Information Text Regarding the Processing of Personal Data

PRIVATE DAISY POLYCLINIC

INFORMATION TEXT ON THE PROCESSING OF PERSONAL DATA

This clarification text belongs to the patients/clients applying to the PRIVATE DAİSY POLYCLINIC operating under the ownership of SONGÜL DURUR ZEVZİR, in accordance with  the Personal Data Protection Law No. 6698 ( “KVKK” ) and the European Union General Data Protection Regulation ( “GDPR” ) in the Turkish Legal Legislation. It has been prepared to inform data owners about the procedures and principles regarding the processing of Personal Data.

Ensuring the security of patients’/clients’ Personal Data is one of the primary goals of PRIVATE DAISY POLYCLINIC, owned by SONGÜL DURUR ZEVZİR. For this reason, in order to securely process the Personal Data of patients/clients and prevent any unlawful access or leakage of these data, the necessary security measures are taken by PRIVATE DAISY POLYCLINIC in accordance with the applicable legislation.

DATA CONTROLS

Your Personal Data, within the scope of KVKK No. 6698, “Yenişehir Mah. 33rd St. No:30A İskenderun/Hatay/Türkiye” and “Harbiye Mah. Macka Street. Narmanli Apt. It will be processed by PRIVATE DAİSY POLYCLINIC, owned by SONGÜL DURUR ZEVZİR, operating at the branch address “No: 24 D:14-16 Şişli/İstanbul/Türkiye”. SONGÜL DURUR ZEVZİR ,  with Mersis Number 3370957721400001,  is accepted as “DATA CONTROLLER” within the scope of KVKK  and  “DATA CONTROLLER” within the scope of GDPR.

PRIVATE DAİSY POLYCLINIC SONGÜL DURUR ZEVZİR has made an agreement with a law firm with Personal Data Protection Expertise as the “Data Protection Officer”  within the scope of GDPR, and within the scope of PRIVATE DAİSY POLYCLINIC, the Compliance Process Regarding the Protection of Personal Data Within the scope of KVKK and GDPR, provided that the responsibility for implementation belongs to the Data Controller. was carried out under the consultancy and guidance of an expert law firm.

YOUR PERSONAL DATA TO BE PROCESSED

Your Personal Data specified below will be processed in accordance with the basic principles stipulated in KVKK Article 4 and GDPR Article 5, in line with the Personal Data Processing Conditions and Purposes specified in KVKK Articles 5 and 6 and GDPR Articles 6 and 9, and in this Information Text. Within the scope of the following purposes; It will be processed by PRIVATE DAISY POLYCLINIC in accordance with the law, in connection with the purpose of processing, limited and proportionate, observing the principle of justice and transparency, in an accurate and up-to-date manner, and by taking all kinds of technical and administrative measures stipulated in the legislation in order to ensure data security.

1- YOUR IDENTITY  INFORMATION :  Your name, surname, TR Identity Number and/or Passport Number and/or Temporary TR Identity Number, your identity information, passport information, place and date of birth, marital status, gender, profession, signature and other identity data that can identify you. .

2- YOUR CONTACT INFORMATION :  Your address (residence/workplace), telephone number (your home/workplace fixed and/or mobile phone numbers), your 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 regarding previous surgeries/operations, medications you constantly use, information regarding Covid-19 disease, medical treatments. , your prescription information, skin analysis data, body measurement analysis data, unhealthy habits and other health data required for the treatments and applications to be applied to you.

4- YOUR PHOTOS AND VIDEO IMAGES: Your  image and audio recording data in photographs and/or videos recorded before, during and/or after the medical procedure, and the images recorded by closed-circuit security cameras to ensure workplace safety. your data.

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 round-trip information, hotel accommodation information.

FOR WHAT PURPOSE IS YOUR PERSONAL DATA PROCESSED?

