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Text of the Personal Data Protection Law


CLARIFICATION TEXT ON THE LAW ON THE PROTECTION OF PERSONAL DATA

Inci Group Health Services Inc. and the clinics operating under the İnci brand are Inci Dis Bahcesehir (Bahcesehir Istanbul Smile Dental Polyclinic and Medical Materials Foreign Trade Ltd. Comp.), Inci Basaksehir (Sermizan Health Services Inc.), Inci Levent (Levent Inci Health Services Inc.), Inci Dis Zeytinburnu (Eshat Araz’s Consulting Center) will be able to process your personal data as Data Controller within the scope of the Law No. 6698 on the Protection of Personal Data (“Law”) and the European Union General Data Protection Regulation (“GDPR”) and the relevant legislation, within the framework we explain in detail below.

You can find detailed information about the protection, processing, storage and destruction of your personal data under the heading “Protection and Privacy of Personal Data” on our website.

 

  1. COLLECTION, PROCESSING AND PROCESSING PURPOSES OF PERSONAL DATA

 

  1. COLLECTION OF PERSONAL DATA

 

Inci Group Health Services Inc. and the clinics operating under the İnci brand are Inci Dis Bahcesehir (Bahcesehir Istanbul Smile Dental Polyclinic and Medical Materials Foreign Trade Ltd. Comp.), Inci Basaksehir (Sermizan Health Services Inc.), Inci Levent (Levent Inci Health Services Inc.), Inci Dis Zeytinburnu (Eshat Araz’s Consulting Center) call centre, website, social media channels, sms channels, mobile applications and business/program partner may be collected verbally, in writing or electronically through similar means. The Company may use cookies to provide better services and to adapt the content to individual needs and interests. Disabling cookies in the browser does not prevent the use of services on the website, but may cause some technical problems. Cookies are also used to collect general, statistical information about the user’s use of the website. Our detailed cookie policy is available on our website. Personal data can also be collected from digital media such as company websites, software and applications offered for use via computers or some smart devices, social media accounts activated by persons authorised to provide services on behalf of the company. Within the scope of security camera surveillance activity, the Company aims to increase the quality of the service provided, to ensure its reliability, to ensure the security of our company, customers and other persons and to protect the interests of customers regarding the service they receive. Our detailed disclosure text regarding the camera surveillance activity is available on the website.

 

  1. PROCESSING PERSONAL DATA

 

The Company may process your personal data of private and general nature, especially your health data, for the specified purposes:

Your identity information: Your name, surname, Turkish ID number, passport number or temporary Turkish ID number, place and date of birth, marital status, gender, insurance and/or any other identification data that can identify you;

Your Contact Details: Your address, telephone number, e-mail address and other contact data, your voice call records kept by customer representatives or customer services in accordance with call centre standards, and your personal data obtained when you contact us via e-mail, letter or other means; other personal data you send to us through our communication channels,

Family Members and Relatives Information, children, spouses and identity information of the data subject,

Your Bank Account Information: Your financial data such as your bank account number, IBAN number, credit card information only on the slip, billing and invoice information,

Physical Space Security Information, If you use the car park belonging to our customers, your vehicle registration plate information, visit information, entry and exit information, your images obtained from camera recordings that are constantly recorded in common areas, your voice recording,

Legal Action Information, information requests from judicial and administrative institutions, data resulting from audits and inspections, your other personal data, including your CV provided in this regard if you apply for a job to the Company, and any personal data related to your service contract if you are a company employee or related employee, your data regarding private health insurance for the purpose of financing and planning of health services and your data from the Social Security Institution,

Marketing Information, targeting information that may affect the service, cookie records, surveys filled out by our Customers, thank you and complaint letters, satisfaction results, etc. notifications you make to evaluate,

Personal Data of Special Nature, data on race, health and sexual life, data on criminal convictions and security measures, biometric data, especially the information required to be obtained as required by the service provided or legal legislation.

