Clarification Text

CLARIFICATION TEXT UNDER THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

Law No. 6698 on the Protection of Personal Data (hereinafter referred to as “KVKK” or “Law”), it is important to process and preserve personal data and / or sensitive personal data. For this reason, as ESTELİT SAĞLIK HİZMETLERİ A.Ş. (hereinafter referred to as “ELİT KLİNİK” or “Company”), we act in accordance with the KVKK regarding the protection, preservation and processing of your personal data and / or sensitive personal data. We frequently receive data from you on the internet. Personal data and/or sensitive personal data received and recorded during the visit of our website are processed in accordance with the Law on the Protection of Personal Data. In this context, ELİT CLINIC receives and maintains your data within the legal limits in the capacity of data controller. We would also like to state that; All personal data and/or sensitive personal data received during the visit of our website are protected within the framework of our Privacy Policy. In this regard, you can review our Privacy Policy, which you can find on our page, and the KVKK clarification text of our website from the link www.elitklinik.com.tr. This clarification text has been prepared by ELİT KLİNİK as the data controller within the scope of Article 10 of the Personal Data Protection Law No. 6698 and the Communiqué on the Procedures and Principles to be followed in the Fulfillment of the Disclosure Obligation.

1. WHAT IS PERSONAL DATA?

Personal data is defined as “any information relating to an identified or identifiable natural person” in the Law No. 6698 on the Protection of Personal Data. As can be understood from the definition, any information that makes you identifiable is personal data. To give an example of what personal data is; your identity information (your name, surname, marital status, T.R. identification number, etc.), your contact information (your phone number, address, e-mail address, etc.), your transaction security information (your IP / MAC address, your login-exit information to our website, etc.), your accounting information (your bank account number, iban number, credit card information, billing information, etc.), your visit to our medical center.), your camera recordings images that are kept for security and audit purposes in case you visit our medical center, your health information (your laboratory results, test results, examination data, appointment information, check-up information, prescription information and all kinds of health and sexual life data obtained during or as a result of the execution of your medical diagnosis, treatment and care services, including but not limited to), your health data that you send or enter on www.elitklinik.com.tr and your other personal data. In addition to all these, political opinion, sect, race, religion, association-foundation membership, health information, philosophical thought, belief, sexual preference, criminal record, criminal conviction information, biometric data are personal data of special nature. Provided that it is directly related to the establishment or performance of a contract, your personal data is processed based on the legal reason that it is necessary to process personal data belonging to the parties to the contract and that it is mandatory for the data controller to fulfill its legal obligation.

2. LEGAL BASIS

Law No. 6698 on the Protection of Personal Data stipulates that the persons whose data are processed must be informed before data processing activities are carried out. This issue, which is considered as the Obligation to Inform, is stipulated in Article 10 of the Law on the Protection of Personal Data as follows: “During the acquisition of personal data, the data controller and the person authorized by the data controller are obliged to inform the relevant persons about the identity of the data controller and its representative, if any, for what purpose the personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method and legal reason for collecting personal data, and other rights listed in Article 11.” In Article 3 of this Law, the data controller is defined as “the natural or legal persons who determine the purposes and means of processing personal data and are responsible for the establishment and management of the data recording system”. Again, the data processor is defined as “the natural or legal person who processes personal data on behalf of the data controller based on the authorization granted by the data controller.” In this context, the data controller is ELIT CLINIC, whose website you have visited. The information of the data controller is as follows.
Data Controller: ESTELIT SAĞLIK HİZMETLERİ A.Ş.
Address: Hamidiye, Cendere Cad. No: 103 – 1 T4 Blok, 34396 Kağıthane/İstanbul
Tel: +90 444 0 207
E-mail: [email protected]

