CLARIFICATION INFORMATION TEXT ON THE PROCESSING OF PERSONAL DATA

This clarification text has been prepared by OP:  DR . It has been prepared to inform data owners about the procedures and principles regarding the processing of personal data of patients/clients applying to  (“OP. DR. Emre Gönen”) .

Ensuring the security of patients/clients’ personal data OP. DR. It is one of the primary targets of Emre Gönen. For this reason, in order to securely process the personal data of patients/clients and prevent any unlawful access or leakage of these data, necessary security measures are taken in accordance with the applicable legislation. DR. It is taken by Emre Gönen.

DATA CONTROLLER

Your Personal Data, within the scope of KVKK No. 6698, “Harbiye, Teşvikiye Cd. No:37 Daire:4, 34365 Şişli, İstanbul / Turkey. DR. It will be processed by Emre Gönen OFFICE. OP., registered at Şişli Tax Office, Tax Identification No. 4080156331. Emre Gönen is accepted as a “DATA CONTROLLER” within the scope of KVKK and a “DATA CONTROLLER” within the scope of GDPR .

YOUR PERSONAL DATA TO BE PROCESSED

Your personal data and special categories of 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 within the scope of the purposes stated in this Information Text; 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, by taking all kinds of technical and administrative measures foreseen in the legislation to ensure data security, OP. DR. It will be processed by Emre Gönen.

  1. YOUR IDENTITY INFORMATION: Your name, surname, TR ID number and/or passport number and/or temporary TR ID number, ID information, passport information, place and date of birth, marital status, gender, profession, signature and other identification data that can identify you.
  2. YOUR CONTACT INFORMATION: Your address (residence/workplace), telephone number (your home/workplace fixed and/or mobile telephone numbers you have declared), 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, prescriptions. your information, your hormonal information, your sexual life information, your body analysis and measurement information, your skin analysis information, your harmful habits and other health data required for the treatments and applications to be applied to you.
  4. YOUR PHOTO/VIDEO IMAGES AND AUDIO DATA: Your image and audio recording data contained in photographs and/or videos recorded before, during and/or after the medical procedure.
  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 examination, preventive medicine, medical diagnosis, treatment, medical applications 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 perform patient satisfaction and demand management. To be able to fulfill legal and contractual obligations, to preserve information regarding 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 International Health Tourism, Health To be able to plan the transfer, accommodation and translator services of Health Tourist patients/clients coming within the framework of tourism, to announce innovations regarding medical treatment and practices, to inform third parties about the medical services offered within the framework of Health Tourism Legislation, to plan and manage health services and their financing, to be able to plan and manage the health services and financing established between the doctor and the patient. In order to fulfill the responsibilities arising from legal relations, to fulfill financial and administrative obligations, to ensure technical and commercial security and to fulfill public obligations, in accordance with KVKK and GDPR, OP. DR. It is processed by Emre Gönen. Your Personal Data, OPin the following situations and conditions. DR. It will be processed by Emre Gönen within the scope of KVKK and GDPR:

  1. Your Identity Data; It will be processed in order to carry out examination, preventive medicine, medical diagnosis, treatment, medical applications and care services, to create a patient file, to carry out patient satisfaction and demand management, and to plan the transfer, accommodation and translator services of Health Tourist patients/clients within the framework of Health Tourism.
  2. 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.
  3. Your Health Information; To be able to carry out your medical treatments successfully, to receive consultation from another specialist physician if deemed necessary during your treatment process, to create a patient file, to preserve the information regarding your health data that must be kept in accordance with the relevant legislation within the period, to fulfill the legal obligations within the scope of the current Health Law and Health Tourism Legislations. will be processed in order to bring
  4. Your Photo, Video and Voice Recording Information; OP. DR. It will be processed by Emre Gönen in order to observe and manage the treatment process, and also, provided that you give your explicit consent, it may be processed in order to medically inform foreigners who want to receive health services in our country within the framework of Health Tourism Legislation, about the medical procedure applied to you.
  5. 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.
  6. Your Transfer and Accommodation Information ; It will be processed in order to plan the transfer and accommodation services of Health Tourist patients/clients within the framework 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, OPwill provide service in your medical treatment. DR. The legal obligations imposed on Emre Gönen 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 and Special Personal Data, OP. DR. Depending on the health service provided by Emre Gönen;

