Anasayfa

1. INTRODUCTION

DATA CONTROLLER AND REPRESENTATIVE

1. INTRODUCTION

Personal data processing and protection policy

Personal data processing and protection policy

2025-02-18 20:12:06

1. INTRODUCTION

Within the scope of this Personal Data Processing and Protection Policy (“Policy”), the fundamental principles adopted by Istanbul Smile Medical Clinic Inc. in conducting personal data processing activities are explained. This Policy also outlines the compliance of Istanbul Smile Medical Clinic Inc. with the regulations stipulated in the Personal Data Protection Law No. 6698 (“Law”) and informs personal data owners about the principles and legal provisions adopted by our clinic.

With full awareness of our responsibility, your personal data is processed within the framework of this Policy and is reasonably protected.

2. PURPOSE OF THE POLICY

The primary purpose of this Policy is to establish the principles for the lawful processing of personal data by Istanbul Smile Medical Clinic Inc., ensuring transparency by informing and enlightening individuals whose personal data is processed by our clinic.

3. SCOPE OF THE POLICY

This Policy applies to the personal data processed by Istanbul Smile Medical Clinic Inc., including:

  • Principles of processing personal and health-related data,
  • Purposes and conditions for processing such data,
  • Transfer of data within the country and abroad,
  • Deletion and disposal of personal data,
  • Rights of individuals over their processed data.

The relevant procedures and principles regarding these matters are outlined below.

4. ACCESS AND UPDATES

This Policy is published on our clinic’s official website and is made available to data subjects upon request. Updates are made when necessary.

(According to Article 4 of the Personal Data Protection Law No. 6698, the personal data we collect and process must be accurate and up-to-date when necessary. Therefore, in the event of any changes to your personal data, you may update your information using the methods described in the Clarification Text available on our website.)

Our clinic reserves the right to amend this Policy in accordance with legal regulations.In the event of any contradiction between the provisions of the Law and the regulations stated in this Policy, the provisions of the Law shall prevail.

5. DEFINITIONS

The definitions used in this Policy are listed below:

Explicit ConsentConsent that is based on being informed and freely given regarding a specific matter.
AnonymizationMaking personal data unidentifiable in such a way that it cannot be associated with an identified or identifiable natural person, even by matching it with other data.
Personal DataAny information related to an identified or identifiable natural person.
Processing of Personal DataAny operation performed on personal data, whether fully or partially automated or through non-automated means as part of a data recording system. This includes obtaining, recording, storing, preserving, modifying, rearranging, disclosing, transferring, taking over, making it available, classifying, or preventing its use.
KVK LawLaw No. 6698 on the Protection of Personal Data.
KVK BoardThe Personal Data Protection Board.
KVK AuthorityThe Personal Data Protection Authority.
Sensitive Personal DataData related to a person’s race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, clothing, association, foundation, or union membership, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data.
Data SubjectThe natural person whose personal data is processed, referred to as the ‘relevant person’ under the KVK Law.
Data ControllerThe natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
Data ProcessorA natural or legal person who processes personal data on behalf of the data controller based on the authority given by them.
Data Controllers RegistryThe registry of data controllers (VERBİS) maintained under the supervision of the Personal Data Protection Board.
Data InventoryThe inventory created and detailed by Istanbul Smile Medical Clinic Inc., linking its personal data processing activities to business processes, purposes of data processing, the recipient group to which personal data is transferred, and the relevant data subject group.


6. PERSONAL DATA INVENTORY AND CLASSIFICATION OF PERSONAL DATA

At Istanbul Smile Medical Clinic Inc., in line with its legitimate and lawful personal data processing purposes, personal data is processed in compliance with one or more of the data processing conditions specified in Article 5 of the Personal Data Protection Law (KVK Law). This is done in accordance with the general principles outlined in Article 4 of the KVK Law, along with all other legal obligations set forth in the KVK Law. The processing applies to personal data owners covered under this Policy, including but not limited to:

  • Hasta and Service Recipients,
  • Potential Service Recipients,
  • Employees and Job Candidates,
  • Visitors,
  • Supplier Employees and Representatives,
  • Paylaşholders/Partners,
  • Parents/Guardians/Legal Representatives,
  • Employee Relatives,
  • Job Candidate Relatives,
  • Emergency İletişims,
  • Witnesses, Interpreters, Consultants, and Reference Persons.


Personal data is processed to:

  • Fulfill the necessary requirements for the services we provide and enable individuals to benefit from these services.
  • Comply with legal obligations under the Personal Data Protection Law, Fundamental Law on Health Services, Regulation on Personal Health Data, Regulation on Private Healthcare Institutions Providing Outpatient Diagnosis and Treatment, Patient Rights Regulation, and other related regulations.
  • Protect public health, carry out preventive medicine, conduct medical diagnosis, treatment, and care services, and plan and manage healthcare services and their financing.
  • Respond to any questions or complaints related to the healthcare services received.
  • Measure, improve, and research patient satisfaction.
  • Verify identity (including biometric signatures within the scope of explicit consent) and facilitate communication with affiliated institutions regarding healthcare services.
  • Ensure billing and financial reconciliation.
  • Provide information regarding the services received, additional services, and new services.
  • Notify individuals of appointments when a booking is made.
  • Conduct necessary examinations and evaluations related to healthcare services.
  • Fulfill legal obligations regarding information sharing, reporting, and notifications as required by government authorities.
  • Store documents and information as required by applicable legal regulations.
  • Educate and inform other patients and the public, conduct promotional activities, expand service volume, and engage in scientific research and training, based on explicit consent.
  • Monitor the security of patients, visitors, employees, and related third parties via a closed-circuit camera recording system, ensuring legal, technical, and commercial security, preventing criminal activities by third parties, and maintaining the physical security of the company’s buildings and surroundings.

In addition to the above, personal data will be processed in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.


Personal Data Inventory

Istanbul Smile Medical Clinic Inc. has created a personal data inventory in accordance with the Regulation on the Data Controllers Registry, issued by the Personal Data Protection Authority. This inventory includes:

  • Data categories,
  • Data sources,
  • Purposes of data processing,
  • Data processing methods,
  • Recipient groups to which data is transferred,
  • Retention periods of the data.

Within this scope, Istanbul Smile Medical Clinic Inc. processes the following categories of personal data, without being limited to these types:

Identity InformationInformation written on your identity card, including name, surname, Turkish ID or foreign identity number, passport number, mother’s name, father’s name, place of birth, date of birth, marital status, religion, blood type, registered province, district, and neighborhood, as well as any other details written on your identity card.
İletişim InformationCommunication details requested from you or provided by you, such as home phone number, mobile phone number, residence address, other address details, and email address.
Personal RecordsCopies of identity cards, population registry records, residence certificates, health reports, diploma copies, criminal records, passport photos, family status documents, military service status certificates, employment/service contracts, Social Security Institution (SGK) employment entry declarations, criminal records, health-related information and documents.
Professional ExperienceDiploma information, attended courses, in-service training information, certificates, etc.
Bank Account Information (Finance)Bank account number, IBAN number, and other details related to your bank card.
Resume Informa