Clarification Text

DISCLOSURE TEXT ON THE PROCESSING OF PERSONAL DATA

This Clarification Text has been prepared for the purpose of informing data subjects about the procedures and principles regarding the processing of Personal Data of patients/consultants who apply to Etya Turizm Egitim Hizmetleri Ticaret Limited Sirketi ("ETYA") in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK"), the European Union General Data Protection Regulation ("GDPR"), the Regulation on Personal Health Data and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform.

Ensuring the security of the Personal Data of patients/consultants is one of the primary objectives of Etya. For this reason, all necessary security measures are taken by Rtya in accordance with the applicable legislation in order to process the Personal Data of patients/consultants securely and to prevent any unlawful access or leakage of such data.

  • DATA RESPONSIBLE

Your Personal Data will be processed by "Etya Turizm Egitim Hizmetleri Ticaret Limited Sirketi" within the scope of KVKK numbered 6698 and GDPR. Etya Turizm Egitim Hizmetleri Ticaret Limited Sirketi, registered at Turkey, Istanbul, Esenyurt, Piri Reis Mahallesi, 2281 Sokak, 13/97, Esenyurt Tax Office 3810431640 Tax No. Etya Turizm Egitim Hizmetleri Ticaret Limited Sirketi is considered as "Data Controller" within the scope of KVKK and "Controller" within the scope of GDPR.

  • YOUR PERSONAL DATA TO BE PROCESSED

Your personal data that we process in the capacity of data controller for the following purposes;

  • Your Identity Information:Your name, surname, Turkish ID Number and/or Passport Number and/or Temporary Turkish ID Number, place and date of birth, marital status, gender, occupation, signature and other identification data that can identify you.
  • Your Contact Information: Your address (residence/workplace), telephone number (your home/workplace fixed and/or mobile telephone numbers you have notified), e-mail address, social media accounts and other communication data.
  • Your Health Data:In order to make a medical evaluation regarding the treatment to be applied to you by coming to Etya and its Partners for medical application purposes
  • Your Photo/Video Images and Audio Data: Your image and audio data contained in photographs and/or videos recorded before, during and/or after the medical procedure, as well as your video image data and audio recording data obtained from cameras that are under 24/7 closed recording in our office and treatment centers.
  • Your Financial Information:Your bank account number, IBAN number, credit card information, billing and invoice information and other financial data.
  • 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.

  • PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your Personal Data and Sensitive Personal Data; To be able to carry out your post-operative care services, to carry out your controls after medical application, treatment and operation processes, to carry out complication processes that may occur, to communicate with you one-on-one, to manage appointment processes, to manage patient satisfaction and demand management, to fulfill legal and contractual obligations, to keep the information regarding your health data that must be kept in accordance with the relevant legislation within the specified periods, işyeri güvenliğini sağlayabilmek, Uluslararası Sağlık Turizmi kapsamındaki mevzuata uygun olarak yasal yükümlülükleri yerine getirebilmek, Uluslararası Sağlık Turizmi çerçevesinde gelen Sağlık Turisti hastaların/danışanların transfer, konaklama ve tercüman hizmetlerini planlayabilmek, tıbbi tedavi ve uygulamalara ilişkin yenilikleri duyurabilmek, uygulanan tıbbi işlemler/operasyonlar hakkında 3. To be able to inform third parties medically, to carry out promotional and marketing activities regarding medical applications/operations applied within the framework of International Health Tourism Incentive legislation, to plan and manage health services and financing, to fulfill the responsibilities arising from the legal relationship established between the doctor and the patient, to fulfill financial and administrative obligations, to ensure technical security and to fulfill public obligations, in accordance with KVKK and GDPR.

Your Personal Data and Sensitive Personal Data will be processed by Etya within the scope of KVKK and GDPR in the following situations and conditions:

  • Your Identity Datawill be processed in order to carry out treatment/post-operative care services, to create a patient file, to realize patient satisfaction and demand management, to plan transfer, accommodation and interpreter services of incoming Health Tourist patients/consultants within the framework of International Health Tourism.
  • Your Contact Informationwill be processed in order to carry out your controls after treatment and operation processes, to manage appointment processes, and may also be processed for the purpose of promoting, informing and announcing innovations regarding medical treatment and applications, provided that you give your explicit consent.
  • Your Health Informationwill be processed in order to create a patient file, to keep the information regarding your health data that must be kept in accordance with the relevant legislation within the period, and to fulfill the legal obligations under the applicable Health Law and International Health Tourism Legislation.
  • Your Photograph, Video and Voice Recording Informationwill be processed by Etya in order to observe and manage the treatment and/or operation process, to ensure the safety of the practice and also, provided that you give your explicit consent, to inform third parties about the medical procedure/procedures applied to you, to manage promotional and marketing activities in accordance with the International Health Tourism Promotion legislation.
  • Your Financial Datawill be processed for the purpose of checking your fee payments, issuing invoices and refunding any excess fees.
  • Your Transfer and Accommodation Informationwill be processed in order to plan the transfer and accommodation services of Health Tourist patients/consultants coming within the framework of International Health Tourism.

