KVKK Privacy Notice

Dear Patient,

We respect and value the privacy of your personal life. For this reason, in order to protect your fundamental rights and freedoms, we would like to inform you about your rights regarding the collection, protection, and processing of your Personal Data.

In accordance with Law No. 6698 on the Protection of Personal Data (KVKK), Law No. 3359 on Basic Health Services, Decree Law No. 663 on the Organization and Duties of the Ministry of Health and Its Affiliated Institutions, the Regulation on the Processing and Protection of the Confidentiality of Personal Health Data (the "Regulation"), Ministry of Health regulations, and other applicable legislation; within the scope of this Privacy Notice, Dr. Hüseyin NAZLIKUL provides you with certain information regarding the lawful collection and processing of your Personal Data — including your special category Personal Data — that you provide to us while benefiting from our health services and other services.

Dr. Hüseyin NAZLIKUL, acting as the Data Controller, may record, store, update, and, where permitted or required by legislation or agreements, share and transfer your Personal Data with third parties (relatives of the person receiving services and/or the public and/or private legal entities to which the service recipient is employed or insured, other public and/or private legal entities, and third parties from whom our clinic receives services or with whom it cooperates in order to carry out the activities specified in the legislation to which our clinic is subject), and may classify and process it in the manner described in this Privacy Notice and permitted under the KVKK and relevant legislation.

Your health data is considered a special category of personal data under the KVKK and cannot be processed without your explicit consent. However, your health data may be processed without your explicit consent, for purposes such as protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing, by persons under an obligation of confidentiality or by authorized institutions and organizations.

Your Personal Data is obtained by Dr. Hüseyin NAZLIKUL for the purposes of protecting public health, preventive medicine, carrying out medical diagnosis, treatment, and care services, and planning and managing health services and their financing, through written channels (patient identification forms, patient information and consent forms, etc.), as well as verbal, visual, electronic, email, call center, and website channels.

PERSONAL DATA PROCESSED:

Your personal and special category Personal Data, primarily your health data, includes: your name, surname, Turkish ID number and/or passport number and/or temporary Blue Card ID number, place and/or date of birth, marital status, gender, health insurance, occupation, insurance card number, workplace registration and/or patient ID number, and other identifying data that could identify you; your address, phone number, email address, and other contact data; Personal Data obtained when you contact us through voice recordings kept by customer representatives and/or call center services in accordance with call center standards, as well as through email, letters, or other means; your financial data such as bank account number, IBAN number, credit card information, billing and invoice information; your data related to private health insurance, as well as data regarding payer institutions such as the Social Security Institution, for the purpose of financing and planning health services; and any and all health information and data obtained during and/or as a result of the provision of medical diagnosis, treatment, and care services, including but not limited to patient medical reports, diagnostic data, biometric and genetic data, laboratory results, test results, examination data, doctor's analyses and comments, appointment information, and prescription information; your notifications such as surveys, thank-you letters, complaint letters, and satisfaction results; your vehicle license plate information if you use the parking lot; your images obtained from the continuously recording cameras in the common areas of Dr. Hüseyin NAZLIKUL's clinic; your health data, IP address, cookies, and other Personal Data that you send and/or enter through all websites and online services belonging to Dr. Hüseyin NAZLIKUL; if you apply for a job, your resume and other Personal Data obtained in this regard; and any and all Personal Data related to your service agreement. This data may be processed by Dr. Hüseyin NAZLIKUL in a manner connected, limited, and proportionate to the purpose for which the information was obtained from you.

PURPOSE OF PROCESSING PERSONAL DATA:

Your Personal Data may be processed by Dr. Hüseyin NAZLIKUL for the following purposes.

• Fulfilling our legal obligations under Law No. 3359 on Basic Health Services, Decree Law No. 663 on the Organization and Duties of the Ministry of Health and Its Affiliated Institutions, Law No. 6698 on the Protection of Personal Data, the Regulation on the Processing and Protection of the Confidentiality of Personal Health Data, and other applicable legislation,
• Planning and managing our clinic's internal operations and daily practices (treatments)
• Protecting public health, preventive medicine, carrying out medical diagnosis, treatment, and care services, planning and managing health services and their financing,
• Conducting promotional and informational activities tailored to you and enabling you to benefit from them,
• Preserving information related to your health data that must be retained under applicable legislation,
• If you make an appointment, notifying you about the appointment, providing information, and/or sending appointment reminders,
• Carrying out risk management and quality improvement activities,
• Fulfilling legal and regulatory requirements,
• Sharing and responding to information requests from the Ministry of Health and other public institutions and organizations pursuant to legislation,
• Issuing invoices in return for the services we provide,
• Complying with internal policies and principles,
• Measuring and increasing patient satisfaction following your receipt of health services,
• Analyzing your use of health services and retaining your health data for the purpose of developing and improving the health services we provide to you, and responding to your questions or complaints regarding our services,
• Sharing information requested by contracted institutions/organizations, primarily private insurance companies, within the scope of financing health services, and identity verification,

Being contacted by Dr. Hüseyin NAZLIKUL for informational and promotional purposes regarding our services, and, without limitation, for carrying out and improving medical diagnosis, treatment, and care services, planning and managing health services and their financing, increasing and researching patient satisfaction, and related purposes.

Your Personal Data, obtained and processed pursuant to applicable legislation, may be kept in Dr. Hüseyin NAZLIKUL's physical archives and/or transferred to computer environments, and retained in both digital and physical form.

CASES IN WHICH EXPLICIT CONSENT IS NOT REQUIRED FOR THE PROCESSING OF PERSONAL DATA:

As a rule, the processing of your health data (SpecialCategoryPersonalData) is prohibited, and it may only be processed on a legal basis or with the consent of the data subject. There are exceptions under which Special Category Personal Data may be processed without the explicit consent of the data subject. In the following cases (KVKK Art. 5 and the Regulation Art. 7), your Personal Data may be processed without explicit consent being required.

• Where explicitly provided for by law,
• Where processing of your Personal Data is mandatory to protect your life or the physical integrity of yourself or another person, in cases where you, as the data subject, are unable to express your consent due to actual impossibility or where your consent is not legally valid,
• Where processing of your Personal Data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract,
• Where processing is mandatory in order to fulfill a legal obligation,
• Where your Personal Data has been made public by you,
• Where processing of data is mandatory for the establishment, exercise, or protection of a right,
• Where processing of data is mandatory for the legitimate interests of Dr. Hüseyin NAZLIKUL, provided that this does not harm your fundamental rights and freedoms
• It may be processed when all protective mechanisms have been established by the State.
• If the data is necessary for the protection of health, medical diagnosis, treatment, or management of health services, it is not prohibited, provided it is processed by persons subject to an obligation of confidentiality.
• In addition, your Special Category Personal Data relating to health and sexual life may only be processed by Dr. Hüseyin NAZLIKUL without seeking explicit consent, for the purposes of protecting public health, preventive medicine, carrying out medical diagnosis, treatment, and care services, and planning and managing health services and their financing.
• Special Category Personal Data of data subjects relating to race, ethnic origin, political opinion, religious or philosophical belief, sect or other beliefs, appearance and dress, membership in associations, foundations, or trade unions may be processed without the explicit consent of the data subject in cases stipulated by law.
• Your Personal Data may be processed without explicit consent being required, in cases where it has been made public by the data subject themselves.

In the processing of special category personal data, if it is determined that the adequate measures specified by the Personal Data Protection Board have not been taken, a decision may be made not to process the data even where the data subject has given explicit consent.

Sincerely,

Dr. Hüseyin NAZLIKUL

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