PROCESSING AND PROTECTION OF PERSONAL DATA LIGHTING TEXT
(DATA POLICY)
AKL Health Education Consultancy Ticaret A.Ş. as a personal data processor legal entity. The polyclinic enterprise operated by “AKL” has adopted the basic principle of complying with all obligations arising from the legislation regarding the processing and protection of personal data.
As AKL data controller, it obtains, collects and processes your personal data in accordance with the Personal Data Protection Law No. 6698 and the relevant sub-legislation.
This Text, which provides illumination about the processing and protection of personal data;
*From which sources we obtain your personal data,
*The necessity, purpose and legal reasons for obtaining and processing your personal data,
*Whether we transfer your personal data and to whom we may transfer it,
*The rights of persons whose personal data are processed, arising from the legislation,
He elaborates on his subjects.
PERSONAL DATA PROCESSED (WHOSE PERSONAL DATA WE PROCESS)
In its capacity as data controller, AKL only processes the personal data of the following groups of persons.
1-Workers working in our company who are data controllers
2-Worker candidates
3-Reference persons declared in writing by the job applicants
4-Interns
5-On-the-job training trainees
6-Patients
7-Patient candidates
8- Persons who are contacted and contacted through physical means, telephone communication, e-mail, mobile applications or any virtual platform for the purpose of diagnosis, treatment or receiving such services (Their name, surname and telephone information were obtained as a result of fair or stand promotion activities. and interviewees)
9-Patient relatives and companions
10-Parties of the commercial activity or the persons who are or will be cooperated with due to the commercial activity, or the authorized or employees of such enterprises or companies (supply, advertisement, promotion, support, marketing, consultancy, transportation, reference resources, etc.)
11-Lawyers with a power of attorney relationship
12-Consultants or authorized or employees of consultancy companies
13-Contracted Independent Accountant and Financial Advisor, Sworn-in Certified Public Accountants, independent audit firms and their employees
14-Visitors
15-Legal representatives, parents, guardians or guardians of the persons whose personal data we process
16- Persons who are parties in legal processes and their legal representatives
17- Third parties who are deemed necessary to be contacted within the scope of the workflow, although they do not have a commercial or legal connection
PROCESSED PERSONAL DATA (WHAT WE PROCESS PERSONAL DATA)
In its capacity as data controller, AKL processes the following personal data of the persons concerned in accordance with the legislation.
Identity Data
All data regarding the identity of the persons whose data will be processed, such as name-surname, nationality, TR identity number, place and date of birth, marital status, father’s name, mother’s name, gender, passport number and information in case of not being a Turkish citizen, or temporary citizenship identification number, are within this scope.
Personally Identifiable Data
The handwritten or wet signature of the person is within this scope.
Communication Data
This includes data related to communication such as residence address, business address, correspondence address, telephone or mobile phone number, e-mail address.
Visual and Audio Data
*Images taken by company security cameras with a closed circuit camera system for security purposes,
*Audio data recorded by recording company telephone communication (voice response system) for the purpose of service delivery quality, activities and management, follow-up of requests or complaints,
*Images (photo or video recording) processed with the special written consent (consent) of the patients for promotion, research, persuasion processes, confirmation and proof of the medical procedure, or promotion of the medical procedure to other patient candidates, to follow the developments as a result of the treatment.
This is the data in scope.
Personnel Data
It is the data processed about the whole of the personnel transactions created in accordance with the legislation obligations such as wages, the number of working days per month or the employment contract about the workers.
Training Data
It is the data on the education status and training documents for workers, worker candidates, interns or on-the-job training trainees or other related persons.
Job and Occupation Data
All data on current or former job or occupation for workers, prospective workers, trainees or on-the-job training trainees or other relevant persons. (Including professional experience, diploma, course data)
Comment and Complaint Data
It is the data of comments and complaints transmitted by any person on the website or through other channels, after pre-approval and consent (by ticking the option of approval and consent) in order to evaluate the services offered.
