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Clarification Text on the Processing and Protection of Personal Data

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This Clarification Text has been drafted by eKonsey Özel Sağlık Hizmetleri Sağlık Yatırım ve Danışmanlık Ltd. Şti. ("Our Company"), acting in the capacity of data controller, in accordance with the Law on the Protection of Personal Data No. 6698 ("Law"), to provide explanations and information regarding the processing of Personal Data belonging to all persons associated with our Company. You can access detailed information regarding the processing of your Personal Data shared with our Company from the Policy on the Processing and Protection of Personal Data (Policy) located on the website with the domain name www.ekonsey.com.

  1. Purposes of Processing Personal Data

Within the scope of your legal and/or commercial relationship with our Company, the Personal Data you have shared may be processed by our Company in accordance with the law, the purpose of the Law, and the processing purposes listed below. In this direction, our Company processes Personal Data within the scope of the Personal Data processing conditions specified in Articles 5 and 6 of the Law for the purposes of:

  • Fulfillment of legal and contractual obligations to be performed by our Company,
  • Fulfilling our legal obligations contained in the Basic Law on Health Services No. 3359, the Decree-Law on the Organization and Duties of the Ministry of Health and its Affiliated Institutions No. 663, the Regulation on the Processing and Ensuring the Privacy of Personal Health Data, and other relevant regulations,
  • Protection of public health, execution of preventive medicine, medical diagnosis, treatment, and care services, planning and management of health services and financing,
  • Identification and verification of your identity for your security,
  • Questioning your entitlement with contracted institutions, ensuring financial reconciliation regarding the health service, sharing information requested by institutions,
  • Execution of the billing process,
  • Sharing information acquired with the Ministry of Health and other public institutions and organizations in accordance with the legislation and responding to their requests,
  • Contacting Personal Data Subjects who convey their requests and complaints to our Company and ensuring the follow-up and management of requests and complaints,
  • Analyzing your use of health services for the purpose of improving the services we offer,
  • Ensuring compliance with internal policies and principles,
  • Maintaining information regarding your health data that must be stored pursuant to the relevant legislation,
  • Carrying out necessary IT activities to ensure the security of data held by our Company, and in this context, receiving external technical support services,
  • Creating personnel file information for the Personnel in line with the employment contract concluded between the Personnel and our Company, keeping this information up to date, maintaining it, and storing it for the duration of the statute of limitations prescribed by legal legislation,
  • Paying the salary earned by the Personnel for their duty and documenting/controlling the payment, tracking advance payments and expenses incurred,
  • Setup and backup of e-mail accounts allocated to the Personnel by our Company for use within the scope of our Company's activities, creation of necessary user accounts and passwords for the Personnel's access to digital environments and software, making authorization limitations, and providing technical support for these within or outside the Company;
  • Carrying out promotion and information activities, contacting you for informational purposes regarding our services,
  • Without being limited to these, for the purposes of carrying out and improving medical diagnosis, treatment, and care services, planning and management of health services and financing, increasing and researching patient satisfaction, and related reasons.
  1. To Whom and For What Purpose Personal Data May Be Transferred

Within the scope of the Personal Data transfer conditions specified in Articles 8 and 9 of the Law, our Company may transfer your personal data in line with the stated purposes and those contained in legal regulations, by ensuring that all necessary technical and administrative measures are taken to ensure the appropriate security level in accordance with the KVKK/GDPR and relevant health legislation, to: institutions or organizations permitted by the provisions of the Basic Law on Health Services No. 3359, the Decree-Law on the Organization and Duties of the Ministry of Health and its Affiliated Institutions No. 663, the Regulation on the Provision of Remote Health Services of the Ministry of Health No. 31746, the Regulation on the Processing and Ensuring the Privacy of Personal Health Data, and other relevant legislation; private insurance companies; our direct/indirect domestic/foreign shareholders, subsidiaries, and/or affiliates; our group companies; auditors; consultants; business partners; domestic/foreign organizations and other third parties from whom we receive services contractually to carry out our activities or with whom we cooperate.

In the event that the processing activity carried out for the aforementioned purposes does not meet any of the exceptions provided under the Law, your explicit consent regarding the relevant processing is obtained by our Company.

  1. Method and Legal Basis for Collecting Personal Data

Personal Data are collected and processed by our Company or data processors assigned by our Company, in all kinds of verbal, written, and electronic environments, through technical and other methods, via various channels such as the call center and website, for the purpose of auditing compliance with Article 1 of the Law regulating the purpose and Article 2 regulating the scope, for the realization of the purposes included in Articles 5 and 6 of the Law and the Policy, and within the framework of legal reasons based on legislation, contracts, or requests, in order to fulfill responsibilities arising from the law completely and accurately.

  1. Rights of the Personal Data Subject Under the Law

In accordance with Article 10 of the Law, our Company notifies you of your rights as a Personal Data Subject, provides guidance on how to exercise these rights, and carries out the necessary internal functioning, administrative, and technical arrangements for all these. In accordance with Article 11 of the Law, our Company informs the persons whose Personal Data are collected that they have the right to: learn whether Personal Data is processed, request information if Personal Data has been processed, learn the purpose of processing Personal Data and whether they are used in accordance with their purpose, know the third parties to whom Personal Data are transferred domestically or abroad, request correction if Personal Data are processed incompletely or incorrectly, request the deletion or destruction of Personal Data within the framework of the conditions provided in Article 7 of the Law, request notification of the transactions made pursuant to subparagraphs (d) and (e) of Article 11 of the Law to third parties to whom Personal Data are transferred, object to the occurrence of a result against the person themselves by analyzing the processed data exclusively through automated systems, and request compensation for the damage in case of loss due to unlawful processing of Personal Data.

Personal Data Subjects may submit their requests regarding the aforementioned rights to our Company free of charge by filling out and signing the Application Form in the ANNEX, using the information and documents that will identify their identity and the methods specified below or other methods determined by the Personal Data Protection Board:

  • Submitting a copy of the filled form with a wet signature in person, via notary public, or by registered mail with return receipt to the address: Levent Mah. Hacı Adil Cad. Zerrin Sok. No:2/2 Beşiktaş İSTANBUL,
  • Sending the form via registered electronic mail to the address [info@ekonsey.com] signed with a secure electronic signature regulated under the Electronic Signature Law No. 5070,
  • Following a method prescribed/to be prescribed by the Personal Data Protection Board.

In order for third parties to make an application request on behalf of Personal Data Subjects, there must be a special power of attorney issued by a notary public by the Personal Data Subject in the name of the person who will make the application.

Our Company will conclude the request as soon as possible and at the latest within 30 (thirty) days free of charge depending on the nature of the request. However, if the transaction requires an additional cost, our Company reserves the right to charge a fee over the tariff determined by the Personal Data Protection Board.