Personal Data Protection

PERSONAL DATA PROTECTION

LIGHTING TEXT ON THE PROCESSING OF PERSONAL DATA

As ESTEFAVOR SAĞLIK HİZMETLERİ ANONİM ŞİRKETİ (“Estefavor” or “Company”) with the Illumination Text for the Processing of Personal Data (“Illumination Text”), in accordance with the Personal Data Protection Law No. 6698 (“Personal Data Protection Law” or “Law”), As the Responsible, within the framework of our obligation to inform you under the Personal Data Protection Law, the methods and legal reasons for collecting your Personal Data as defined below, our methods and policy of protecting your Personal Data, the Personal Data samples processed, the identity of the data controller, the purposes of processing your Personal Data, We would like to inform you about the rights granted to you under the Law on the Protection of Personal Data.

Within the scope of the Law on the Protection of Personal Data, personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”), and Special Quality Personal Data, which is a special type of this, refers to race, ethnicity, political thought, philosophical belief, religion, sect or means data on other beliefs, dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data (“Special Quality Personal Data”). In this context, the definition of Personal Data also includes your Sensitive Personal Data.

1. Identity of Data Controller

Your personal data is registered with the Istanbul Trade Registry in the capacity of data controller with the registration number 325094-5, Mersis number 0380115482500001, the company headquarters is Ataköy 7-8-9-10. Kisim Mah. Cobancesme E-5 Yan Yol Cad. Ataköy Towers A Blok No: 20/1 Interior Door No: 109 Bakırköy, Istanbul by ESTEFAVOR SAĞLIK HİZMETLERİ ANONİM ŞİRKETİ, in accordance with the Personal Data Protection Law, within the scope described below.

2. How We Collect Your Personal Data and Legal Reasons

Your personal data through different channels in order to carry out Company activities; It is collected on the basis of legal reasons to ensure compliance with the legislation and Company policies. Your collected personal data can be processed and transferred for the purposes specified in this Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law.

Estefavor acts in accordance with all the obligations sought in the relevant legislation, especially the Personal Data Protection Law, in all Personal Data processing activities it carries out, and takes the necessary security measures to securely host your Personal Data and to prevent the unlawful use of your Personal Data.

In accordance with the Law on the Protection of Personal Data, we collect your Personal Data automatically or non-automatically, verbally, in writing or electronically, by the following methods, through the following channels and other channels that may be added to them in the future, and we process them within the scope of Article 5.1, Article 5.2, Article 6.2 and Article 6.3 of the Personal Data Protection Law. :

– Electronically via our website www.estefavor.com and other websites that may be established in the future (“Website”), automatically or non-automatically, including but not limited to the following pages,

– As a result of the conversation with our call center,

– Electronically or automatically, from accounts operated on behalf of Estefavor through various Social Media channels (Google, YouTube, Facebook, Instagram, WhatsApp, Twitter, Linkedin, Yandex, Pinterest, Snapchat, Twitch, TikTok, Oracle BlueKai, Bip etc.),

– As a result of the conversation made through the live support application on our website,

– As a result of the meeting to be made by reaching Estefavor doctors or related personnel via phone, WhatsApp Application or e-mail,

– Over the phones used by Estefavor marketing and promotion personnel, or via SMS or WhatsApp etc. As a result of communication established through applications,

– In case you apply to Esefavor, you can communicate with the doctors or related personnel by phone, SMS or WhatsApp etc. As a result of the interviews you will make over the applications,

– If you apply to Estefavor, as a result of face-to-face meetings with doctors or related personnel,

– The personal data of the persons and company officials or employees with whom the business relationship is made as a requirement of the commercial activity, on the contract and other commercial activity documents, on the communication platforms,

– As a result of the personal data being included on the contract and other commercial activity documents of our Legal Advisors, Lawyers and Consultants or the authorized or employees of the consultancy companies, on the communication platforms,

– As a result of the applications made through panels such as “contact us” or “get information” through the promotion and advertisement on social media,

– As a result of requesting a mobile phone number for personal data and encryption requested in accordance with the legislation in order to be able to connect to the broadcast in the wireless network (Wi-Fi) special for the guests within the scope of the wireless Internet service,

– Obtaining data in the form of recording Device Identity Information from the logins to the website,