Location or Location Data
It is the data about the location or current location, which is outside the scope of the communication data and transmitted by the persons by any means and by themselves.
Transaction Security Data (IP Data and Cookies)
This includes IP address, browser information, website login and password information, (Mac ID, IP address information, website login and password information).
Legal Data
In addition to the data regarding the legal transaction of the persons whose data are processed, all the data regarding the plaintiff, the defendant and the enforcement proceedings.
Financial Data
It is the data of the persons whose data is processed, such as bank account number or IBAN number. The data controller is the data requested and processed by the employees working in the company and the patients receiving services.
Health Data on Patients
During the execution of medical diagnosis, treatment and care services such as laboratory and medical imaging results, medical diagnosis or treatment test results, blood group, examination data, prescription information, which are within the scope of the health service that must be followed for legal reasons or are provided in the medical files, and processed with the consent of the person. All kinds of health data obtained are within this scope.
Health Data on Workers
It is the data in the health reports and medical documents received from the workers to be kept in the personnel file in accordance with the labor legislation, employment contract and occupational health and safety legislation.
Customer Transaction Data
Patients’ credit card, mail order, advance receipt, payment receipt, invoice, promissory note, check, receipt, order information, request information, etc. data in this context.
Clothing Data
Size data etc. fixture, uniform, material and shoe size etc. data is included in this scope.
Biometric Data
Palm information, fingerprint, retina scan, face recognition etc. data is included in this scope.
Physical Space Security Data
Entry and exit registration information of patients, patient candidates, workers, interns, on-the-job training trainees, worker candidates and visitors, and security camera records are the data in this scope.
III.PROCESSING OF PERSONAL DATA
A. OBTAINING (COLLECTING) PERSONAL DATA
1. Through Which Channels and How Personal Data are Collected
1.1 . Data Collected Through Our Website
* Over the information transmitted by entering the name and phone number in the MAKE AN APPOINTMENT section of the website,
* Via the information transmitted through the section on the website that is used to directly switch to the WHATSAPP application,
* Via the information transmitted on the website within the scope of WHATSAPP SUPPORT LINE,
* Through the information transmitted as a result of the calls made from the section on the website where the polyclinic phone number is shared,
* Over the information transmitted within the scope of the comment made to the Google Comment section directed from the WRITE COMMENT section on the website,
* Through the information transmitted through the section for DETAILED INFORMATION on the website, which is used to switch to the WHATSAPP application,
Personal data given by the person and limited to the purpose (communication) are within this scope.
1.2. Data Collected via Telephone or Electronic Mail or Other Digital Communication Applications
The outpatient clinic assistant staff can communicate via the phones they use or via SMS or e-mail or WhatsApp etc. Personal data provided by the person concerned as a result of the communication established through the applications and limited to the purpose (communication and other necessary data regarding patient candidacy) are within this scope.
1.3. Data Collected in the Scope of Face-to-face Communication
In case of applying to our clinic in person, personal data collected for a limited purpose as a result of face-to-face interviews with the relevant health consultants or health personnel are within this scope.
1.4. Data Collected in the Scope of Examination, Diagnosis or Treatment
Personal data, which are collected for limited purposes as a result of examination service, examination, diagnosis or treatment received as a result of medical procedures performed by polyclinic health personnel, and most of which are in the nature of medical data, are within this scope.
1.5. Data Collected as a Requirement of Routine Commercial Activity
Personal data obtained from the contract and other commercial activity documents of the person and company officials or employees with whom the business relationship is required as a requirement of the commercial activity,
Personal data obtained from the contract and other commercial activity documents of the lawyers, financial advisors, sworn financial advisors, occupational health and safety, environment, data processing and any other authorized or employees of the companies that have a contract with the company,
It is within this scope.