Your Personal Data; To be able to create a patient file, to carry out your examination, medical diagnosis, treatment and care services, to carry out your checks after medical diagnosis and treatment processes, to manage complication processes that may occur, to communicate with you one-on-one, to manage appointment processes, to realize patient satisfaction and demand management, to fulfill legal and contractual obligations. To be able to bring information about your health data that must be kept in accordance with the relevant legislation within the specified periods, to receive consultation services from other relevant specialist physicians when necessary in order to carry out your treatment correctly, to fulfill legal obligations in accordance with the legislation within the scope of health tourism, to transfer patients/clients coming within the scope of health tourism. To be able to plan accommodation and interpreter services, to announce innovations in medical treatment and practices, to inform third parties about the medical procedure applied, to plan and manage health services and financing, to ensure workplace safety, to fulfill the responsibilities arising from the legal relationship established between the doctor and the patient. is processed by PRIVATE DAİSY POLYCLINIC in accordance with KVKK and GDPR, in order to fulfill financial and administrative obligations, ensure technical and commercial security and fulfill public obligations.

Your Personal Data will be processed by ÖZEL DAİSY POLİKLİĞİ within the scope of KVKK and GDPR in the following cases and conditions:

• Your Identity Data;  It will be processed in order to carry out examination, preventive medicine, medical diagnosis, treatment and care services, to create a patient file, to perform patient satisfaction and demand management, and to plan transfer, accommodation and translator services for patients/clients arriving within the framework of Health Tourism.
• Your Contact Information; It will be processed for the purpose of carrying out your checks after medical diagnosis and treatment processes, managing appointment processes, and may also be processed for the purpose of introducing, informing and announcing innovations in medical treatment and practices, and for congratulations and celebrations on special occasions, provided that you give your explicit consent.
• Your Health Information; To be able to successfully carry out your medical treatments and medical aesthetic applications, to receive consultation from another specialist physician if deemed necessary during your treatment process, to create a patient file, to preserve information regarding your health data that must be kept in accordance with the relevant legislation, within the scope of the current Health Law and Health Tourism Legislations. The area will be processed in order to fulfill legal obligations.
• Your Photo, Video and Voice Recording Information; It will be processed by PRIVATE DAISY POLYCLINIC in order to observe and manage the treatment process, to ensure workplace safety, and may also be processed for the purpose of informing third parties about the medical procedure applied to you and for medical promotion, provided that you give your explicit consent.
• Your Financial Data; It will be processed for the purpose of controlling your fee payments and issuing invoices and, in case of any excess fee, for a refund.
• Your Transfer and Accommodation Information;  It will be processed in order to plan the transfer and accommodation services of patients/clients coming within the scope of health tourism.

Your above-mentioned personal data will be processed in line with the above-mentioned purposes and legislation in order to carry out your medical treatment and fulfill the obligations related to your treatment. If you do not provide your relevant personal data, the legal obligations imposed on PRIVATE DAISY POLYCLINIC, which will provide service in your medical treatment, will not be fulfilled properly and your treatment and/or recovery processes will not be carried out successfully.

PERSONAL DATA COLLECTION METHOD

Your Personal Data, depending on the health service provided by PRIVATE DAİSY POLYCLINIC;