  1. For examination and treatment purposes, OP. DR. By coming to Emre Gönen and providing medical evaluation regarding the treatment to be applied to you, through your health reports, laboratory and imaging results, analyses, health reports and your statements regarding your health data and examination findings,
  2. OP. DR. By filling out the “Patient Information and Consent Form” regarding the treatment to be applied by Emre Gönen,
  3. OP. DR. Through the contact form you fill out on Emre Gönen’s corporate website “www.emregonen.com.tr”,
  4. OP. DR. Through e-mails sent to the corporate e-mail address of Emre Gönen ” iletisim@emregonen.com.tr “,
  5. OP. DR. Through photo/video recordings recorded before, after and/or during the medical procedure that Emre Gönen applied/will apply to you,
  6. Upon your request and when necessary; OP. DR. In order for Emre Gönen to diagnose and control you online via remote access, 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. facebook/bip/telegram/clubhouse etc.) using OP. DR. Through your written/audio/visual (photo and/or video recording) messages you send to Emre Gönen and your online audio/video calls you make through these applications,
  7. OP, which is located on social media accounts (instagram/youtube/facebook/twitter/linkedin/clubhouse etc.) whose servers are located abroad, of which you are already a user by accepting their Privacy Policies and International Transfer Policies. DR. By sending a direct message to the profile account of Emre Gönen and/or commenting on his posts,
  8. OPthrough 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 Policies and International Transfer Policies. DR. 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 information provided by Emre Gönen,
  9. OP. DR. If you want to join the wireless internet network (wi-fi) available in Emre Gönen’s practice as a guest user, through log-recording devices (firewall) used within the scope of technical measures taken in accordance with the legislation,

will be collected and OP. will be provided throughout the examination, medical diagnosis, treatment and care services. DR. It will be processed in accordance with KVKK and GDPR in order for Emre Gönen to fully and properly fulfill its contractual and legal obligations.

PURPOSE, METHOD AND LEGAL REASON FOR PROCESSING YOUR PERSONAL DATA

Your Personal Data, OP. DR. By real or legal persons authorized by Emre Gönen  in the capacity of “DATA PROCESSOR/PROCESSOR”  ; It can be recorded physically and electronically, along with the necessary technical and administrative security measures, by taking verbal, written, camera and photographic records, and can be processed, provided that your explicit consent is obtained, 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;

  1. OP. DR. Sending you SMS messages and/or e-mails and establishing mobile communication in order to promote, announce and inform you about the innovations regarding the medical services provided by Emre Gönen will only be possible with your express consent.
  2. OP. DR. Sharing on Emre Gönen’s social media accounts (instagram, YouTube, Facebook, Twitter, Linkedin, Clubhouse, etc.) and corporate websites will only be possible with your explicit consent.
  3. 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 OP. DR. Since there will be no international transfer made by Emre Gönen, YOUR EXPRESS CONSENT WILL NOT BE REQUIRED, YOUR EXPRESS CONSENT WILL BE DEEMED TO BE RECEIVED BY THE SERVICE PROVIDER OF WHICH YOU ARE THE USER;