 

  1. PURPOSES OF PROCESSING PERSONAL DATA

 

Your personal data shared by you;

Carrying out the necessary work, including but not limited to determining and implementing the commercial and business strategies of our Company, carrying out marketing activities, carrying out business development and planning activities, in order to benefit you and/or the institutions and organisations you represent from the products and services offered by our Company,

Ensuring the physical security and supervision of the locations in use by our company,

Establishing business partner/customer/supplier (authorised or employees) relationships,

Ensuring the contractual requirements and financial reconciliation regarding the products and services offered together with our business partners, suppliers or other third parties,

Follow-up of legal and administrative affairs, human resources policies,

It may be processed for the purpose of calling our Company’s call centre or using the website and/or participating in trainings, seminars or organisations organised by our Company.

 

STORAGE OF PERSONAL DATA

 

  1. a) Your personal data will be stored in electronic and/or physical environments. In order to ensure that your personal data provided and stored by our Company are not subject to unauthorised access, manipulation, loss and damage in the environments where they are stored, the design of the necessary business processes and technical security infrastructure developments are implemented.
  2. b) Your personal data will be processed by taking all necessary information security measures, provided that they are not used outside the purposes and scope notified to you, and will be stored and processed for the legal retention period or, if no such period is stipulated, for the period required by the purpose of processing. When this period expires, your personal data will be removed from our Company’s data streams by deletion, destruction or anonymisation methods.
  3. c) The Company adopts the principle of acting in accordance with the law when sharing data with both business and solution partners. Data is shared with business and solution partners with a commitment to data confidentiality and only as much data as required by the service and these parties are obliged to take measures to ensure data security.
  4. d) The Law on the Regulation of Trade Law and the Regulation on Commercial Communication and Commercial Electronic Messages. In accordance with the Regulation on Commercial Communication and Commercial Electronic Messages, electronic messages for advertising purposes may only be sent to persons whose prior consent has been obtained. The consent of the person to whom the advertisement will be sent must be explicitly available. The Company complies with the details of the “consent” determined in accordance with the same legislation. This consent can be obtained in writing in physical environment or by any electronic means of communication.
  5. e) If a contractual relationship has been established with our customers and prospective customers, the personal data collected may be used without the consent of the customer. However, this use is realised in line with the purpose of the contract. On the other hand, the data left to us by our prospective customers (prospective customers) are processed in order to provide them with easier and higher quality service afterwards. These data will be deleted upon request, unless a contractual relationship exists.
  6. f) The data received by our company are processed in the system only to the extent necessary. Excess information is not recorded in the system, deleted or anonymised. These data may be used for statistical purposes.
  7. g) We inform you that your personal data mentioned above can be processed within the framework of the provisions of the Basic Law on Health Services No. 3359, the Decree Law No. 663 on the Organisation and Duties of the Ministry of Health and Affiliated Institutions, the Regulation on Private Hospitals, the Regulation on the Processing of Personal Health Data and the Protection of Privacy and the regulations of the Ministry of Health and other legislation provisions, and can be transferred to the physical archives and information systems of the HOSPITAL and / or our suppliers, and can be kept both in digital and physical environment within the scope of the disclosure obligation of the data controller.

 

  1. TRANSFER OF PERSONAL DATA

 

In accordance with the additional regulations listed in Articles 8 and 9 of the Law and determined by the Personal Data Protection Board, the Company may transfer personal data domestically or abroad if the conditions for transferring personal data are met.

 

Transfer of personal data to third parties at home, your personal data may be transferred by the company in the presence of at least one of the data processing conditions specified in Articles 5 and 6 of the Law and provided that the basic principles regarding the data processing conditions are complied with.

 

Personal data may be transferred to third parties abroad upon the written commitment of the company and the data controller in the relevant country to provide adequate protection, the Personal Data Board’s authorisation of this processing and the existence of at least one of the data processing conditions in Articles 5 and 6 of the Law.

You can obtain the conditions and detailed information regarding the transfer of your personal data from the Personal Data Protection and Processing Policy on our website.