Your Personal Data and Sensitive Personal Data mentioned above will be processed for the purposes and in accordance with the legislation stated above in order to carry out your medical treatment/operation and to fulfill the obligations regarding the medical service provided. If you do not provide your relevant personal data, the legal obligations imposed on Etya, which will provide services in your medical treatment and/or operation, will not be fulfilled properly, and your operation, treatment and recovery processes will not be carried out successfully.

  • METHOD AND LEGAL REASONS FOR COLLECTING YOUR DATA

Your Personal Data, by real or legal persons authorized by Etya "DATA PROCESSOR/PROCESSOR" In the capacity of; verbal, written, camera and photographic recordings may be processed by taking verbal, written, camera and photographic recordings, by keeping records in physical and electronic media together with all technical and administrative security measures required by the legislation, and by obtaining your explicit consent in cases stipulated by the relevant provisions of KVKK and GDPR.

Where your explicit consent is required;

Pursuant to Article 6/1/a of the GDPR and Article 5/1 of the LPPD, your Personal Data may be processed only with your explicit consent in the following cases;

  • In order to promote, announce and inform you about the innovations regarding the services provided by Etya, it will be possible to send sms messages and / or e-mails to you and to establish mobile communication only with your explicit consent.
  • It will be possible to share your photographs and/or video recordings taken before, during and/or after the medical procedure in order to observe the development of the treatment on Etya's social media user accounts (instagram, youtube, facebook, twitter, linkedin, google etc.) and corporate websites only with your explicit consent.
  • Since sharing your data through service providers whose servers are located abroad will be considered as "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, your explicit consent will not be sought as there will be no overseas transfer made by Etya, and your explicit consent will be deemed to have been obtained by the service provider you are using;
  • If you send written/voice messages and/or photo/video recordings or make audio/video calls to Etya by using the service providers (whatsapp/zoom.us/facetime/skype/messanger/google/instagram /facebook etc.) whose servers are located abroad, of which you are already a user by accepting the Confidentiality Agreement and Overseas Transfer Principles.In case you send written/voice messages and/or photos/video recordings to Etya or make audio/video calls and request to receive remote examination/diagnosis services in this way; By accepting the policies of the aforementioned applications, you have accepted the processing of your Personal Data and Special Qualified Personal Data that you share with Etya through these applications in accordance with Etya's KVK Clarification Text and Privacy principles, you have consented to contact you through the aforementioned applications and you are deemed to have given explicit consent to the aforementioned applications for the transfer of your data abroad in accordance with the policies of these applications whose servers are located abroad that you have previously accepted.
  • In cases where you request to be contacted via electronic mail service providers (Hotmail, gmail, yahoo, etc.) whose servers are located abroad, of which you are currently a user by accepting its own Privacy Policy and Overseas Transfer Principles; You are deemed to have given explicit consent to Etya's processing of your Personal Data and Sensitive Personal Data shared in the messages in accordance with its own KVK Clarification Text and Privacy principles and to the transfer of your data abroad in accordance with the policies of these service providers whose servers are located abroad, which you have previously accepted.
  • In cases where you apply for Etya's advertisements and promotions published on social media service providers (facebook, instagram, youtube, Google, whatsapp, etc.) whose servers are located abroad; your data that you allow to be automatically processed and transferred abroad by accepting the Privacy and Overseas Transfer Principles of the relevant social media service providers will be transferred to ........... by the relevant social media service provider and will be processed and stored by Etya in accordance with its own Clarification Text and Privacy Principles that you have read. In these cases; You are deemed to have accepted Etya's Clarification Text and Privacy Principles and the processing of your Personal Data and Special Qualified Personal Data in this direction, and you are deemed to have given explicit consent for Etya to reach you and contact you via your contact information you have provided.
  • In case you send a direct message to Etya's profile account on social media accounts (instagram, youtube, facebook, twitter, linkedin, etc.) whose server is located abroad, of which you are already a user by accepting their Privacy Policies and Overseas Transfer Principles; Etya will use your data in accordance with its own KVK Clarification Text and
  • You are deemed to have given your explicit consent to its processing in accordance with the privacy principles and to contact you through the relevant application.