  • By using service providers whose servers are located abroad (whatsapp/zoom.us/facetime/skype/messanger/google/instagram/facebook/telegram/clubhouse etc.) of which you are already a user by accepting its Privacy Agreement and International Transfer Principles, OP. DR. If you send a written/voice message and/or photo/video recording or make an audio/video call to Emre Gönen and request to receive remote examination/diagnosis service in this way; By accepting the policies of the mentioned applications, OPthrough these applications. DR. Your Personal Data and Special Personal Data that you shared with Emre Gönen, OP. DR. You are deemed to have accepted the processing of Emre Gönen in accordance with this KVK Disclosure Text and Privacy principles, you have consented to be contacted through these applications, and you have given explicit consent to the said applications to transfer your data abroad in accordance with the policies you have previously accepted of these applications whose servers are located abroad. .
  • In cases where you accept its Privacy Policy and International Transfer Principles and request to be contacted via e-mail service providers (Hotmail, Gmail, Yahoo, etc.) whose servers you are currently using are located abroad; OP. DR. You are deemed to have given your explicit consent for Emre Gönen to process your Personal Data and Special Personal Data shared in the messages in line with its KVK Disclosure Text and Privacy principles, and for your data to be transferred abroad by your e-mail service provider in accordance with the policies you have previously accepted of these service providers whose servers are located abroad. .
  • OP. DR. In cases where you apply for Emre Gönen’s advertisements and promotions 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 OPby the relevant social media service provider. DR. It will be transferred to Emre Gönen and OP. DR. It will be processed and stored by Emre Gönen in accordance with its Information Text and Privacy Policy that you are reading. In these cases; OP. DR. With the Information Text of Emre Gönen, you have accepted the Privacy Principles and the processing of your Personal Data and Special Personal Data accordingly, and you can contact OPthrough your contact information provided. DR. You are deemed to have given your express consent for Emre Gönen to reach you and communicate with you.
  • OP, which is located on social media accounts (instagram, youtube, facebook, twitter, linkedin, etc.) whose servers are located abroad, of which you have already become a user by accepting their Privacy Policies and International Transfer Policies. DR. If you send a direct message to the profile account of Emre Gönen; OP. DR. You are deemed to have accepted that Emre Gönen will process your data in accordance with its KVK Disclosure Text and Privacy principles, and you have given explicit consent to be contacted through the relevant application.

SITUATIONS WHERE YOUR DATA MAY BE PROCESSED WITHOUT EXPRESS CONSENT STATEMENT

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

  • OP, who is under the obligation of confidentiality in accordance with the Law, in order to carry out examination, medical diagnosis, treatment and care services. DR. Your Health Data, which is considered Special Personal Data, will be processed by Emre Gönen without your explicit consent.

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

  • In order to be able to carry out your checks after medical diagnosis and treatment processes, to communicate with you one-on-one, and to manage appointment processes, OP. DR. Your Personal Data will be processed by Emre Gönen without your explicit consent.

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, OP. DR. Your Personal Data will be processed by Emre Gönen 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 the KVKK and Articles 45 and 49 of the GDPR, OP. DR. Emre Gönen carries out and develops examination, preventive medicine, medical diagnosis, treatment and care services, receives consultation services from other specialist physicians when necessary, fulfills the administrative obligations regarding the International Health Tourism Legislation, provides transfer, accommodation and translator services for Health Tourist patients arriving within the framework of Health Tourism. planning services, communicating with patients, managing control appointment processes, planning and managing health services and their financing, fulfilling responsibilities arising from the legal relationship established between doctor and patient, fulfilling financial, legal and administrative obligations, ensuring technical and commercial security and public obligations. For the purpose of fulfilling and promoting the medical services offered to foreign people who want to come to our country as Health Tourists within the framework of Health Tourism Legislation; may be transferred to third parties and institutions to the extent necessary to achieve the purpose, by concluding Confidentiality Agreements stipulated by the legislation and by providing all necessary administrative and technical security measures. In this context, OP. DR. Your Personal Data processed by Emre Gönen;

  1. To other specialist physicians for consultation,
  2. Insured Employees,
  3. To its suppliers,
    • Financial Advisors, Tax and Finance Consultants and Auditors
    • Legal Advisor
    • Database (Server) Providers
    • translators
    • Web Consultant
    • Data Protection Officer
    • IT Consultant
    • Tourism Agencies
  4. Public Institutions and Organizations authorized within the framework of the law,
  5. It can be transferred to Judicial Authorities.

PERSONAL DATA PROCESSING TIME

Your Personal Data, OP. DR. It will be kept by Emre Gönen 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.