3. SCOPE OF THE DISCLOSURE OBLIGATION OF THE DATA CONTROLLER ELİT CLINIC

In accordance with the foregoing, ELİT CLINIC is the data controller. Under the title of data controller, ELİT CLINIC informs and enlightens you in this Clarification Text about the purpose for which personal data can be processed by whom and for what purpose, to whom and for what purpose it can be transferred, the method and legal reason for collecting data and the rights of the data owner for the protection of personal data. Your personal data are processed within the limits stipulated by the Law No. 6698 on the Protection of Personal Data and based on the principles of the law. All kinds of your personal data obtained by ELİT CLINIC (including but not limited to personal data of special nature) may be processed for the following purposes: Confirming your identity, Protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, Sharing the information requested with the Ministry of Health and other public institutions and organizations in accordance with the relevant legislation, Planning and management of the internal functioning of our Medical Centers and daily operations, Medical Center Management, Measuring, increasing and researching patient satisfaction by Patient Rights departments, supplying medication, informing you about appointments if you make an appointment, performing risk management and quality improvement activities, conducting analysis for the purpose of improving health services, financing your health services, covering your examination, diagnosis and treatment expenses by Patient Services, Financial Affairs and Marketing departments, Sharing the information requested with private insurance companies within the scope of detention query, Conducting research, Fulfillment of legal and mandatory requirements, Sharing the information requested with private insurance companies within the scope of financing health services,
Invoicing for our services by Patient Services, Financial Affairs, Marketing departments and confirming your relationship with contracted institutions,
Marketing, Media and Communication, Participation in campaigns and providing campaign information by Call Center departments, Designing and communicating special content, tangible and intangible benefits on web and mobile channels,
To inform you about the requests and complaints you have submitted to ELİT KLİNİK and to inform you when necessary,
It is processed within the personal data processing conditions and purposes specified in the law and other relevant legislation for the purposes of following and executing the relevant legal proceedings. In addition, your personal data mentioned above can be transferred to the physical archive and information systems of ELİT CLINIC and kept both in digital and physical environment.

4. PRINCIPLES FOR PROCESSING YOUR DATA

To be kept for the period stipulated in the relevant legislation or required for the purpose for which they are processed;
To process in accordance with the law;
To ensure the timeliness of the data;
To act in accordance with the rules of honesty;
Not to be used for purposes other than the purpose for which it is processed;
To be measured and limited for the purpose for which it is processed;
To process in accordance with general morality, custom and custom;
To process in accordance with general morality, custom and custom; To process in accordance with all relevant legislation provisions, especially the provisions of the Personal Data Protection Law No. 6698; As ELİT CLINIC, we have adopted the principle.

5. DATA PROCESSING PROCEDURE

Your personal data can be processed by ELIT CLINIC in the presence of two situations. These two situations are as follows:CIRCUMSTANCES OF COMPLIANCE WITH THE LAW ON EXPLICIT CONSENTCIRCUMSTANCES WHERE EXPLICIT CONSENT IS NOT REQUIREDThe Law No. 6698 on the Protection of Personal Data states that in some cases, explicit consent is not required for the processing of personal data. These cases specified in paragraph 2 of Article 5 of the Law are as follows:
It is clearly stipulated in the laws.
It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid.
It is necessary to process the personal data of the parties to the 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 obligation.
It has been made public by the data subject himself/herself.
Data processing is mandatory for the establishment, exercise or protection of a right.
Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject. In the presence of such situations, ELİT CLINIC has the right to process data without your explicit consent. ELİT CLINIC has the right to process personal data other than health and sexual life from your special categories of personal data without seeking explicit consent in cases stipulated by law. Personal data related to health and sexual life can only be processed by persons or authorized institutions and organizations under the obligation of confidentiality for the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, without seeking the explicit consent of the person concerned.

6. METHOD AND LEGAL REASON FOR COLLECTING YOUR DATA

In developing and changing technological conditions, our company collects data from different channels. The website is one of the areas where we collect personal data automatically. Personal data and/or special categories of personal data collected through the website within ELİT KLİNİK are processed based on one or more of the legal reasons in Articles 5 and 6 of Law No. 6698 or on the condition of explicit consent. We would like to state that the relevant person is informed according to the category and type of the processed data, the purpose for which the data will be processed, to whom and for what purpose the processed data can be transferred, the method and legal reason for data collection and the rights of the person concerned are explained in the aforementioned clarification texts and explicit consent is obtained when necessary. The legal reasons for the collection of your personal data are as follows:
Law No. 6698 on the Protection of Personal Data,
Basic Law No. 3359 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 the Processing and Protection of Privacy of Personal Health Data,
Ministry of Health regulations and other legislation.