• By coming to the PRIVATE DAISY POLYCLINIC for examination and treatment, through your health reports, laboratory and imaging results, analyses, health reports and your statements regarding your health data, so that a medical evaluation can be made regarding the treatment to be applied to you,
• By filling out the “Patient Information and Consent Form” regarding the treatment that PRIVATE DAİSY POLYCLINIC will apply to you,
•  By visiting PRIVATE DAİSY POLYCLINIC’s corporate website  daisypoliklinik.com and by filling out the contact form on this page,
• Via e-mails you send to the corporate e-mail address of PRIVATE DAİSY POLİKLINİĞİ ( info@daisypoliklinik.com ),
• Through photo/video recordings recorded before, after and/or during the medical procedure performed on you at PRIVATE DAISY POLYCLINIC,
• Upon your request and when necessary; In order to be able to diagnose and control you online via remote access by PRIVATE DAİSY POLYCLINIC, you can use remote connection application service providers (whatsapp/zoom.us/facetime/skype/messanger/google/instagram/) from whom you receive service by accepting their Privacy Policies and International Transfer Policies. Through your written/audio/visual (photo and/or video recording) messages you send to PRIVATE DAİSY POLYCLINIC and/or SONGÜL DURUR ZEVZİR or the Polyclinic Responsible Manager Doctor using Facebook etc. and your online audio/video calls you make through these applications,
• PRIVATE DAİSY POLYCLINIC and/or SONGÜL DURUR ZEVZİR’, whose servers are located on social media accounts (instagram, YouTube, Facebook, Twitter, Linkedin, etc.) located abroad, of which you are already a user, by accepting their Privacy Policy and International Transfer Principles. By sending a direct message to the profile accounts of the Polyclinic Responsible Manager Doctor and/or commenting on their posts,
• SONGUL DURUR ZEVZİR and/or PRIVATE DAİSY POLYCLINIC via social media accounts (instagram, youtube, facebook, twitter, linkedin, google, etc.) whose servers are located abroad, of which you are already a user by accepting their Privacy Policy and International Transfer Principles. Through the information you transfer by allowing it to be processed automatically through panels such as ” contact us ” or ” get information ” in the promotions and advertisements of ,
• If you want to join the wireless internet network (wi-fi) available within PRIVATE DAİSY POLYCLINIC as a guest user, through log-recording devices (firewall) used within the scope of technical measures taken in accordance with the legislation,
• Within the scope of the legitimate interests of PRIVATE DAİSY POLYCLINIC, through closed-circuit security cameras that do not have sound recording feature, in order to ensure workplace security,

will be collected and processed in accordance with KVKK and GDPR in order to ensure that PRIVATE DAISY POLYCLINIC can fully and properly fulfill its contractual and legal obligations throughout the examination, medical diagnosis, treatment and care services.

PURPOSE OF PROCESSING YOUR PERSONAL DATA,

METHOD AND LEGAL REASON

Your Personal Data may be processed by real or legal persons authorized by ÖZEL DAİSY POLİKLİĞİ as ” DATA PROCESSOR/PROCESSOR “; It can be processed by taking verbal, written, camera and photographic records, and by keeping physical and electronic records with the necessary technical and administrative security measures, and with your explicit consent in cases stipulated by the relevant provisions of KVKK and GDPR.

SITUATIONS WHERE YOUR EXPRESS CONSENT STATEMENT IS REQUIRED

In accordance with GDPR article 6/1/a and KVKK article 5/1, your Personal Data may be processed in the following cases only with your explicit consent;

• Sending you SMS messages and/or e-mails and establishing mobile communications for the purpose of promoting, announcing and informing you about the innovations regarding the medical services provided by PRIVATE DAİSY POLYCLINIC will only be possible with your express consent.
• Your photo and/or video recordings taken to observe the progress of the treatment before, during and/or after the medical procedure can be shared on the social media accounts (instagram, Instagram, etc.) Sharing on 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 is considered “transfer abroad” and there is an “explicit consent requirement” for transfer abroad, your explicit consent will be obtained in such cases. However,  in the following cases, since there will be no international transfer made by PRIVATE DAISY POLYCLINIC, YOUR EXPRESS CONSENT WILL NOT BE REQUIRED, AND YOUR EXPRESS CONSENT WILL BE OBTAINED BY THE SERVICE PROVIDER OF WHICH YOU ARE THE USER ;

