Cemteş Özel Sağlık İşletmeleri Sanayi ve Ticaret Ltd. Şti (“ Hekimoğlu ” ) , operating in Şehremini Mahallesi Turgut Özal Millet Caddesi No 71 floor 1 Fatih / İstanbul, show great sensitivity to ensure that all kinds of data belonging to you are processed and stored in the best possible way and selectively. Accordingly, we present the following issues within the scope of the obligation to inform in order to ensure that we can act in accordance with the Personal Data Protection Law No. 6698 (“Law”) and the relevant legislation.
Cemteş Özel Sağlık Hizmetleri Sanayi ve Ticaret Ltd. Şti – Hekimoğlu Imaging Center (Hekimoğlu ), we continue to stay in the preliminary program of the privacy policy, which is also a patient right, in the clinic activities we provide, with the awareness that the protection of Personal Data is regulated as a constitutional right and due to the requirement of the privacy of private life. With this awareness, our patients, patient relatives, and our clients (hereinafter referred to as “patients and clients” as well as “PATIENTS”) who benefit from the health services and consultancy services we provide, and the personal data transmitted to those in the possession of those stored by our center and its services are processed in accordance with the relevant legislation, primarily the Law on the Protection of Personal Data No. 6698 (“KVKK”), and are provided in the necessary standards required for storage.
With this Disclosure Text, before the Personal Data is processed, information is provided by Hekimoğlu to the Data Owners, and by fulfilling the information and disclosure fee of Article 10 of the KVKK , information is provided as the “Data Controller” on how personal information is collected, how it is collected, how it is processed (how it is kept as a personal, how it is collected, how Awards, how we protect it, how we transfer it, how it will be deleted, etc.) within the scope of the health services we provide. In addition, in cases where it is necessary, the Explicit Consent of the relevant Data Owners is taken as basis.
KVKK, as the permanent and Data Controller, will be able to record, store, update, transfer, classify personal information within the limits explained in this text and ordered by the legislation, and process it based on the rules of lawful processing in a permissible manner.
The information regarding the operation of personal care by Hekimoğlu as the data controller is below;
1- HOW DO WE COLLECT AND PROCESS PERSONAL DATA?
We collect various information from our patients and/or, if necessary, from our patients’ legal representatives, before and/or during the health services and consultancy services framework service of our services, from our employees and from our center and its services and third parties within the scope of the service we provide, also through camera monitoring activities carried out at the entrance and inside our clinic . The said information is updated in accordance with the data processing principle and conditions in the Personal Data Protection Law No. 6698 (“KVKK”) under all circumstances.
Our clinic is monitored and recorded 24 hours a day with a closed circuit camera system. During this process, it is automatically operated based on the legal justification of “Data is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person” in Article 5 of the KVKK for the purpose of ensuring the security of the physical life of all visitors to our clinic and the visual and audio data controller operations and for the scanning and monitoring of visitor records .
Accordingly, the monitoring areas, numbers and monitoring applications of security cameras are implemented as sufficient and intended limitations to achieve the security purpose. Areas that may result in the violation of the privacy of the person by exceeding the security purposes (eye clinics, toilets, etc.) are not monitored and recorded with cameras. In accordance with Article 10 of the KVKK regarding the monitoring activity with cameras by our clinic; “ Clarification Text Regarding the Monitoring Activity with Cameras in the Clinic ” is published on our www.hekimoglugoruntuleme.com website and the Data Owner is informed by presenting a notification request/sign regarding the maintenance in a way that can be seen in the areas where the monitoring is carried out .
Cemteş Özel Sağlık Hizmetleri Sanayi ve Ticaret Ltd. Şti – Hekimoğlu Imaging Center (Hekimoğlu). However, within the scope of its field of activity, our Clinic operates in Special Personal Data. In terms of Special Personal Data, for which the legal approval is provided by the Data Controller Hekimoğlu in settings related to the range of patient records and treatment options, data processing is carried out in accordance with the conditions specified in the legislation.
Of the personal data of private information, health data of the relevant persons can be processed by persons or authorized institutions and organizations without the explicit consent of the KVKK article 6/3, but only for the protection of public health, preventive medicine, treatment diagnosis and care studies, planning and management of health services and education. In addition, all private personal data, regardless of their type, can be processed only if sufficient measures are prepared by the KVKK.