1.6. The Data Requested for Connecting to the Wireless Internet Network (WIFI) Broadcast Available for Use in the Business
Personal data obtained as a result of requesting personal data (TC ID number or mobile phone number) requested in accordance with the legislation in order to connect to the wireless Internet network (WIFI) broadcast, which is available to the patient, patient and other visitors in the business building, is within this scope.
IV. PURPOSE OF PROCESSING PERSONAL DATA AND LEGAL REASONS
A. Purposes of Processing Personal Data
Your personal data mentioned above will be processed for the following purposes.
1- Fulfillment of legal obligations
2- Fulfillment of the provisions of the contract,
3-Commercial activity and management requirements,
4-Providing Health Services (Medical diagnosis, examination, treatment and all kinds of care services)
4.1. Carrying out medical diagnosis, treatment and care services,
4.2. Sharing the information requested by the Ministry of Health and all other relevant official institutions and organizations in accordance with the health legislation,
4.3. Financing your health services, meeting the expenses of examination, diagnosis and treatment,
4.4. Informing the patients about the appointment,
4.5. Confirming the identity of the patient,
4.6. Measuring, increasing and researching patient satisfaction by outpatient clinic management, patient rights, patient experience departments,
4.7. Invoicing by patient services, financial affairs, marketing departments,
4.8. To be able to answer all kinds of questions and complaints about our health services by the outpatient clinic management.
5.Technical requirements;
5.1.Planning and managing the internal functioning of the outpatient clinic management,
5.2.Research and analysis for the quality of service delivery, patient experience, improving the quality of health services,
5.3. Providing training to the workers by the policlinic management,
5.4. Monitoring and preventing unauthorized transactions by the policlinic management,
5.5. Carrying out risk management and quality improvement activities,
5.6. Taking all necessary technical and administrative measures within the scope of data security by the outpatient clinic management,
5.7. When necessary, necessary communications can be provided by the relevant personnel of the data controller in order to carry out transportation, accommodation and courtesy services within the scope of health tourism,
5.8. Participation in the campaigns and providing campaign information, designing special content, tangible and intangible benefits on the web and other mobile channels, social media, and communicating them to the addressees,
5.9. To be able to carry out the training and activities by the educational institutions with which the polyclinic management is in cooperation.
B. Legal Reasons for Processing Personal Data
Your personal data mentioned above;
-Health Services Basic Law No. 3359,
Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates,
-Regulation on Private Health Institutions with Outpatient Diagnosis and Treatment
-Regulation on Processing of Personal Health Data and Protection of Privacy
-Law No. 6698 on the Protection of Personal Data,
-1774 Identity Notification Law,
-Labor Law No. 4857,
-5510 Social Insurance and General Health Insurance Law,
– Occupational Health and Safety Law No. 6331,
-Law of Obligations,
-Turkish Commercial Code,
-Other relevant legislation,
It is processed for legal reasons.
C. Legal Limits
Protection of Personal Data No. 6698, as stated in paragraph 3 of Article 6 of the Law, personal data related to health and sexual life can only be used for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, health services and planning their financing. and management, by persons or authorized institutions and organizations under the obligation to keep secrets without seeking the explicit consent of the person concerned.
V. TRANSFER OF PERSONAL DATA
A. Reasons for Transfer
Your personal data,
-Health Services Basic Law No. 3359,
Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates,
-Regulation on Private Health Institutions with Outpatient Diagnosis and Treatment
-Regulation on Processing of Personal Health Data and Protection of Privacy
-Law No. 6698 on the Protection of Personal Data,
-1774 Identity Notification Law,
-Labor Law No. 4857,
-5510 Social Insurance and General Health Insurance Law,
– Occupational Health and Safety Law No. 6331,
-Law of Obligations,
-Turkish Commercial Code,
-Other relevant legislation,
Obligations arising from the legislation can be transferred in accordance with the purpose and in a limited manner, in accordance with the provisions of the contract and in accordance with routine business activities.