Situations where your data can be processed without explicit consent;

Based on our legitimate interests pursuant to Article 6/1/f GDPR and Article 5/2/f KVKK;

  • In order to ensure the security of the practice, patient satisfaction and demand management, Etya will process your Personal Data without seeking your explicit consent.

Pursuant to the legal and statutory obligations under Article 6/1/c of the GDPR, Article 5/2/a and Article 5/2/ç of the KVKK, your Personal Data will be processed without your explicit consent in the following cases;

  • Creating a patient file.
  • Maintaining information about your health data that must be kept in accordance with the relevant legislation.
  • Checking your wage payments and issuing invoices.
  • Fulfillment of tax payments.
  • Fulfillment of obligations in accordance with the Ministry of Health Legislation.
  • Fulfillment of obligations under the International Health Tourism Legislation.
  • Ensuring your data security.
  • Fulfillment of legal obligations before the Judicial Authorities.
  • Performing administrative obligations before Administrative Institutions and Organizations.
  • PERSONS/ORGANIZATIONS TO WHICH PERSONAL DATA MAY BE TRANSFERRED FOR THE ABOVE-MENTIONED PURPOSES

Your Personal Data and Sensitive Personal Data collected in accordance 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. In accordance with Articles 8 and 9 of the KVKK and Articles 45 and 49 of the GDPR, Etya carries out and develops medical practice, post-operative care services, obtaining consultation services from a specialist physician / physicians when necessary, fulfilling administrative obligations regarding International Health Tourism legislation, planning transfer, accommodation and interpreter services of Health Tourist patients coming within the framework of International Health Tourism, for the purposes of communicating with patients, planning and managing health services and financing, managing promotional and marketing activities in accordance with the International Health Tourism Incentive legislation, fulfilling the responsibilities arising from the legal relationship established between the doctor and the patient, fulfilling financial, legal and administrative obligations, ensuring technical security and fulfilling public obligations; To the extent sufficient for the realization of the purpose, by signing the necessary confidentiality agreements, by providing all administrative and technical security measures in accordance with the legislation, to the following 3. persons and organizations. In this context, your Personal Data processed by Etya;

  • Insured Employees,
  • Private Hospitals
  • Other specialists for consultation purposes,
  • Suppliers,
  • Financial Advisors, Tax and Financial Consultants and Auditors
  • Legal Advisor
  • Interpreters
  • Overseas Promotion Marketing Consultant
  • IT Consultant
  • WEB Consultant
  • "Clinic Management Software Program" Service Provider
  • Database (Server) Providers
  • Public Institutions and Organizations authorized under the laws,
  • It will be transferred to the Judicial Authorities.
  • Storage and Destruction of Your Personal Data

Our Company stores your personal data processed in accordance with the law in a proportionate manner for the purpose of processing. Personal data are stored until the end of the period required by the relevant legislation in case the purpose and/or reason for processing has disappeared. When the purpose and reason for processing your personal data is no longer valid, they will be destroyed when the statute of limitations required for the fulfillment of our obligations arising from the law is completed.

The table below shows the retention periods of your Personal Data.

Your Personal Data

Storage Periods

Your Identity Information

10 Years after the Termination of the Service Provided to the Service Recipient

Contact Information

10 Years after the Termination of the Service Provided to the Service Recipient

Health Information

1 year after the end of the service provided to the service recipient

Your Photo and Video Information

2 years

Financial Information

5 Years after the Termination of the Service Provided to the Service Recipient

  • AGE LIMIT FOR CONSENT OF THE DATA SUBJECT

Within the scope of the LPPD, patients/consultants will be able to personally give consent for the processing of their personal data provided that they are at least 18 years old. Consents of patients/consultants below this age limit must be given by their legal representatives.

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

  • WITHDRAWAL OF CONSENT

In case you give consent to Etya regarding the processing of your Personal Data, 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 your consent to our contact address specified below as stated below.