Your personal rights that you share with us within the scope of our clinic activities and Consultancy Services; are collected by automatic or non-automatic programs for the purposes of protecting public health, preventive medicine, medical diagnosis, monitoring treatment and care, planning and management of health services and financing provided by Hekimoğlu; through all media including social media applications such as websites, surveys, social responsibility, and through verbal, written, visual or electronically arranged, arranged lines, call centers, websites, verbal, written and similar channels by being obtained, recorded, stored, changed, and rearranged. Any transaction on the data within the scope of KVKK is considered as “recording personal data”.
In addition, when you use our line or website for information, appointments, complaints or other transactions for the provision of services, when you visit our center or website and when you browse this site, it cannot be processed personally.
2- WHAT PERSONAL DATA DO WE COLLECT?
The information regarding your personal data that we collect for the purposes specified in a sub-item below, although its content may vary depending on the health services provided or offered to you or your legal relations with our center and Hekimoğlu (patient, consultant, patient relative, etc.), is provided below;
Your identity information: Your name, surname, copy of your identity document or passport or driver’s license, your TR ID number, passport number or temporary TR ID number, place and date of birth, marital status, gender, insurance or patient protocol number and other identity conditions by which we can identify you.
the appointment .
Your Contact Information: Your address, telephone number, e-mail address and other communications are not managed personally, obtained manually through e-mail, letter or other means of communication.
Your Accounting Information: Your bank account information, IBAN number, credit card information, financial systems such as storing invoices .
In order to protect and ensure health status, suitable for special health protection and/or without Social Security Institution protection.
The camera kept for security and control purposes within our center is recording the images.
Your Health Information: Laboratory failures, test results, examination health conditions, including your prescription and medical diagnosis with records that cannot be examined, and all kinds of health and sexual life obtained during or as a result of maintenance and repair, including your personal health (your medical history, possible health and surgeries, allergies, the continuous use you have, etc.)
Your Biometric Data and other data: information about health outcomes
the video call service with remote connection systems, our identity links, communication links, health links and related sexual life and genetic links as well as visual and auditory links obtained in relation to the service, Interview Records / Client File prepared by the Consultant.
All websites and online services belonging to our clinic are provided through the health protection, IP address, cookies and personal privacy that you send and/or enter.
quality and general quality that you share with our center and Hekimoğlu through various channels are within the scope of the data.
Both specific personal data and general personal data you share;
the Health Services Fundamental Law No. 3359, the Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Regulation on Private Health Institutions that Can Provide Outpatient Diagnosis and Treatment, the Regulation on Personal Health Data and other relevant regulations,
Maintaining our contractual responsibilities,
Preserving information regarding your health data that must be stored within the scope of relevant legislation,
Sharing the requested information with the Ministry of Health and other public institutions and organizations regarding relevant legislative changes,
Protection of public health, expansion of preventive medicine, medical diagnosis, treatment and care,
To provide information on legislation and compliance to prosecutors, courts and relevant public officials upon request in matters related to public security and legal disputes,
Health and care outcomes, including preventive health care
Provision and management of informatics for the delivery of health services,
Video Consulting Service Delivery,
Taking all necessary technical and administrative procedures within the scope of data security,
Planning and expanding the practice’s internal backups, adding software, performing analysis, risk management and expanding quality,
To inform you about the number of appointments,
Abuse and unauthorized initiation and blocking,
Among the services provided are the organization of freelance receipts;
Verification of your identity,
To answer all your questions and complaints regarding health services,
Classification of patient care and initiation of patient distribution, development and development of our staff,
Provision of medicine or treatment devices,
Carrying out risk management and quality improvement activities,
international venues , ensuring the safety of life and property,
It can be processed for its intended purposes.
Safe storage of personal information is not protected as confidential and personal for our clinic. By transferring the physical archive and/or information systems within Cemteş Özel Sağlık Hizmetleri Sanayi ve Ticaret Ltd. Şti – Hekimoğlu Imaging Center (Hekimoğlu) and/or contracted organizations both digitally and digitally, appropriate security measures are taken and regular security inspections are carried out according to the immutability and quantity of physical data.
4- ISSUES RELATED TO EXPLICIT CONSENT WITHIN THE SCOPE OF THE CONDITIONS FOR PROCESSING PERSONAL DATA
Within the scope of Articles 5/1 and 6/2 of the KVKK, “personal data cannot be processed without the explicit consent of the relevant person”. However, the following are listed as exceptions to this situation in Article 5/2 of the KVKK;
Clearly foreseen in the laws
a de facto impossibility or whose consent is not legally recognized, or of another person.