B. Authorities to be transferred
Personal data may be transferred to the following authorities for the reasons stated above.
*Ministry of Health, sub-units of the ministry and family health centers, physician’s offices,
*Private insurance companies (health, pension, life insurance, etc.),
*Social Security Institution,
*Ministry of Family and Social Policies,
*The Ministry of Labor and Social Security,
* General Directorate of Security and other law enforcement agencies,
*General Directorate of Population and Citizenship Affairs,
*Other authorized official institutions and organizations,
*Turkish Pharmacists Association and Pharmacies,
* Judicial authorities, enforcement offices, mediators,
* Laboratories, medical centers, polyclinics, ambulances, medical devices and institutions providing health services in cooperation for medical diagnosis and treatment,
*The health institution to which the patient was referred or to which the patient applied himself,
*Legal representatives, parents and guardians authorized in writing
*Real or legal persons who receive consultancy services, including lawyers, accountants, financial advisors, sworn financial advisors, tax advisors and auditors, who work within the scope of the contract,
* Regulatory and supervisory authorities,
*Banks where the polyclinic, patients or workers who are related to our company pursuant to any contract have accounts,
*Individual pension companies that work within the scope of compulsory or optional IPS (Private Pension System),
* Insurance companies
* Car rental companies and businesses,
*Suppliers, support service providers, archive service providers and business partners whose services are utilized or cooperated with,
* Outsourcing service providers (limited to subject and purpose)
*Cargo or courier companies,
*Air, land or sea passenger transport companies.
IV. OUR MEASURES AND COMMITMENTS ON THE PROTECTION OF PERSONAL DATA
In its capacity as data controller, AKL protects the above-mentioned personal and private personal data in its own physical and electronic environments with great sensitivity and by fully complying with the provisions of the legislation, by taking all kinds of administrative and technical measures.
AKL has taken all kinds of administrative and technical measures to protect your personal data.
AKL is committed to protecting all personal data. In order to prevent the illegal processing and access of personal data and to ensure the protection of personal data, technical and administrative measures are carried out by using various methods and security technologies to ensure the appropriate level of security.
AKL will not disclose the personal data it has obtained to others in violation of the provisions of the Law on the Protection of Personal Data No. 6698 and will not use it for purposes other than processing.
AKL has prepared and signed all warnings or consent statements, undertakings, and has implemented the necessary multi-faceted audit activities in cases where it is necessary and necessary to share (transfer) personal data with outsourcing service providers and suppliers, consultants or lawyers.
V. COOKIE POLICY
AKL does not position cookies on its website. During the use of our website and mobile application, IP address, browser information. (Mac ID, IP address information, website login and password information) are not received.
VI. YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA
Pursuant to Article 11 of the Personal Data Protection Law, you can exercise your rights regarding the processing and protection of your personal data, provided that you prove your identity by applying to AKL Sağlık Eğitim Danışmanlık Ticaret A.Ş.
A. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
1. Learning whether your personal data is being processed
2. If your personal data has been processed, requesting information about it
3. To learn the purpose of processing your personal data and whether they are used in accordance with its purpose,
4. To know the person or authorities to which personal data is transferred,
5. To request correction of personal data if it is incomplete or incorrectly processed,
6. Requesting the deletion or destruction of personal data,
7. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
8. To request the compensation of the damage in case of loss due to unlawful processing of personal data,
You have their kakas.
AKL Sağlık Eğitim Danışmanlık Ticaret A.Ş. undertakes the destruction (deletion, destruction or anonymization) of your personal data within the framework of the conditions stipulated in Article 7 of the Law on the Protection of Personal Data. You can request from . However, by evaluating your destruction request, which method is appropriate, according to the conditions of the concrete case, AKL Sağlık Eğitim Danışmanlık Ticaret A.Ş. will be evaluated by In this context, you can always request information from AKL Sağlık Eğitim Danışmanlık Ticaret A.Ş. about why we have chosen the disposal method we have chosen.
