DR.
GONUL ATEŞSAÇAN EXAMINATION
EXPLANATION
TEXT ON THE PROCESSING OF PERSONAL DATA
This clarification text is based
on the Law on the Protection of Personal Data No. 6698 in Turkish Law ( “KVKK”
). and in accordance with the General Data Protection Regulation of the European Union ( “GDPR”
) , DR. To GÖNÜL ATEŞSAÇAN EXAMINATION (“DR. GÖNÜL ATEŞSAÇAN”) has
been prepared for the purpose of enlightening the data owners about the
procedures and principles regarding the processing of Personal Data of
patients/clients.
Ensuring
the security of the Personal Data of patients/clients DR. It is one of the
priority targets of GÖNÜL ATEŞSAÇAN . For this reason, in order to process the
Personal Data of patients/clients 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.
DATA
SPEAKER
Your Personal Data, within the
scope of KVKK No. 6698, " Operator Cemil Topuzlu Cad. 18 March St. Cengic Apt. No:1/1
Kat:9 D:11 Caddebostan-Kadıköy/Istanbul/Turkey ” Dr.
It will be processed by GÖNÜL ATEŞSAÇAN EXAMINATION. GÖNÜL ATEŞSAÇAN, registered
with Göztepe VD, 37714609120 Tax Identity Number , is “DATA SPEAKER ” under KVKK and
“DATA CONTROLLER” under GDPR. is
accepted as
DR.
GÖNÜL ATEŞSAÇAN has agreed with a Law Firm with Personal Data Protection
Expertise as a "Data Protection Officer" within the scope of GDPR,
and DR. Within the body of GÖNÜL ATEŞSAÇAN MUAYENEHANESİ, the Compliance
Process on the Protection of Personal Data within the scope of KVKK and GDPR
was carried out under the consultancy and guidance of the Expert Law Firm,
provided that the implementation responsibility belongs to the Data Supervisor.
YOUR
PERSONAL DATA TO BE PROCESSED
Your
Personal Data and Sensitive Personal Data stated below, in accordance with the
basic principles set forth in KVKK art. and within the scope of the purposes
contained in this Clarification Text; DR. It will be processed by GÖNÜL
ATEŞSAÇAN.
1-
IDENTITY YOUR INFORMATION : Your
name, surname, TR Identity Number and/or Passport Number and/or Temporary TR
Identity Number, identity information, passport information, place and date of
birth, marital status, gender, profession, signature and other identification
data that can identify you.
2-
YOUR CONTACT INFORMATION : Your address ( residence /workplace), your phone
number (your home/workplace fixed and/or mobile phone numbers), e-mail address,
IP address, social media accounts and other communication data.
3-
YOUR HEALTH INFORMATION: Your blood type, laboratory and imaging results,
tests, allergies, chronic diseases, venereal diseases, infectious diseases,
data on previous surgeries/operations, medications you constantly use,
information on Covid-19 disease, medical
your treatments, prescription
information, medical history, body analysis and measurement information, skin
analysis information, hormonal tests, eating habits, harmful habits and other
health data necessary for the treatment and applications to be applied to you.
4-
YOUR PHOTO/VIDEO IMAGES AND AUDIO DATA: Medical Your image and audio recording data,
including photographs and/or videos recorded before, during and/or after
the medical procedure, and your data recorded by security cameras, which are
under closed circuit recording to ensure workplace safety.
5-
YOUR FINANCIAL INFORMATION: Your
bank account number, IBAN number, credit card information, billing and billing
information and other financial data.
6- YOUR TRANSFER AND
ACCOMMODATION INFORMATION: If you are a Health Tourist coming within the scope of
International Health Tourism, your transfer information, flight ticket and
return information, hotel accommodation information.
PERSONAL
DATA IS PROCESSED
Your Personal Data; to create a patient file, to provide examination,
preventive medicine, medical
diagnosis, treatment, medical applications, weight loss services accompanied by
medical evaluation, to carry out your post-treatment care services , to perform
your controls after the medical diagnosis and
treatment processes, to manage the complications that may occur, to communicate
with you personally, Observing the treatment protocol, managing the appointment
processes, performing patient satisfaction and demand management, fulfilling legal and contractual
obligations, keeping the information about your health data that must be kept
in accordance with the relevant legislation, within the specified periods,
receiving consultation services from other relevant specialist physicians when necessary
in order to carry out your treatment correctly. To be able to fulfill legal
obligations in accordance with the legislation within the scope of
International Health Tourism, / to be able to plan the transfer, accommodation,
interpreter services of the clients, to announce
the innovations in medical treatment and practices, to inform third parties
about the medical services offered, to plan and manage the health services
and financing, to ensure workplace safety ,
In accordance with KVKK and GDPR , DR. It is processed by GÖNÜL ATEŞSAÇAN.