It is necessary to delete personal information related to the modification of a contract, provided that it is directly related to the establishment or performance of a contract.
It is mandatory for the data controller to fulfill its legal registration.
It has been made public by the relevant person himself.
Data processing is necessary for the change, exercise or protection of a right.
Verification is mandatory for the legitimate interests of the data owner, without prejudice to the fundamental rights and freedoms of the person concerned.
However, I would like to point out that these exceptions do not apply to all special personal data. As stated in Article 6/1 of the KVKK; “data related to race, ethnicity, political party, belief, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security data, as well as biometric and genetic data are personal data of special information” and cannot be processed without the explicit consent of the person concerned. If it is cleared by law, explicit consent is not required for personal data other than health and sexual life.
Personal data regarding health and sexual life cannot be processed by persons or authorized institutions and organizations that are subject to confidentiality without the explicit consent of the person concerned, only for the purposes of protecting public health, preventive medicine, medical diagnosis, and care and treatment departments, planning and managing the financing of health services.
For this reason, we process the sexual life conditions of the patient to whom we need to provide preventive medicine and other health services, without obtaining explicit consent, if they belong to the health system and are related to it.
We process private data, other than health and sexual life, as regulated by law, without obtaining explicit consent.
We process all other private and personal information with your explicit consent.
In short, your personal data will be processed in a manner prescribed by the rules of law and compliance with the rules, in connection with the processing systems, in a limited and proportionate manner, accurately and up-to-date, with certain clear and legitimate transactions and, where necessary, with your explicit consent.
5- STORAGE, DELETION, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA
The procedures and principles regarding the storage and destruction of Personal Data and the storage conditions are included in the “Personal Data Storage and Destruction Policy ” which can be copied by the Clinic. The safe storage of data is confidential for our Clinic. Appropriate security measures are taken according to the quality and beauty of this change and regular security audits are carried out.
Personal Data processed by the Clinic in accordance with the legislation is stored for a period appropriate to the purpose of recording and/or processing in the legislation, and at the end of this period, it is deleted, destroyed or anonymized ex officio or upon the request of the relevant Data Owner .
Data can be stored in a physical or digital environment, and services can be received from Third Party service providers that are available in the countries.
6- WHO CAN ACCESS PERSONAL DATA AND TO WHOM THIS DATA IS TRANSFERRED?
The Health Services Fundamental Law No. 359, the Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Regulation on Private Healthcare Institutions Providing Outpatient Diagnosis and Treatment, the Regulation on Personal Health Data and other relevant legislation, the Ministry of Health and its affiliated subunits, the security forces and other law enforcement forces affiliated to the Ministry of Internal Affairs, the Prosecutor’s Office, the Courts, other official authorities authorized by laws, the private insurance company that you can become a member of so that you can use your private insurance, the health regions related to your referral relations, the authorized legal representatives provided, our lawyers, consultants, auditors, business partners, our laboratories, centers and similar third parties in cooperation for health services in case of a possible legal dispute, domestic institutions and other third parties with whom we cooperate, who have a contractual service responsibility to carry out our activities, in order to protect the physiological and health status and “to protect public health, preventive medicine, medical diagnosis, treatment and increase the performance of care, Based on the legal explanation of “health services and financing planning and management”, preparation of commitments regarding all technical and administrative transactions that are limited and proportionate only in connection with the service received and whose service availability is a requirement of KVKK is conveyed with the preliminary inclusion.
Personal Data requested within the scope of the relevant legislation of public institutions and systems, “Personal Data” included in Article 8/2-a of the KVKK , sharing of Personal Data with public legal entities, can be stored as part of KVKK 5/2-ç. It is mandatory for the Data Administrator to fulfill the legal record , it is assumed that the sharing of Personal Data with public legal entities is not impaired in any way.
Our clinic acts in accordance with the legislation, Board decisions and relevant regulations regarding the transfer of Personal Data.
It is essential that Personal Data is shared with Clinic users and Third Parties, excluding Clinic users for whom access is mandatory, unless the data is mandatory for the Clinic’s regime.
In order to store information regarding the transfer of Personal Data without the consent of the person concerned, as per the 5th and 6th types of the LPPD, Personal Data is transferred to other persons without the Explicit Consent of the Data Owner , except for the conditions that require the transfer of Personal Data to administrative and judicial institutions and organizations as required by the LPPD or relevant legislation .