• By accepting its Privacy Agreement and International Transfer Principles and using the service providers whose servers are located abroad (whatsapp/zoom.us/facetime/skype/messanger/google/instagram /facebook etc.) of which you are already a user, you can access PRIVATE DAİSY POLYCLINIC. If you send a written/voice message and/or photo/video recording or make an audio/video call or request to receive remote examination/diagnosis service by contacting yourself in this way; By accepting the policies of the mentioned applications, you have accepted the processing of your Personal Data and Special Qualified Personal Data that you shared with ÖZEL DAİSY POLİKLINİĞİ through these applications, in accordance with the KVK Information Text and Privacy principles that will be communicated to you through the application of ÖZEL DAİSY POLİKLİĞI, and you have accepted these applications whose servers are located abroad. You give explicit consent to the relevant service provider for the transfer of your data abroad in accordance with their policies.
• In cases where you accept its Privacy Policy and International Transfer Policies and request to be contacted via e-mail service providers (Hotmail, Gmail, Yahoo, etc.) whose servers you are currently using are located abroad; You have agreed that ÖZEL DAİSY POLİKLINİĞİ will process your Personal Data and Special Personal Data shared in the messages in line with its KVK Disclosure Text and Privacy principles, and you have given explicit 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. you are counted.
• In cases where you apply for advertisements and promotions of PRIVATE DAİSY POLYCLINIC and/or SONGUL DURUR ZEVZİR published on social media service providers (facebook, Instagram, Google, WhatsApp, etc.) whose servers are located abroad; By accepting the Privacy and International Transfer Policies of the relevant social media service providers, your data that you allow to be automatically processed and transferred abroad will be transferred to ÖZEL DAİSY POLYCLINIC by the relevant social media service provider and will be automatically read by ÖZEL DAİSY POLYCLINIC. It will be processed and stored in accordance with its text and Privacy Policy. In these cases; You accept the Information Text and Privacy Principles of PRIVATE DAİSY POLYCLINIC and the processing of your Personal Data and Special Personal Data accordingly.
• PRIVATE DAİSY POLYCLINIC and/or SONGUL DURUR ZEVZİR’, whose servers are located on social media accounts (instagram, YouTube, Facebook, Twitter, Linkedin, etc.) located abroad, of which you are already a user, by accepting their Privacy Policy and International Transfer Principles. If you send a direct message to e or the profile account of the Polyclinic Responsible Manager Doctor; You agree that ÖZEL DAİSY POLYCLINIC will process your data in accordance with its KVK Disclosure Text and Privacy principles.

SITUATIONS WHERE YOUR DATA MAY BE PROCESSED WITHOUT EXPRESS CONSENT STATEMENT:

In accordance with GDPR article 9/2/h and KVKK article 6/3;

• In order to carry out examination, medical diagnosis, treatment and care services,  your Health Data, which is considered Special Personal Data, will be processed without your explicit consent by PRIVATE DAISY POLYCLINIC and the responsible manager doctor, who are under the obligation of confidentiality  in accordance with the Law.

In accordance with GDPR article 6/1/b and KVKK article 5/2/c;

• Your Personal Data will be processed by PRIVATE DAISY POLYCLINIC, without your explicit consent, in order to carry out your checks after medical diagnosis and treatment processes, to communicate with you one-on-one, and to manage appointment processes.

Based on our legitimate interests in accordance with GDPR article 6/1/f and KVKK article 5/2/f;

• In order to achieve patient satisfaction and demand management, your Personal Data will be processed by PRIVATE DAISY POLYCLINIC without your explicit consent.

Based on legal obligations in accordance with GDPR article 6/1/c, KVKK article 5/2/a and KVKK article 5/2/ç, your Personal Data will be processed without your explicit consent in the following cases;

• Creating a patient file.
• Preserving information regarding your health data that must be kept in accordance with the relevant legislation.
• Checking your fee payments and issuing invoices.
• Execution of tax payments.
• Fulfillment of obligations in accordance with the Ministry of Health Legislation.
• Fulfilling obligations in accordance with Health Tourism Legislation.
• Ensuring your data security.
• Fulfillment of legal obligations before the Judicial Authorities.
• Fulfillment of administrative obligations before Administrative Institutions and Organizations.

