (f) of Article 6(1) GDPR, on grounds relating to his particular situation. Dr. GÖNÜL ATEŞSAÇAN cannot process your Personal Data if it cannot show a strong legitimate reason such as the establishment, exercise or protection of a legal right, which is above the interests, rights and freedoms of the Data Owner.

Ø  Where Personal Data is processed for direct marketing purposes, the Data Owner has the right to object at any time to the processing of Personal Data for marketing, including profiling to the extent that it relates to such direct marketing.

Ø  If the Data Owner objects to the processing of Personal Data for direct marketing purposes, the Personal Data will no longer be processed for such purposes.

9.2     RIGHTS OF THE DATA OWNER ACCORDING TO KVKK

of natural persons whose Personal Data are processed pursuant to Article 11 of the KVKK are as follows;

·         Learning whether personal data is processed or not,

·         If personal data has been processed, requesting information about it,

·         Learning the purpose of processing personal data and whether they are used in accordance with its purpose,

·         Knowing the third parties to whom personal data is transferred at home or abroad,

·         Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

·         Requesting the deletion or destruction of personal data in the event that the reasons requiring its processing have disappeared, although it has been processed in accordance with the provisions of the KVKK and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

·         Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

·         To request the compensation of the damage in case of loss due to unlawful processing of personal data.

In case the data owners have any rights or requests that they want to use from the rights listed above; Their written application, in which they clearly and comprehensibly stated which of the rights specified in Article 11 of the KVKK , they would like to use, with wet signatures and documents to prove their identity, were submitted to Dr. GÖNÜL ATEŞSAÇAN MUAYENEHANESİ in person, send it via a notary public or by signing with a secure e-signature to Dr. GÖNÜL ATEŞSAÇAN 's corporate e-mail address is gonul@gonulatessacan.com They can be forwarded to the address or they can be sent by other methods specified in the KVKK . In the applications, it is obligatory to include the name- surname , signature, TR identity number / passport number / temporary identity number , residence or workplace address, e-mail address, telephone and fax number, the subject of the request, in accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller" . .

Dr. GÖNÜL ATEŞSAÇAN will conclude the request free of charge as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be charged.

EFFECTIVE DATE : 01.04.2021

UPDATE DATE : 01.04.2021