Your
Personal Data, in the following terms and conditions, DR.
It will be processed by GÖNÜL ATEŞSAÇAN within the scope of KVKK and GDPR:
·
Your Identity Data; It will be
processed in order to carry out examination, medical diagnosis,
treatment and care services , to create a patient file, to perform patient satisfaction and demand management , to
plan the
transfer, accommodation and interpreter services of Health Tourist
patients/clients coming within the scope of Health Tourism .
·
Your Contact Information; It will be processed for the purpose of performing
your checks after the medical diagnosis and treatment processes, managing the
appointment processes, and can also be processed for the purpose of promoting,
informing and announcing the innovations regarding medical treatment and
practices, and congratulating and celebrating on special days, provided that
you give your explicit consent.
·
Your Health Information; To be able to successfully carry out your medical
treatments, medical aesthetic applications and the treatment method that will
be created to lose your excess weight, to receive consultation from another
specialist if necessary during
your treatment process, to create a patient file, to keep the information on
your health data that must be kept in accordance with the relevant legislation,
It will be processed in order to fulfill the legal obligations
within the scope of Health Law and Health Tourism Legislation .
·
Your Photo, Video and Audio
Recording Information; DR. It will be processed by GÖNÜL
ATEŞSAÇAN in order to monitor and manage the treatment process and the
treatment protocol applied, to ensure workplace safety,
and may also be processed to inform third parties about the medical procedure
applied to you, provided that you give your explicit consent .
·
Your Financial Data; It will be processed for the purpose of issuing
invoices by controlling your fee payments and refunding if there is any excess
fee.
·
Your Transfer and Accommodation
Information; It will be processed in order to
plan the transfer and accommodation services of the Health Tourist
patients/clients coming within the framework of Health Tourism.
Your
personal data mentioned above will be processed in line with the
above-mentioned purposes and legislation in order to carry out your medical
treatment and fulfill your obligations regarding your treatment. If you do not
provide your relevant personal data, DR. Legal obligations imposed on GÖNÜL ATESSAÇAN
will not be fulfilled properly and your treatment and/or recovery processes
will not be carried out successfully.
METHOD
OF COLLECTING PERSONAL DATA
Your
Personal Data and Sensitive Personal Data, DR. Depending on the health service
offered by GÖNÜL ATEŞSAÇAN ;
·
For the purpose of examination and
treatment, DR. GÖNÜL ATEŞSAÇAN , through your health reports, laboratory and
imaging results, analyzes, health reports and statements you have given
regarding your health data so that a medical evaluation can be made regarding
the treatment to be applied to you,
·
DR. By filling in the “Patient
Information and Consent Form” regarding the treatment to be administered by GÖNÜL
ATESSAÇAN ,
·
DR. Corporate websites of GÖNÜL
ATEŞSAÇAN www.gonulatessacan.com/ www.aristodiyet.com/ www.onlinediyetim.com
through the contact form you fill
out,
·
DR. By e-mails you will send to
the corporate e-mail addresses of GÖNÜL ATEŞSAÇAN ,
·
DR. By means of photo/video
recordings recorded before, after and/or during the medical procedure that
GÖNÜL ATESSAÇAN has /will apply to you,
·
Upon your request and where
necessary; DR. GÖNÜL ATEŞSAÇAN, in order to carry out your online diagnosis and
controls via remote access, by accepting their Privacy Policies and
International Transfer Policy, the remote connection application service
providers (whatsapp/zoom.us/facetime/skype/messanger/google/instagram/facebook)
etc. ) using DR. Through your written/audio/visual (photo and/or video
recording) messages you send to GÖNÜL ATEŞSAÇAN and your online audio/video calls
through these applications,
·
By
accepting
their Privacy Policies and International Transfer
Policy , DR . _ By sending a direct message to the profile account of GÖNÜL ATEŞSAÇAN and/or commenting on his posts,
·
By
accepting
their Privacy Policies and
International Transfer Policy , DR . _
Through the information you transfer by allowing it to be
automatically processed through panels such as “ contact us ” or “ get information ” in
the promotions and advertisements made by GÖNÜL ATEŞSAÇAN ,
·
DR. In case you want to join the existing
wireless internet network ( wi -fi) in GÖNÜL ATEŞSAÇAN's office as a guest
user, through the log -recording devices (firewall) used within the scope of
the technical measures taken in accordance with the legislation ,
·
DR. Within the scope of GÖNÜL
ATEŞSAÇAN's legitimate interest, through security cameras, which are under
closed circuit recording, without sound recording feature, for the purpose of
ensuring workplace safety,
will be collected and during the
examination, medical
diagnosis, treatment and care services , DR. It will
be processed in accordance with KVKK and GDPR in order for GÖNÜL ATEŞSAÇAN to
fulfill its contractual and legal obligations fully and properly.