7. TRANSFER AND PROTECTION OF DATA

A- TRANSFER
‍In accordance with the Law No. 6698 on the Protection of Personal Data, your data may be shared with third parties from whom we receive services, third parties with whom we cooperate, physicians and other personnel working within our companies, third parties from whom we receive consultancy, including lawyers, tax and financial advisors and auditors, our business partners and other third parties with whom we cooperate to develop or carry out health services for the above-mentioned purposes, where necessary in accordance with the conditions in our confidentiality agreements. For each transferred data, a detailed explanation is made in the Clarification Text made before the data is obtained for the purpose to whom the data can be transferred. However, under all circumstances, ELİT CLINIC acts in accordance with Articles 8 and 9 of Law No. 6698 while transferring data. In addition, it takes necessary technical and administrative measures. B- PROTECTION
‍The Personal Data Protection Law No. 6698 mainly aims to protect data and prevent unauthorized transfer. As ELİT CLINIC, we take the necessary technical and administrative measures to prevent the transfer of data to unauthorized third parties, especially the provisions of the relevant law. In this context, we especially make our internal policies in accordance with the Law on the Protection of Personal Data and we have all kinds of state-of-the-art software and hardware for the protection of personal data. In order to ensure all these, we try to prevent both our employees within the company and third parties we do business with from violating our Privacy Policy, which you can access at www.elitklinik.com.trlinkinden.

8. RIGHTS OF THE DATA SUBJECT

A- GENERAL INFORMATION ABOUT THE APPLICATION
Article 11 of the Law No. 6698 on the Protection of Personal Data stipulates the rights of the data subject. In the Law, the data subject is considered as “data subject” and has the right to make some requests regarding the processing of his/her data. To learn whether personal data is processed, To request information if personal data has been processed, To learn the purpose of processing personal data and whether they are used in accordance with their purpose, To know the third parties to whom personal data is transferred domestically or abroad, To request correction of personal data in case of incomplete or incorrect processing,
“Deletion, destruction or anonymization of personal data”.To request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the Law titled “Deletion, destruction or anonymization of personal data”,
To request that the incomplete or incorrectly processed data is corrected or that the information regarding the deletion or destruction of the data upon the request of the person concerned is notified to third parties to whom personal data is transferred,
To object to the occurrence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
To request compensation for the damage in case of damage due to unlawful processing of personal data. You can submit your requests regarding your rights arising from the Law on the Protection of Personal Data explained above to our company within the framework of the procedure specified in this Clarification Text. Your requests in question will be answered by ELİT CLINIC as soon as possible or within thirty days at the latest. Applications must be made by the data owner himself/herself. ELİT CLINIC will only consider the application made by the data owner and share information about the applicant. B- APPLICATION PROCEDURE
You can submit your requests to ELİT KLİNİK, which has the title of data controller, regarding your rights mentioned above in writing or by using the registered electronic mail (KEP) address, secure electronic signature, mobile signature or the e-mail address previously notified to the data controller by the data subject and registered in the system of the data controller. In order to exercise your request rights regarding personal data, you can review the information on our website and use the “Information Request Form in accordance with the Law No. 6698 on the Protection of Personal Data”, which you can also access via https://www.elitklinik.com.tr. C- INFORMATION REQUIRED TO BE IN THE APPLICATION
The information that should be included in your application is as follows:
Your Name and Surname
Your T.R. Identity Number
Your Nationality, Passport Number or Identity Number, if any, if you are a Foreign National
Your Wet Signature at the Bottom of the Request Form if a Written Application is to be Made
KVKK 11.

The Content of Your Request pursuant to Article
Your E-Mail Address We Can Contact You
Residential or Workplace Address for Notification