7- WE PROCESS DUE TO SOCIAL MEDIA AND ADVERTISING / PROMOTION ACTIVITIES
We know that this processing activity will never be carried out if you do not give your explicit consent. Your visual and audio records such as photos and videos can be processed on our social media accounts if your explicit consent is obtained. In case of your explicit consent on our social media accounts, opening your visual and audio records poses a risk. In case your explicit consent is withdrawn, these registered third-party applications or other search engines can track women in cases that are beyond our control. Make sure that your explicit consent is given based on your free will and that you have read the information carefully.
8- CASES WHERE YOUR PERSONAL DATA IS TRANSFERRED BASED ON YOUR EXPRESS CONSENT
Cemteş Özel Sağlık Hizmetleri Sanayi ve Ticaret Ltd. Şti – Hekimoğlu Imaging Center (Hekimoğlu) always wants to inform patients face to face about the results of these tests in case of their patients giving tests or samples for medical diagnosis and treatment and this purpose consists of control appointments. However, verbal information about test results or health problems during the period when their patients continue can be provided via e-mail, telegram, WhatsApp, Signal etc. applications with the explicit consent of the users. In the information provided by Hekimoğlu in this report, the distribution of personal sections of special storages abroad is carried out in the way that the servers of the applications in question are stored. Therefore, Hekimoğlu includes your explicit consent to transfer personal information and private information within the scope of article 9.1 “Personal data cannot be transferred abroad without the explicit consent of the relevant person” in the KVKK from patients who want to be informed via e-mail, WhatsApp, Signal etc. applications. In addition , it can be stored in a physical or digital environment held personally by Hekimoğlu , it can be found in countries and services can be received from third party service providers in this regard. If the servers of Third Party Service Providers are operated during the receipt of this service , your explicit consent is reserved for the storage of personal information and private persons in Third Party Service Providers within the scope of article 9.1 “Personal data cannot be transferred abroad without the explicit consent of the relevant person” in the KVKK.
9- WHAT SHOULD YOU DO IF YOUR PERSONAL INFORMATION CHANGES?
If there is a change in your personal data, you must tell us so that we can update our records. In addition, the suitability of our installation is requested from the dimensions to check the accuracy and up-to-dateness of personal care such as contact and address unrelated.
10- PERSONAL DATA OF CHILDREN
Within the scope of the laws of the Republic of Turkey, we can process personal data of persons over 18 years of age with the consent of the minor’s parent or guardian in cases where explicit consent is required.
11- RIGHTS OF THE PERSONAL DATA OWNER STATED IN ARTICLE 11 OF THE KVKK
The requirement of Article 11 of the KVKK No. 6698 and the rights of the Personal Data Owner are as follows:
Regarding your processed personal data, by applying in accordance with the legislation,
Learning whether personal data is being processed,
Requesting information regarding the cutting of personal data,
To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
To inform third parties to whom personal data is transferred, whether domestically or abroad,
Not requesting information about personal data if it is processed incompletely or incorrectly,
Requesting the deletion or non-destruction of personal data of file frames in Article 7 of the KVKK (the right to deletion is worthy of storage under the personal record legislation within the scope of health, since the Regulation on Personal Health Data is worth storing)
In case of protection, deletion or destruction of personal data, this separation is not requested to be notified to third parties to whom personal data is transferred (the right to delete the content of the record of storage of personal data within the scope of health legislation is not worth storing)
Objecting to the emergence of a result against the person by ensuring that the processed recorded data is analyzed by exclusively automated systems,
In case of damage caused due to the illegal processing of personal data, the right to demand compensation for the damage is exercised.
In order to exercise your rights listed above, you can make your request to determine your identity and provide the necessary information, including your explanations regarding your rights, by using the command “Şehremini Mahallesi Turgut Özal Millet Caddesi no 71 floor 1 Fatih/ İstanbul” or send it through a notary public, or you can send a signed copy of your request from your registered e-mail address with a secure electronic signature via info @ hekimoğlugoruntuleme.com e-mail.
The right to request proof of identity during the application process is reserved for the purpose of verifying identity information.
Your requests will be finalized free of charge as soon as possible and within 30 days at the latest, depending on the registration of your request. However, if the transaction requires an additional cost, the fee in the tariff recorded by the Personal Data Protection Board will be charged. If your request is to be made on behalf of someone else, a power of attorney with this information and the correct information about your identity must be attached to your application along with other documents.