OUR PERSONAL DATA PROTECTION POLICY (PDPP)
A- Introduction:
This PDP Policy is made by Can Hospital Polyclinic and Health Service Trade Ltd. Company (hereinafter referred to as Turkuaz Dental Clinics), which provides health services is a Data Holder in accordance with the Law on Protection of Personal Data (PDPL). Our PDPP has been prepared in accordance with the procedures and principles and our obligations of The Law Numbered 6698 on the Protection of Personal Data (PDPL), Regulation on the Processing of Personal Health Data and Ensuring Privacy, and other relevant legislation.
(* Changes to PDPP: Turkuaz Dental Clinics may make changes in this Policy in accordance with legal regulations. These changes are deemed to have been notified to Data Owner from the moment the Policy is updated and published on our website.)
B- – Purpose and Scope:
We need to collect and keep personal data in order to carry out the health service, which is the main subject of our business, and other commercial relations and service contracts required to provide this service in accordance with the law. Personal data must be collected with the explicit consent of the Data Owner. However by the law or legal regulation, in some conditions, such as public security, public health personal data can be collected without the requirement of explicit consent of Data Owner. Personal data obtained within the scope of PDP Policy, depending on the nature of the relationship established with Turkuaz Dental Clinics includes;
– Employees
– Company Partners
– Employee Candidates
– Patients and Visitors,
– Collaborating Company Partners and Employees,
– Accessing All Kinds of Applications and Services
– Third Parties
C- Definitions:
1-Data Holder:
Data Holder is legally a person who collects, processes, and preserves personal data based on a legitimate reason. In this concept Can Hospital Polyclinic and Health Service Trade Ltd. Company is Data Holder within the scope of PDPL procedures and principles.
The contact information of the Data Holder is as follows:
Address: Bahariye Cad. Sakızgülü Sok. Beyaz Saray Apt. B Blok No: 30 D: 3 Kadıkoy-Istanbul
Phone Number: 0090 (216) 336 42 40
E-mail: info@dentturkuaz.com
Web page: www.dentturkuaz.com
2- Data Owner:
Data Owner is the real person whose personal data is Processed.
3- Definition of Personal Data and Special Categories of Personal Data:
Personal data within the scope of PDPL, is any information regarding an identified or identifiable natural person. Special categories of personel data includes the datas about special nature such as race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing style, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and your biometric and genetic data.
D- Processed Personal and Special Categories of Personal Data:
Depending on the nature of the relationship established with Turkuaz Dental Clinics in order to carry out the health service, which is the main subject of our business, and other commercial relations and service contracts required to provide this service in accordance with the law; We process the data of employees, employee candidates, company partners, patients and visitors, collaborating company partners and employees, accessing all kinds of applications and services we offer, and third parties.
Depending on the definition of the relationship of the Data Owner with Turkuaz Dental Clinics, the personal data is obtained by varies ways in the physical or electronic environment. Personal data is collected for a certain job in a measured and limited manner within a certain relationship definition stated above. Collecting more personal data than the established relationship with Turkuaz Dental Clinics requires is avoided.
The personal data collected in this context is generally listed below:
Identity data such as name, surname, citizenship identity number, passport number, temporary Turkish identity number, place and date of birth, marital status, gender information, and a copy of the submitted identity card or driver’s license, health insurance, profession, insurance card number, workplace registry and / or patient identification number and other identity data that can identify the person, communication data such as address, phone number, e-mail address, financial data such as bank account number, IBAN number, conducting medical diagnosis, treatment and care services including but not limited to medical reports, diagnostic data, biometric and genetic data, laboratory results, x-ray images, test results, examination data, doctor analysis and comments, appointment information, prescription information, any health data obtained during and / or as a result of these, responses and comments obtained for the purpose of evaluating the services, security camera images taken in the polyclinic area, central phone voice call recordings, data on private health insurance for the purpose of financing and planning health services, Social Security Institution data, health data, IP address, cookies and other personal data sent through all websites and online services belonging to the Data Holder, information on the curriculum vitae and application form of the employee candidates, information required by the employment contract of the employees
E- Data Processing Principles:
Personal and special categories of personal data are processed and kept in accordance with the principles of compliance with the law and the rules of honesty, accuracy and currency, processing for specific, clear and legitimate purposes, being related to the purpose for which they are processed, being limited and proportionate, processing as long as required by the legal or processing purpose, complying with the provisions of the legislation in physical and electronic environments.
Special categories of personal data cannot be processed without the express consent of the Data Owner, except provided that the provisions stipulated by the PDPL are reserved. In cases where it is stipulated that special catefories of personal data can be processed by the provisions of the legislation, special quality personal data other than health and sexual life of the relevant person may be processed in accordance with the provision of PDPL.
In terms of Our Clinics, this requirement includes the work and transactions required by the financing and management of the health service; In legal processes such as investigations, litigation, enforcement proceedings arising from legal relations, especially contracts, the submission of personal data of special nature to legal processes, on the condition of being limited and related to the basis of the relevant legal process, by law enforcement authorities, investigation authorities, courts, ex officio or by the parties or It also includes the storage and processing of personal data of special nature collected by third parties for the duration required for legal processes and for the legal processes.
In accordance with the PDPL, the processing of special categories of personal data related to the health and sexual life of the persons is subject to the condition of their express consent, and in the absence of express consent, for the purpose of conducting preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, under the obligation of secrecy. It has been regulated that the personal data in question can be processed by those who are in possession of it.
Personal data and personal data of special nature will be deleted, destroyed or anonymized when the purpose of processing disappears and / or as per legislation expires.