TRANSFER OF YOUR PERSONAL DATA AND TO WHOM IT WILL BE TRANSFERRED FOR WHAT PURPOSE

Your Personal Data collected in line with the conditions and purposes within the scope of the Personal Data Processing Conditions specified in Articles 5 and 6 of KVKK No. 6698 and Articles 6 and 9 of GDPR; In accordance with Articles 8 and 9 of KVKK and Articles 45 and 49 of GDPR, PRIVATE DAISY POLYCLINIC carries out and develops examination, medical diagnosis, treatment and care services, receives consultation services from other specialist physicians when necessary, and fulfills administrative obligations regarding health tourism legislation. planning the transfer, accommodation and translator services of patients coming within the scope of health tourism, communicating with patients, managing control appointment processes, planning and managing health services and their financing, fulfilling the responsibilities arising from the legal relationship established between the doctor and the patient, financial, legal and For the purposes of fulfilling administrative obligations, ensuring technical and commercial security and fulfilling public obligations, and promoting the medical services offered; To the extent that it is sufficient to achieve the purpose, it can be transferred to the third parties and institutions listed below by signing the necessary confidentiality agreements and providing all administrative and technical security measures in accordance with the legislation.

In this context, your Personal Data processed by ÖZEL DAİSY POLYCLINIC;

• To other specialist physicians for consultation,
• Insured Employees,
• To its suppliers,
• Financial Advisors, Tax and Finance Consultants and Auditors
• Legal Advisor
• Database (Server) Providers
• “Clinic Management Software Program” Service Providers
• Web Consultant
• translators
• Data Protection Officer
• IT Consultant
• Tourism Agencies
• Public Institutions and Organizations authorized within the framework of the law
• It will be transferred to the Judicial Authorities.

PERSONAL DATA PROCESSING TIME

Your Personal Data will be stored by ÖZEL DAİSY POLİKLİĞİ to the extent and for as long as it is legally obliged to keep it. Documentation and storage obligations arise from local norms regarding trade, tax and health legislation. The table shown below includes the retention periods for your Personal Data.

DATA OWNER AGE LIMIT WITHIN THE FRAMEWORK OF LEGISLATION

Within the scope of KVKK, patients/clients will be able to give personal consent for the processing of their personal data, provided that they are at least 18 years old. Approval of 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/consultants residing in European Union countries can give their consent for the processing of their personal data in person, provided that they are at least 16 years old or the age limit stipulated in their country. Approval of patients/clients under this age must be given by their legal representatives.

WITHDRAWAL OF CONSENT

If you give your consent to PRIVATE DAISY POLYCLINIC regarding the processing of your Personal Data, we hereby inform you that you can withdraw your consent at any time for the purposes stated above, 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 as specified below.

RIGHTS OF DATA SUBJECTS ACCORDING TO GDPR

As a Data Owner, your Personal Data is also protected in accordance with the GDPR. In cases where GDPR falls within the jurisdiction (European Union citizens or residents of European Union countries), the rights of Data Owners are as follows;