PURPOSE
OF PROCESSING YOUR PERSONAL DATA,
METHOD
AND LEGAL REASON
Your
Personal Data, DR. As a " DATA PROCESSOR " by real or legal
persons authorized by GÖNÜL ATEŞSAÇAN ; verbal, written, camera and
photographic recordings , together with the necessary technical and
administrative security measures , by keeping the physical and electronic
record, and in cases where the relevant provisions of the KVKK and GDPR are
provided, provided that your explicit consent is obtained.
SITUATIONS
REQUIRED TO GET YOUR EXPRESS CONSENT STATEMENT
Pursuant
to article 6/1/a of GDPR and article 5/1 of KVKK, your Personal Data can only
be processed by obtaining your explicit consent in the following cases;
·
DR. Sending sms messages and/or
e-mails and mobile communication to you for the purpose of promoting,
announcing and informing about the innovations regarding the medical services
provided by GÖNÜL ATEŞSAÇAN will only be possible with your explicit consent.
·
Medical Photographs and/or video recordings
taken to observe the progress of the treatment before, during and/or after the
medical procedure.
DR. Sharing it on GÖNÜL ATEŞSAÇAN 's social media accounts
( instagram , youtube , facebook , twitter , linkedin etc.) and corporate
websites will only be possible with your explicit consent.
·
Since
sharing your data through service providers whose servers are located abroad
will be considered as "transfer abroad" and there is an
"explicit consent condition" for transfer abroad, your express
consent will be obtained in such cases. However, in the following cases,
DR. Since there will be no international transfer by GÖNÜL ATEŞSAÇAN, YOUR
EXPRESS CONSENT WILL NOT BE REQUESTED, AND YOUR EXPRESS CONSENT WILL BE
CONSIDERED BY THE SERVICE PROVIDER YOU ARE THE USER OF ;
Ø whatsapp /zoom.us/ facetime / skype / messanger /
google / instagram / facebook etc.) whose servers you are already a user , DR.
In case you send a written/audio message and/or photo/video recording or make
an audio/video call to GÖNÜL ATEŞSAÇAN or request to receive remote examination/diagnosis
service by contacting yourself in this way; By accepting the policies of the
mentioned applications, DR. GÖNÜL ATEŞSAÇAN and your Personal Data and Private
Personal Data that you share with DR. GÖNÜL ATEŞSAÇAN has agreed to be processed
in accordance with the KVK Clarification Text and Privacy principles to be
transmitted to you through the application, to be contacted through the
applications mentioned, and to be open to the aforementioned applications for
the transfer of your data abroad in accordance with the previously accepted
policies of these applications whose servers are located abroad. you consent.
Ø In cases where you request to be contacted via e-mail
service providers (Hotmail, gmail , yahoo , etc.) whose
servers you are currently using are abroad by accepting their Privacy Policy
and International Transfer Policy ; DR. You accept that GÖNÜL ATEŞSAÇAN
processes your Personal Data and Private Personal Data shared in messages in
accordance with the KVK Clarification Text and Privacy principles, and you
give your express consent to your e-mail service provider for the transfer of
your data abroad in accordance with the policies you have previously accepted
of these service providers whose servers are located abroad. .
Ø DR. In cases where you apply
to GÖNÜL ATEŞSAÇAN 's advertisements and promotions published on social media
service providers ( facebook , instagram , Google,
whatsapp etc.) whose servers are located abroad ; By accepting the Privacy and
International Transfer Policy of the relevant social media service providers,
your data that you allow to be automatically processed and transferred abroad,
is transferred to the relevant social media service provider by DR. GÖNÜL ATEŞSAÇAN and DR.
It will be processed and preserved by GÖNÜL ATEŞSAÇAN in
accordance with its Clarification Text and Privacy Principles, which will be
transmitted to you through the application. In these cases; DR. GÖNÜL ATEŞSAÇAN 's Clarification Text and Privacy Principles and the
processing of your Personal Data and Special Quality Personal Data in this
direction, through the contact information you have provided to DR. You agree
that GÖNÜL ATEŞSAÇAN can contact you.
