Privacy Policy

PREFACE

Within the scope of the Law on the Protection of Personal Data, ESTELİT SAĞLIK HİZMETLERİ A.Ş. (“ELİT KLİNİK”) (hereinafter referred to as “ELİT KLİNİK” or “Company”), we attach importance to the protection of your personal data and / or sensitive personal data. We are sensitive about the storage of all personal data and / or special categories of personal data belonging to you, which are transmitted to our company in various ways. In this context, we have taken the necessary technical and administrative measures as ELİT CLINIC in order to comply with the provisions of the Turkish Constitution and other legislation, especially the Law No. 6698 on the Protection of Personal Data. We share with you our Privacy Policy, which has been put into effect within ELİT CLINIC, which is particularly important for the protection of your personal data.

1. Definitions

Data Controller: It refers to ESTELİT SAĞLIK HİZMETLERİ A.Ş., which determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. Data Owner-Related Person: Refers to the real person whose personal data is processed. Company: In accordance with this policy, ESTELİT SAĞLIK HİZMETLERİ A.Ş. is referred to. Law: Law No. 6698 on the Protection of Personal Data. Personal Data: It refers to all kinds of information about a real person whose identity is specific or identifiable. Sensitive Personal Data: Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership to associations, foundations or trade unions, health, sexual life, criminal conviction and security measures, and biometric and genetic data. Board: refers to the Personal Data Protection Board. Policy: This refers to this “Privacy Policy”. Processing of Personal Data: It refers to all kinds of operations performed on personal data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. Explicit Consent: Consent regarding a specific subject, based on information and expressed with free will. Destruction: Refers to making personal data inaccessible, irretrievable and non-reusable by anyone in any way. Deletion: Refers to making personal data inaccessible and non-reusable in any way for the relevant users. Anonymization: It refers to making personal data impossible to be associated with an identified or identifiable natural person under any circumstances, even if it is matched with other data. Destruction: Refers to the deletion, destruction or anonymization of personal data. Data: Personal data and sensitive personal data are referred to together.

2. PURPOSE OF THE PRIVACY POLICY

Protection of personal data and compliance with the Law is our basic principle. In all the works we do as ELİT CLINIC, the personal data and / or sensitive personal data we have received from you have been kept confidential and not shared with third parties. In this context, our company has always shown the necessary sensitivity regarding the protection of personal data and / or sensitive personal data. Again, in accordance with the Law No. 6698 on the Protection of Personal Data (hereinafter referred to as “Law” or “KVKK”), our internal regulations have been reorganized and all necessary technical and administrative measures have been taken. In the ongoing process, as ELİT CLINIC, we accept, declare and undertake to comply with all obligations imposed by the law.

3. SCOPE OF THE PRIVACY POLICY

This Privacy Policy has been prepared in accordance with the Personal Data Protection Law No. 6698. Our Company reserves the right to make changes without prior notice in order to keep our Privacy Policy up to date and to comply with the relevant legislation. In case of changes in the privacy policy, the updated policy will be announced on our website. This policy was last updated on ../../../2024.
Your personal data and / or sensitive personal data are processed with your consent or within the scope of compliance with the law. Your data in question;
To ensure company security, to carry out marketing processes,
To provide you with complete service,
To solve your problems quickly,
To increase our quality.
Some personal data and/or sensitive personal data from you are depersonalized and anonymized in the procedures stipulated by the Law. Data used for statistical purposes are currently not included in the regulation of the Law and the scope of our policy. As ELİT KLİNİK, we have the right to change this policy in order to protect personal data within the scope of compliance with the Law. Privacy policy The data of real and legal persons, clients, patients, employees and all other persons with whom ELİT KLİNİK is a solution partner, obtained in any way

4. BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA

Our basic principles regarding the processing of personal data and / or sensitive personal data are as follows. In this context, these principles will apply to the data processed by ELİT CLINIC based on explicit consent or within the scope of compliance with the Law. Compliance with the Law: ELİT CLINIC questions the source and lawfulness of personal data and / or special categories of personal data received from real and legal persons and collected in various ways. In this context, it is important for ELİT CLINIC to obtain the data in accordance with the law.
Compliance with the Rules of Honesty: ELİT CLINIC questions the source of personal data and / or special categories of personal data received from real and legal persons and collected in various ways. In this context, it is important for ELİT CLINIC to obtain the data within the framework of the rules of honesty.
Being Limited, Measured and Connected to the Purpose of Processing: ELİT CLINIC uses personal data and/or sensitive personal data obtained through various means in accordance with the purpose for which they are processed, limited to the purpose of processing, measured and to the extent required by the performance of the service.
Accuracy of Personal Data and/or Sensitive Personal Data: ELİT CLINIC attaches importance to the fact that the personal data and/or sensitive personal data received from real and legal persons and collected by various means do not contain false information and are accurate. However, ELİT CLINIC is not obliged to investigate the accuracy of the personal data and/or sensitive personal data declared by its patients, clients or real and legal persons with whom it is in contact. Because this is not possible legally and in line with our working principles.
To be up-to-date when necessary: If there has been a change in the personal data and / or sensitive personal data obtained in various ways, ELİT CLINIC attaches importance to the transmission of such change to the company and updating the data if it is transmitted.
Processing for Specific and Legitimate Purposes: ELİT CLINIC processes personal data and/or sensitive personal data without obtaining explicit consent within the framework of the explicit consent given by the data owner or the exceptions stipulated by law. The purpose of processing each data is specific and no personal data processing activity is carried out for any illegitimate purpose.
Preservation for the Period Stipulated in the Law and/or Required for the Purpose for which they are Processed:
ELİT KLİNİK stores the personal data and/or special categories of personal data it obtains for the periods stipulated in the relevant laws and/or required for the purpose for which they are processed. When the aforementioned purposes end, it anonymizes, destroys or deletes the data. 5. SCOPE OF PRIVACY POLICY
Your personal data and/or sensitive personal data are deleted, destroyed or anonymized upon the expiration of the statute of limitations and retention periods stipulated in the Law, completion of judicial processes or other requirements appropriate for the purpose. Deletion, destruction and anonymization operations are carried out upon the request of the relevant data owner or ex officio (spontaneously) by ELİT CLINIC. 6. PRINCIPLE OF PURITY
The principle of parsimony is also known as the principle of maximum savings. Personal data and/or special categories of personal data received through various means are transferred to our company’s system. Pursuant to the said principle, the data are processed in the system as much as necessary.

The data to be collected by ELIT CLINIC is determined in accordance with the purpose and varies. In this context, data are collected in accordance with the purpose and data that are not parallel to the purpose are not collected. Excess data other than its purpose is not saved in the company system, deleted, destroyed or anonymized. However, such data may be used for statistical purposes. 7. CONFIDENTIALITY AND SECURITY OF DATA As
ELITE CLINIC, we attach importance to the confidentiality of your personal data and/or special categories of personal data. In this context, your personal data and / or sensitive personal data that reach our Company in any way are confidential. ELİT CLINIC complies with the confidentiality of such data at every stage of its commercial activities. In this context, full compliance with this company privacy policy is ensured.
Necessary technical and administrative measures are taken to prevent unauthorized access to personal data and/or sensitive personal data collected in various ways, to prevent damage to the rights of the data owner and to protect the data. In addition, data protection is requested from third parties with whom we share personal data and/or sensitive personal data within the framework of compliance with the law when necessary. Again, our software programs are updated and constantly renewed. In order to ensure a high level of protection, technological requirements are fulfilled and compliance with standards is ensured. 8. UPDATE OF DATA
The principle of timeliness is essential within ELITE CLINIC. Because personal data and/or special categories of personal data obtained in various ways can be updated when necessary or upon request. Necessary measures regarding the update are also taken by ELİT CLINIC. 9. ACCURACY OF DATA
The principle of accuracy of the declared personal data and / or sensitive personal data has been adopted by ELİT CLINIC. ELİT CLINIC is not obliged to investigate the accuracy of personal data and/or sensitive personal data declared by its patients, clients or real and legal persons with whom it is in contact. Because this is not possible legally and in line with our working principles. In this context, transactions are carried out on the basis that the declared data is correct. 10. PURPOSES OF PROCESSING PERSONAL DATA AND / OR SPECIAL QUALIFIED PERSONAL DATA
The processing of personal data and / or special categories of personal data is carried out in parallel with the purposes in the Clarification Texts of ELİT KLİNİK. These Clarification Texts may vary according to the personal data and/or special categories of personal data processed. In parallel with the difference in the Clarification Texts, the purposes of processing personal data and / or sensitive personal data may also vary. 11. COLLECTION AND PROCESSING OF PERSONAL DATA AND / OR SPECIAL NATURE PERSONAL DATA IN CONTRACT RELATIONSHIP
If a contractual relationship has been established with patients, clients or prospective patients and clients, personal data collected in accordance with the contract may be processed by ELİT CLINIC without obtaining explicit consent.