Personal data collected about persons under the age of 18 are limited to their name, surname, age and degree of affinity, and these data can only be given to us by the relevant adult (parent or guardian).
B. SITUATIONS OUT OF THE SCOPE OF THE RIGHT OF APPLICATION
Pursuant to Article 28 of the Personal Data Protection Law, personal data owners will not be able to assert their right of application, since the following cases are excluded from the scope of the Personal Data Protection Law:
– Processing personal data for purposes such as research, planning and statistics by making them anonymous with official statistics.
– Processing personal data for art, history, literature or scientific purposes or within the scope of freedom of expression, provided that it does not violate national defense, national security, public security, public order, economic security, privacy of private life or personal rights or constitute a crime.
– Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations that are authorized by law to ensure national defense, national security, public safety, public order or economic security.
– Processing of personal data by judicial authorities or execution authorities in relation to investigation, prosecution, trial or execution proceedings.
– Pursuant to paragraph 2 of Article 28 of the Personal Data Protection Law, it is not possible to assert the rights in the following cases, with the exception of the right to demand the compensation of the damage:
-Personal data processing is necessary for the prevention of crime or for criminal investigation,
– Processing of personal data made public by the person concerned,
-Personal data processing is required by the authorized and authorized public institutions and organizations and professional organizations in the nature of public institutions, for the execution of supervisory or regulation duties and for disciplinary investigation or prosecution, based on the authority given by the law,
-Personal data processing is necessary for the protection of the economic and financial interests of the State with regard to budgetary, tax and financial matters.
C. YOUR WAYS TO CONTACT OUR COMPANY TO USE YOUR RIGHTS
Your rights under the Personal Data Protection Law;
1- By coming to the address of Barbaros Mahallesi Halk Caddesi No:49/1 Ataşehir Istanbul of AKL Health Education Consultancy Trade Inc., filling in the Application Form on the Protection of Personal Data and submitting it personally against signature,
2- By filling out the Application Form on the Protection of Personal Data, which is included in the Processing and Protection of Personal Data Clarification Text published on the website www.aklpoliklinik.com of AKL Health Education Consultancy Trade Inc., and submitting it through a notary public,
3- By sending an e-mail to the aklsaglik@hs01.kep.tr kep mail address of AKL Health Education Consultancy Trade Inc. ,
4 – By sending it through a notary public,
You can use it.
According to the nature of your request and application method, AKL Health Education Consultancy Trade Inc. may request additional verifications (such as sending a message to your registered phone, calling) in order to determine whether the application belongs to you and thus protect your rights.
As a rule, your requests in your application will be concluded free of charge within thirty working days at the latest, depending on the nature of the request. However, if the process requires a separate cost for the Clinic, as stated in the Communiqué on the Procedures and Principles of Application to the Data Controller published in the Official Gazette dated 10.03.2018 and numbered 30356 by the Personal Data Protection Authority, a total of 50 (Fifty) TL cannot be exceeded. A fee may be charged. AKL Health Education Consultancy Trade Inc. If it is understood that it is caused by an error, the paid fee, if any, will be returned to you.
In order to confirm that you are the right person in case of your application, AKL Sağlık Eğitim Danışmanlık Ticaret A.Ş. management reserves the right to request some confirmatory information from you. Unless you cancel your application, AKL Health Education Consultancy Trade Inc. You are deemed to have accepted these requests of the management.
VII. CONSENT and APPROVAL
When you read this Clarification Text, you accept, declare and declare that you are fully and completely informed about the processing of your personal data and that you have given your consent to the processing of your personal data. You are deemed to have committed.
VIII. CONTACT INFORMATION
AKL Health Education Consultancy Trade Inc.
Barbaros Mahallesi Halk Caddesi No:49/1 Atasehir Istanbul
Tel: 0 (216) 334 82 82