Ø By accepting
their
Privacy Policies and International Transfer Policy , DR . _
If you send a direct message to the
profile account of GÖNÜL ATEŞSAÇAN ; DR. You agree that GÖNÜL ATEŞSAÇAN
processes your data in accordance with the KVK Clarification Text and Privacy
principles that will be transmitted to you through the application and
communicates with you through the relevant application.
SITUATIONS
WHERE YOUR DATA MAY BE PROCESSED WITHOUT EXPRESS CONSENT STATEMENT:
Pursuant
to article 9/2/h of GDPR and article 6/3 of KVKK;
·
In
order to carry out examination, medical diagnosis, treatment and care services ,
DR. Your
Health Data, which is considered as Special Quality Personal Data, will be
processed by GÖNÜL ATEŞSAÇAN without your
explicit consent.
In
accordance with GDPR article 6/1/b and KVKK article 5/2/c;
·
In order to be able to carry out
your controls after the medical diagnosis and treatment processes, to
communicate with you one-on-one, to manage the appointment processes, DR. Your Personal Data will be processed by GÖNÜL ATEŞSAÇAN
without your explicit consent.
Based
on our legitimate interests in accordance with GDPR article 6/1/f and KVKK
article 5/2/f;
·
In order to realize patient
satisfaction and demand management, DR. Your Personal Data will be processed by
GÖNÜL ATEŞSAÇAN without your explicit consent.
Based
on legal obligations pursuant to GDPR article 6/1/c, KVKK article 5/2/a and
KVKK 5/2/ç, your Personal Data will be processed without your explicit consent
in the following cases;
·
Creating a patient file.
·
Preservation
of information about your health data, which must be kept in accordance with
the relevant legislation.
·
Issuing invoices by controlling
your wage payments.
·
Execution of tax payments.
·
Fulfillment of obligations
pursuant to Ministry of Health Legislation.
·
Fulfillment of obligations
pursuant to Health Tourism Legislation.
·
Ensuring your data security.
·
Fulfillment of legal obligations
before the Judicial Authorities.
·
Fulfillment of administrative
obligations before Administrative Institutions and Organizations.
YOUR
PERSONAL DATA
TO WHOM
IT WILL BE TRANSFERRED AND FOR WHAT PURPOSES
Your
Personal Data collected in accordance with the conditions and purposes within
the scope of Personal Data Processing Conditions specified in Articles 5 and 6
of the KVKK No. 6698 and 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, DR. GÖNÜL
ATEŞSAÇAN, providing services for examination, preventive medicine, medical diagnosis,
treatment, medical aesthetic applications, weight loss programs accompanied by
medical evaluation, execution and development of post-treatment care services , receiving consultation services from other
specialist physicians when necessary, fulfilling administrative obligations
regarding International Health Tourism Legislation. Planning the transfer,
accommodation and interpreter services of the health tourist patients coming
within the framework of Health Tourism , communicating with the patients,
managing the control appointment processes, planning and
managing the health services and financing, fulfilling the responsibilities
arising from the legal relationship established between the doctor and the
patient, financial, legal For the purposes of fulfillment of administrative and
administrative obligations, ensuring technical and commercial security and
fulfilling public obligations, providing medical information to third parties
about the medical services provided , To
the extent necessary for its realization, it will be able to transfer it to
third persons and institutions by signing the necessary Confidentiality Agreements
and providing all administrative and technical security measures in accordance
with the legislation. In this context, Dr. Your Personal Data processed by
GÖNÜL ATEŞSAÇAN;
·
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 Web/Promotion Consultant
Ø “Clinical Management Software System” Service Provider
Ø interpreters
Ø Data Protection Officer
Ø IT Consultant
Ø Tourism Agencies
·
Public Institutions and
Organizations authorized within the framework of laws,
·
It can be transferred to the
Judicial Authorities.