  • YOUR RIGHTS UNDER THE GDPR

As a Data Subject, your Personal Data is also protected under the GDPR. The rights of Data Subjects (citizens of the European Union or residents of European Union countries) where they fall under the jurisdiction of the GDPR are as follows;

  • Right of Access (Article 15 of the GDPR):The data subject has the right to confirm whether personal data about him/her is being processed by applying to Etya and to learn the details in Article 15 of the GDPR if personal data is processed.
  • Right to Correction (GDPR Article 16):The Data Owner has the right to have his/her personal data, which are under the possession of Etya and which have changed, corrected by applying at any time.
  • Right to Erasure (GDPR Article 17):The Data Subject has the right to request the erasure of his/her personal data held by Etya. If the matters specified in Article 17 of the GDPR occur, Etya will delete your personal data without delay.
  • Right to Restriction of Processing (Art. 18 GDPR):In the event that Data Subjects object to the timeliness of their Personal Data, Data Subjects have the right to request restriction of the use of their data until the accuracy of the Personal Data is confirmed by Etya. In cases where the Data Subject requests the deletion of Personal Data due to the illegality of the Personal Data processing activity, the Data Subject has the right to request restriction of the use of the data until the request is realized. The Data Subject has the right to request restriction of the use of his/her data in cases where Etya no longer needs his/her personal data for the purpose of processing. Where Data Subjects object to processing pursuant to Article 21/1 GDPR, they have the right to request restriction of the use of their data until it is verified whether Etya's legitimate grounds for processing outweigh the Data Subject's legitimate grounds.
  • Right to Data Portability (GDPR Article 20):The Data Subject has the right to request the transfer of his/her Personal Data held by Etya to another controller at any time, if technically feasible. However, this right may be exercised when data processing is based on consent or when required by the contract.
  • Right to Object (Art. 21 GDPR): The Data Subject has the right to object to the processing of personal data, including profiling, on grounds relating to his or her particular situation, under subparagraphs (e) or (f) of Article 6(1) of the GDPR. Etya may not process personal data unless it can demonstrate a strong legitimate ground, such as the establishment, exercise or protection of a legal right or overriding the interests, rights and freedoms of the Data Subject. Where the Data Subject's Personal Data is processed for direct marketing purposes, the Data Subject has the right to object at any time to the processing of his/her personal data for this purpose, 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.
  • YOUR RIGHTS UNDER ARTICLE 11 OF THE KVKK

Data subjects must first apply to the data controller in order to exercise their rights regarding their personal data. According to Article 14/2 of the LPPD, a complaint cannot be filed with the Board without first applying to the data controller.

Your personal data by applying to our company,

  • Find out if it is being processed,
  • Do not request information if processed,
  • Learn the purpose of processing and whether it is used for its intended purpose,
  • Knowing the third parties to whom it is transferred domestically / abroad,
  • Request correction if incomplete / incorrectly processed,
  • Article 7 of the Law on the Protection of Personal Data to request deletion/destruction within the framework of the conditions stipulated in the article,
  • To request notification of the above-mentioned transactions to third parties to whom the data is transferred,
  • Object to the occurrence of a result to your detriment due to analysis exclusively by automated systems,
  • If you suffer damage due to unlawful processing, you have the right to demand compensation for the damage.

  • Data Controller and Application Method You Can Apply Within the Scope of KVKK Provisions

In case there are rights or requests that you want to use among your rights listed above; Articles regarding the rights of data subjects in the GDPR and KVKK 11. You can submit your written application, in which you clearly and understandably state which of the rights specified in the article you request to use, with wet signature and documents to prove your identity, to Etya's address "Turkey, Istanbul, Esenyurt, Piri Reis Mahallesi, 2281 Sokak, 13/97", which is also available on their corporate website, in person, send it through a notary public or send it to the e-mail address "info.vsbf@tourvitahealth.com" by signing it with a secure e-signature or send it by other methods specified in KVKK. In accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller", it is mandatory to include name-surname, signature, Turkish ID Number/Passport Number/temporary Turkish ID Number, residence or workplace address, e-mail address, telephone and fax number, and the subject of the request in your applications.

Etya 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 in the tariff determined by the Personal Data Protection Board will be charged.

You can submit your applications to Etya via the "KVKK Access / Information Request Form" in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller.

  • CONSENT, EXPLICIT CONSENT AND APPROVAL

When you read and accept this Clarification Text, you are deemed to have accepted, declared and undertaken that you have full and complete information about the data processing process carried out by Etya, that you have learned your rights under the KVKK and GDPR, and that you freely and freely consent to the PROCESSING of your Personal Data and Sensitive Personal Data by Etay within the scope of this Clarification Text, and that you have given your consent for explicit consent for the items in Article 3 and Article 4.

You have the right not to accept the Clarification Text after reading it.

ETYA Turizm EGITIM HIZMETLERI TIC. LTD. STI , reports as "DATA RESPONSIBLE" within the scope of KVKK and as "CONTROLLER" within the scope of GDPR.

Sincerely.