In case of processing of special categories of personal data, data may be processed based on explicit consent or legal reasons within the scope of Article 6 of the Law. The data in question are used within the framework of the performance of goods and / or services, execution of the contract, execution of commercial activity. These data can be updated at any time by contacting patients or clients. 12. PERSONAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS AND / OR PERSONAL DATA OF SPECIAL NATURE
Data obtained from information obtained through automated systems without the explicit consent of individuals cannot be used against individuals. ELİT CLINIC acts in accordance with the provisions of the relevant legislation in personal data and/or special categories of personal data processed through automated systems. 13. PERSONAL DATA AND/OR SPECIAL QUALIFIED PERSONAL DATA OF ELİT CLINIC’S EMPLOYEES
PROCESSING WITHIN THE FRAMEWORK OF LEGAL OBLIGATIONS:
Personal data of employees may be processed by ELİT CLINIC without obtaining their explicit consent in order to fulfill the legal obligation of the data controller or if there is an explicit provision in the relevant Law regarding the processing of the data.
PROCESSING PERSONAL DATA IN ACCORDANCE WITH THE EMPLOYMENT AGREEMENT AND WORK RELATIONSHIP:
Personal data of employees can be processed without obtaining the explicit consent of the employees within the framework of proportionality as much as necessary to ensure the business relationship between the company and the employees. ELİT CLINIC undertakes to protect and confidentialize the data of employees under all circumstances and to take the necessary measures in this regard. PROCESSING SPECIAL QUALIFIED PERSONAL DATA OF EMPLOYEES: In accordance with the Law No. 6698 on the Protection of Personal Data, the explicit consent of the person whose data will be processed and the necessary measures stipulated by the Board are required for the processing of special quality personal data. Within the framework of compliance with Law No. 6698 and the principles of the Board, ELİT CLINIC takes both the explicit consent of the person concerned and the necessary measures determined by the Board when necessary when processing special categories of personal data. However, personal data of special nature may be processed without the explicit consent of the person concerned in exceptional cases stipulated in the Law, provided that it is limited and measured.
PERSONAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS:
Some personal data of employees can be processed in automated systems. Such data are used in the performance evaluation of employees, keeping statistical data, promotions and scoring for the company. Employees have the right to object to unfavorable results regarding them. The objection must be made in accordance with internal rules and procedures. The objection in question is subject to evaluation within the company.
PROCESSING PERSONAL DATA FOR THE BENEFIT OF EMPLOYEES:
Personal data of employees can be processed by ELİT CLINIC without obtaining explicit consent within the framework of the relationship provided by the employment contract for transactions related to the benefit of the employee. Again, the Company may process personal data belonging to employees in disputes related to the business relationship with ELİT KLİNİK.
COMPANY INTERNAL TELECOMMUNICATION, INTERNET AND COMMUNICATION:
In order to facilitate the performance of the work, ELİT KLİNİK may allocate computers, phones, cars, applications, software and e-mails to in-house employees.

ELİT CLINIC may control and audit personal data on the vehicles allocated within the scope of its disclosure obligations. The employee cannot use the vehicles allocated to him for his private purposes. It is obligatory to use it only for the purpose of ensuring the performance of the work. Again, the employee accepts, declares and undertakes that he / she will not keep any data and information other than the necessity of work and work in the vehicles allocated from the moment the working relationship with ELİT CLINIC starts. 14. TRANSFER OF PERSONAL DATA AND / OR SPECIAL QUALIFIED PERSONAL DATA TO DOMESTIC AND INTERNATIONAL
ELİT CLINIC may transfer data domestically and internationally in accordance with the conditions stipulated in the Law on the Protection of Personal Data and within the framework of the principles determined by the Board within the scope of compliance with the law or with the explicit consent of the person concerned. ELİT CLINIC acts in accordance with Articles 8 and 9 of Law No. 6698 when transferring personal data and/or sensitive personal data. 15. SUPERVISION AND PROCESS SECURITY
Necessary technical and administrative measures are taken to prevent unauthorized access to personal data and / or sensitive personal data collected in various ways, to prevent damage to the rights of the data owner and to protect the data. In addition, data protection is requested from the companies with which we share personal data and/or sensitive personal data within the framework of compliance with the law when necessary. Again, our software programs are updated, continuously renewed and developed. In order to provide high-level protection, all technological requirements are fulfilled and compliance with standards is ensured. In parallel with all these, ELİT CLINIC conducts all internal and external audits required for the protection of personal data and/or special categories of personal data. 16. NOTIFICATION OF DATA VIOLATIONS
In case of any violation of data, ELİT CLINIC immediately takes action to do its part to eliminate the violations notified to it. It takes the necessary measures to minimize the damage to the relevant person. You can apply for notification of violations according to the procedures specified on our company’s website. In addition, in the event that personal data and / or sensitive personal data are obtained by unauthorized third parties from outside, the company notifies the Personal Data Protection Board directly. 17. RIGHTS OF THE DATA OWNER REQUESTING INFORMATION
The rights of the data owner are stipulated in Article 11 of the Personal Data Protection Law No. 6698.

ELİT CLINIC accepts that the person concerned must be informed before data processing in accordance with the law and, if necessary, obtain his/her explicit consent, and that the person concerned has the right to request information about his/her data, update, delete, destroy and anonymize it after data processing.
Data subjects have the following rights;
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,
To delete 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 data is deleted or destroyed upon the request of the person concerned,
To object to the occurrence of a result against 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.
The information request made on behalf of someone else will not be answered by the company. If it is determined by ELİT KLİNİK that the application made on behalf of someone else in the information request; ELİT KLİNİK reserves all kinds of lawsuit and claim rights. It will be answered as soon as possible and within thirty days from the date the relevant person reaches ELİT CLINIC. ELITE CLINIC may request other information and documents from the applicant if deemed necessary. ESTELİT HEALTH SERVICES A.Ş.