PERSONAL
DATA PROCESSING TIME
Your Personal Data, DR. It will be kept by GÖNÜL
ATEŞSAÇAN to the extent and as long
as it is legally obliged to keep it. Documentation and retention obligations
derive from local norms regarding trade, tax and health legislation. The table
below shows the retention periods for your Personal Data.
|
Your
Personal Data |
Storage Times |
|
Your
Identity Information |
20
Years After the End of the Service Provided to the Service Receiver |
|
Your
Contact Information |
20
Years After the End of the Service Provided to the Service Receiver |
|
Your Health Information |
20
Years After the End of the Service Provided to the Service Receiver |
|
Your Photo and Video Information |
20
Years After the End of the Service Provided to the Service Receiver |
|
Your Financial Information |
5
Years After the End of the Service Provided to the Service Receiver |
DATA
OWNER AGE LIMIT IN THE FRAMEWORK OF LEGISLATION
Within
the scope of KVKK, patients/clients will be able to personally give consent for
the processing of their personal data, provided that they are at least 18 years
old. The consent of the patients/clients under this age limit must be given by
their legal representatives.
Within
the scope of GDPR, citizens of European Union countries and patients/clients
residing in European Union countries can personally give consent for the
processing of their personal data, provided that they are at least 16 years old
or at the age limit stipulated in their country. The consent of
patients/clients under this age must be given by their legal representatives.
WITHDRAWAL
OF CONSENT
Regarding the processing of your
Personal Data, DR. We inform you that if you give
consent to GÖNÜL ATEŞSAÇAN ,
you can withdraw your consent at any time in accordance with the
above-mentioned purposes in accordance with GDPR 6/1/a and KVKK 5/1. Your
consent will be withdrawn if you send your declaration of withdrawal of consent
to our contact address below, as indicated below.
RIGHTS OF DATA OWNERS ACCORDING TO GDPR
As the Data Owner, your Personal Data is also protected in accordance with the GDPR. In cases where GDPR is under jurisdiction (European Union citizens or residents of European Union countries), the rights of Data Subjects are as follows;
·
Right of Access
(GDPR article 15): The data owner, 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 Subject, DR. GÖNÜL ATEŞSAÇAN
has the right to have the changed personal data of his/her party corrected by
applying at any time.
·
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. GDPR clause
If
the issues specified in 17 occur, DR. Your personal data will be deleted by
GÖNÜL ATEŞSAÇAN without delay.
·
Right to
Restriction of Processing (Article 18 GDPR):
Ø If
Data Owners object to the up-to-dateness of their Personal Data, DR. As the
Data Owner, they have the right to request the restriction of the use of the
data until the accuracy of the Personal Data is confirmed by GÖNÜL ATEŞSAÇAN.
Ø In
cases where the Data Owner requests the deletion of his Personal Data due to
the illegality of the Personal Data processing activity, he has the right to
request the restriction of the use of the data until the request is fulfilled.
Ø In
cases where Data Subjects object to the processing in accordance with Article
21/1 GDPR, DR. Until it is verified whether GÖNÜL ATEŞSAÇAN 's legitimate
reasons for data processing outweigh the Data Owner 's legitimate reasons, they
have the right to request that the use of their data be restricted.
·
Right to Data
Migration (GDPR article 20): The Data Owner, where
technically possible, DR. GÖNÜL ATEŞSAÇAN has the right to request the transfer
of the Personal Data held in its custody to another controller at any time by
applying. However, this right may be exercised when data processing is based on
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 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
In cases
where the Data Owner's Personal Data is processed for direct marketing
purposes, profiling is also applicable to the extent that it relates to such
direct marketing.
has the right to object at any time to the processing
of his personal data for this purpose.
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.
RIGHTS
OF DATA OWNERS ACCORDING TO KVKK
The rights 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 of any rights or requests
that you want to use from your rights listed above; You must submit your
written application, in which you clearly and comprehensibly state which of the
rights you want to use, as stated in Article 11 of the KVKK and the articles on
data subject rights in GDPR, with wet signature and documents to prove your
identity, to DR . GÖNÜL ATEŞSAÇAN ' s , “ Operator Cemil Topuzlu Cad. 18 March St. Cengic Apt. No:1/1
Kat:9 D:11 Caddebostan-Kadıköy/Istanbul/Turkey ” , you can present it in person, send it through a notary public
or send it to gonul@gonulatessacan.com by signing with
a secure e-signature or other methods specified in the KVKK . You can send it
with In your applications, name- surname
, signature, TR Identity Number/Passport Number/temporary TR Identity Number,
residence or workplace address, e-mail address, telephone and fax number, the
subject of the request should be included in accordance with the " Communiqué
on the Procedures and Principles of Application to the Data Controller ". mandatory.
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.
You
have the right to refuse to accept the Clarification Text after reading it.
GÖNÜL
ATEŞSAÇAN reports as “DATA SPEAKER” within the scope of
KVKK and as
“CONTROLLER” within the scope of GDPR.
Regards.