YOUR PERSONAL DATASTORAGE PERIOD
Your Identity Information20 Years After the Termination of the Service Provided to the Service Receiver
Your Contact Information20 Years After the Termination of the Service Provided to the Service Receiver
Your Health Information20 Years After the Termination of the Service Provided to the Service Receiver
Your Photo and Video Information20 Years After the Termination of the Service Provided to the Service Receiver
Your Financial Information5 Years After the Termination of the Service Provided to the Service Receiver

DATA OWNER AGE LIMIT WITHIN THE FRAMEWORK OF LEGISLATION

Within the scope of KVKK, patients/clients will be able to personally give 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

PROPF regarding the processing of your Personal Data. DR. If you give your consent to Emre Gönen, we 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 stated 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 can check whether personal data concerning him/her is being processed or not. DR. He/she has the right to confirm by contacting Emre Gönen and to learn the details in GDPR article 15 in case personal data is processed.
  • Right to Rectification (Article 16 GDPR): Data Owner, OP. DR. Emre Gönen has the right to have its changed personal data corrected at any time.
  • Right to Erasure (Article 17 GDPR): Data Owner, OP. DR. Emre Gönen has the right to request the deletion of his personal data. If the matters specified in Article 17 of the GDPR occur, OP. DR. Your personal data will be deleted by Emre Gönen without any delay.
  • Right to Restriction of Processing (Article 18 GDPR):
    • If Data Owners object to the up-to-dateness of their Personal Data, OP. DR. As the Data Owner, they have the right to request the restriction of the use of the data until the accuracy of the Personal Data is confirmed by Emre Gönen.
    • 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.
    • Data Owner, OP. DR. Emre Gönen has the right to request the restriction of the use of his data in cases where his personal data is no longer needed for the purpose of processing.
    • In cases where Data Subjects object to processing pursuant to Article 21/1 of the GDPR, OP. DR. They have the right to request the restriction of the use of their data until it is verified whether Emre Gönen’s legitimate reasons for processing data outweigh the legitimate reasons of the Data Owner.
  • Right to Data Portability (Article 20 GDPR): Data Owner, if technically possible, OP. DR. Emre Gönen has the right to request the transfer of its Personal Data to another controller at any time. 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. OP. DR. Emre Gönen cannot process Personal Data unless it can demonstrate a strong legitimate reason, such as overriding the interests, rights and freedoms of the Data Owner or the establishment, exercise or protection of a legal right.
  • 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; Submit your written application, in which you clearly and understandably state which of the articles regarding data subject rights in the GDPR and the rights specified in Article 11 of the KVKK, that you wish to use, with a wet signature and documents proving your identity, to OP. DR. Emre Gönen’s, “Harbiye, Teşvikiye Cd. No:37 Daire:4, 34365 Şişli, İstanbul Türkiye” Your Personal Data, within the scope of KVKK No. 6698, “Harbiye, Teşvikiye Cd. No:37 Daire:4, 34365 Şişli, İstanbul / Turkey. DR. It will be processed by Emre Gönen OFFICE. OP., registered at Şişli Tax Office, Tax Identification No. 4080156331. Emre Gönen is accepted as a “DATA CONTROLLER” within the scope of KVKK and a “DATA CONTROLLER” within the scope of GDPR 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 “iletisim@emregonen.com.tr” or other methods specified in the KVKK . You can send via . In your applications, your name-surname, signature, TR ID number/passport number/temporary TR ID number, residence or workplace address, e-mail address, telephone and fax number, and the requested elements must be included in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller” It is mandatory. OP. DR. Emre Gönen at the tariff determined by the Personal Data Protection Board will be charged.

CONSENT AND APPROVAL

When you read and accept this Information Text, OP. DR. You hereby declare that you have full and complete information about the data processing process carried out by Emre Gönen, that you have learned your rights under the KVKK and GDPR, and that your Personal Data and Special Personal Data are processed by OPwithin the scope of this Information Text. DR. You are deemed to have accepted, declared and undertaken that you have given your free and free will to the PROCESSING by Emre Gönen.

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

OP. DR. Emre Gönen reports as “DATA CONTROLLER” within the scope of KVKK and as “CONTROLLER” within the scope of GDPR.

Regards.