F- Purpose and Legal Reason for Processing Personal Data:
Personal data obtained due to our activities are generally managed in accordance with the law of health services, appointment and treatment processes and reporting to the authorities, especially the Ministry of Health, Health Services Fundamental Law No. 3359, Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates Decree, Private Hospitals Regulation, Law No.6698 on Protection of Personal Data, Regulation on the Processing of Personal Health Data and Ensuring Privacy and other relevant legislation, fulfillment of legal and regulatory requirements, information on your health data that must be kept in accordance with the relevant legislation, conservation, compliance with internal policies and principles, provision of necessary information in line with the demands and inspections of regulatory and supervisory institutions and official authorities, protection of public health, preventive medicine, medical diagnosis, treatment and management of care services, planning and management of health services and financing, planning and managing the internal functioning of the polyclinic and daily operations, polyclinic management, patient rights, patient experience, measuring, increasing and investigating patient satisfaction by quality departments, risk management by information systems departments and performing quality improvement activities, confirming identity, identification and verification in order to prevent the capture of your personal data by others, conducting special projects by promotion, media and communication departments, designing special content and tangible and intangible benefits on web and mobile channels, and transfer of information about our activities or sharing, collecting treatment fees from relevant institutions based on contracts made with private institutions and insurances, issuing invoices, performing treatment fee refund transactions. meeting appointment requests, questions and opinions on internet-based communication platforms, making notification about our services and activities, signing compulsory documents and forms electronically, notifying appointment reminders and changes, warning about the issues to be taken into consideration after the treatment, ensuring the satisfaction of the service User and the service Conducting outsourced services and consultancy services such as communication with patients to renew their processes, collecting opinions and requests, security and social media management, accounting and advocacy units and laboratories, provided identity documents, contact (address, telephone, e-mail) information, signature, prescription, x-ray, technician affairs information, diagnosis and treatment, genetic and medical history, medicine used, anamnesis information, invoice information, private insurance information, bank account information to be refunded, for a limited time within the scope of providing physical space security It is processed to keep security camera records.
G- Obtaining Personal Data:
Personal data is processed in a limited and measured manner in the following processes and in the following ways;
-By the process of applying to our clinics directly or with a legal representative to get health service and in all processes of the health service we provide, by creating the necessary and / or mandatory forms and records for the realization and follow-up of commercial activities related to our business, by the implementation of all kinds of contracts related to our business and establishment of relations with the company owners and employees, by communication channels such as online appointments, feedback forms, cookies, human resources forms open to visitors on our site, notifications left to our e-mails on dentturkuaz.com and message boxes on other social media platforms (such as facebook, instagram, linkedin, twitter), by notifications made through internet based applications and phone calls such as SMS, Whatsapp, Video Call, by notifications from legal authorities, by security cameras
H- Persons and Institutions to Which Personal Data can be Transferred:
We may transfer it to domestic / foreign organizations and other real and / or legal third persons that we receive and / or provide services to, cooperate with, in order to carry out our activities and our legal responsibilities in accordance with PDPL.
I- Clarification Regarding Protection and Processing of Personal Data in accordance with PDPL:
In accordance with the law, if the legal period expires or the purpose and legal reasons requiring the processing and keeping personal information disappear, processed personal data will be deleted, destroyed or anonymized.
İ- Technical and Administrative Measures:
Turkuaz Dental Clinics has taken technical and administrative measures for the protection of personal and special personal data, and the measures taken, the continuity and effectiveness of the measures are checked regularly.
Relations are supported by contracts and certificates, and trainings to raise awareness are given to the staff. Security measures based on multiple stages and restricted powers are preferred.
J- Rights of Personal Data Owner:
Regarding your personal data processed, in accordance with the legislation your rights are;
-To learn whether personal data is processed, to request information if personal data has been processed,
– Accessing and requesting personal health data, learning the purpose of processing personal data and whether they are used appropriately,
– 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 request deletion or destruction of personal data,
– If personal data are processed incompletely or inaccurately, to request the correction and / or deletion or destruction of personal data to third parties to whom personal data have been transferred,
– To object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
– You have the right to demand the compensation of the damage in case of damage due to the illegal processing of your personal data.
K- Submission of Personal Data Information Request Form to Data Holder:
Personal Data Owner, in accordance with Article 11 of the PDPL, can fill in the “Personal Data Information Request Form” and apply to the address of the Data Holder personally and submit the application form by hand or by sending it via a notary public.
Turkuaz Dental Clinics will conclude the request as soon as possible and within thirty days at the latest, depending on the nature of the request, free of charge or against the fee specified by the Personal Data Protection Board. In this case, if the application is caused by our error, the fee received will be refunded.
M- Cases Where Personal Data Can Be Processed Without Explicit Consent According To PDPP:
In accordance with Article 5 of the PDPL and Article 7 of the Regulation, personal data may be processed without your express consent in the following cases:
– In cases clearly stipulated in the laws,
– If you are unable to disclose your consent as a Data Owner due to the actual impossibility, or in cases where your consent is not legally valid,
-if processing of your personal data is necessary to protect of your own or someone else’s life or body integrity,
-If It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,
– If It is mandatory for a legal obligation to be fulfilled,
– If personal data has been made public by the Data Owner,
– If processing of personal data is mandatory for the establishment, use or protection of a right,
– If data processing is mandatory for the legitimate interests of the Data Holder, provided that it does not harm the fundamental rights and freedoms of the data Owner,
Personal health data may be processed without the express consent of the person under the obligation of authorized institutions and organizations for the purpose of protecting public health, managing and financing health services.