• Right of Access (GDPR article 15):  The data owner has the right to confirm by contacting the PRIVATE DAİSY POLYCLINIC whether personal data relating to him/her is being processed or not, and to learn the details in GDPR article 15 in case personal data are processed.
• Right to Correction (GDPR article 16):  The Data Owner has the right to have his or her changed personal data, which is under the responsibility of ÖZEL DAİSY POLYCLINIC, corrected at any time.
• Right to Deletion (GDPR article 17):  The Data Owner has the right to request the deletion of his personal data held by ÖZEL DAİSY POLYCLINIC. If the issues specified in Article 17 of GDPR occur, your personal data will be deleted by PRIVATE DAISY POLYCLINIC without delay.
• Right to Restriction of Processing (Article 18 GDPR):
• If Data Owners object to the up-to-dateness of their Personal Data, they, as the Data Owner, have the right to request the restriction of the use of the data until the accuracy of the Personal Data is confirmed by ÖZEL DAİSY POLİKLINİĞİ.
• 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 his request is fulfilled.
• The Data Owner has the right to request the restriction of the use of his data in cases where his personal data is no longer needed in line with the processing purpose of PRIVATE DAİSY POLYCLINIC.
• In cases where they object to the processing activity in accordance with Article 21/1 of the GDPR, Data Owners have the right to request the restriction of the use of their data until it is verified whether PRIVATE DAİSY POLYCLINIC’s legitimate reasons for data processing outweigh the legitimate reasons of the Data Owner.
• Right to Data Transfer (Article 20 of the GDPR):  The Data Owner has the right to request the transfer of his Personal Data held by PRIVATE DAİSY POLYCLINIC to another controller at any time, if technically possible. However, this right can be exercised when data processing is based on consent or when required by contract.
• Right to Object (Article 21 GDPR):
• The Data Subject has the right to object to processing of Personal Data, including profiling, on grounds relating to his or her particular situation, pursuant to point (e) or (f) of Article 6(1) of the GDPR. PRIVATE DAİSY POLYCLINIC cannot process Personal Data unless it can demonstrate a strong legitimate reason, such as the establishment, exercise or protection of a legal right or over the interests, rights and freedoms of the Data Owner.
• Where Personal Data is processed for direct marketing purposes, the Data Subject has the right to object at any time to processing of his personal data for such purposes, including profiling to the extent that it is related to such direct marketing.
• If the Data Subject 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 that natural persons whose Personal Data are processed have in accordance with Article 11 of the KVKK are as follows;

• Learning whether personal data is processed or not,
• Requesting information if personal data has been processed,
• Learning the purpose of processing personal data and whether they are used for their intended purpose,
• Knowing the third parties to whom personal data is transferred at home or abroad,
• Requesting correction of personal data in case personal data has been processed incompletely or incorrectly and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,
• Requesting the deletion or destruction of personal data in case the reasons requiring processing no longer exist, even though it has been processed in accordance with the provisions of KVKK and other relevant laws, and requesting that the transaction carried out in this context be notified to third parties to whom personal data has been transferred,
• Objecting to the emergence of a result that is unfavorable to the individual by analyzing the processed data exclusively through automatic systems,
• Request compensation for damages in case of damage due to unlawful processing of personal data.

In case you have rights or requests that you want to exercise from the rights listed above; Your written application, in which you clearly and understandably state which of the articles regarding the data subject rights in the GDPR and the rights specified in Article 11 of the KVKK, you wish to use, with wet signature and documents proving your identity, can be posted on the corporate websites of ÖZEL DAİSY POLİKLİĞİ. located in “Yenişehir Mah. 33rd St. No:30A İskenderun/Hatay/Türkiye” or “Harbiye Mah. Macka Street. Narmanli Apt. No: 24 D:14-16 Şişli/İstanbul/Türkiye” branch address and present it personally, send it through a notary public, sign it with a secure e-signature and send it to the e-mail address ” info@daisypoliklinik. com ” or send it by other methods specified in KVKK. . In your applications, your name-surname, signature, TR Identity Number/Passport Number/temporary TR Identity Number, residence or workplace address, e-mail address, telephone and fax number , and the elements subject to the request must be included, in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller” It is mandatory.

PRIVATE DAISY POLYCLINIC will finalize 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 at the tariff determined by the Personal Data Protection Board will be charged.

CONSENT AND APPROVAL

By reading and accepting this Clarification Text, you are fully and completely informed about the data processing process carried out by ÖZEL DAİSY POLİKINİĞİ, that you have learned your rights under the KVKK and GDPR, and that your Personal Data and Special Personal Data are processed by PRIVATE DAİSY POLYCINIC within the scope of this Clarification Text. You are deemed to have accepted, declared and undertaken that you have given your free and free will to the PROCESSING.

You have the right to refuse to accept the Information Text after reading it.

SONGÜL DURUR ZEVZİR reports as “DATA CONTROLLER” within the scope of KVKK and as “CONTROLLER” within the scope of GDPR.

Regards .