– If we are in contact with Estefavor without any commercial or legal connection, or if we are contacted, personal data are included in the communication platforms of third parties,

– Similarly, with other legal data acquisition methods,

3. Purposes of Processing Your Personal Data

(A) Within the scope of Articles 5 and 6 of the Law;

As a rule, we process your Personal Data based on your explicit consent. However, in exceptional cases permitted under the Personal Data Protection Law, your Personal Data may be processed without your explicit consent. In this context, (i) in order to fulfill our legal obligations (such as tax legislation, legislation for the protection of consumers, obligations arising from the Turkish Code of Obligations, Turkish Commercial Code and other legislation), (e-invoice, e-archive or when required by consumer legislation) (ii) In case you are unable to express your consent due to actual impossibility (iii) for the purposes of establishing or performing a contract (membership contracts, purchase and sale contracts, product or service sale, supply) All kinds of other transactions that can be attributed within the scope of the performance of our obligations such as delivery, delivery and within the scope of the relevant regulation can be given as examples) (iv) in order to fulfill our legal obligations such as receiving your questions and complaints regarding the service, responding to you, and using them in case of a possible dispute, In order to establish or protect a right through other processes, (vi) cost reduction, efficient use of resources, monitoring the call center service quality, ensuring your security and measuring the quality of the service provided to you, while not harming your fundamental rights and freedoms, evaluating your requests within this scope, and to protect our legitimate interests, such as processing; We process your Personal Data. In addition, the processing of the personal data you have made public within the limits set in the Personal Data Protection Law does not require your explicit consent. The processing of your Personal Data that you have made public on Social Media channels, your website and other channels and any other processing that can be attributed within the scope of the relevant regulation can be given as an example to this situation. Apart from this, in case of processing that requires your explicit consent, your explicit consent will also be obtained.

(B) Your Personal Data collected through the above channels, with the methods described above, may also be processed for the following purposes, provided that your explicit consent is obtained:

– Fulfilling legal obligations and carrying out all kinds of business within the legal framework,

– Fulfillment of contract provisions,

– Providing Health Services

– Commercial activity and management requirements,

– Sectoral (health) requirements;

– Protection of public health, preventive medicine, medical diagnosis, treatment and care services whether sick or not,

– Sharing the information requested by all official institutions and organizations in accordance with the health legislation,

– Financing of your health services, examination, diagnosis and treatment expenses by patient services, financial affairs, marketing departments,

– Informing the patients about the appointment through the customer representative, call center and other channels,

– Patient services, identity confirmation by other operating units,

– Measuring, increasing and researching patient satisfaction by business management, patient rights, patient experience departments,

– Billing by patient services, financial affairs, marketing departments,

– Answering all kinds of questions and complaints about our health services by the business management, patient rights and call center, patient relations department,

– technical requirements;

– Planning and managing the internal functioning of the institution by the call center, patient relations, hospital management,

– Research and analysis carried out by the service delivery quality, customer experience, and data processing departments to increase the quality of health services,

– Training of workers by human resources management and quality departments,

– Monitoring and preventing abuse or unauthorized transactions by the internal audit and data processing department,

– Carrying out risk management and quality improvement activities by the quality, information technology departments,

– Taking all necessary technical and administrative measures within the scope of data security by the business management and IT department,

– Ensuring the necessary communication by the officials in order to carry out transportation, accommodation and attendance services within the scope of health tourism,

– Participation in campaigns and providing campaign information by the patient relations, marketing, call center, department, designing special content, tangible and intangible benefits on the web and other mobile channels, social media and communicating them to the interlocutors,

– To be able to carry out training and activities by the educational institutions with which the institution is in cooperation,

4. Processing Time of Your Personal Data

Personal Data that you have shared with Estafavor through the channels mentioned in this Clarification Text will be processed in accordance with the legislation on the protection of Personal Data, especially the Law on the Protection of Personal Data, and the periods required by other legislation, unless the above legitimate purposes are eliminated in any case.

5. Transfer of Your Personal Data to Third Parties and/or Abroad

Your personal data mentioned above and your personal data of special nature; Personal Data Protection Law No. 6698, Health Services Basic Law No. 3359, Regulation on the Processing of Personal Health Data and Protection of Privacy, Identity Notification Law No. 1774, Labor Law No. 4857, Social Insurance and General Health Insurance Law No. 5510,

It will be processed for legal reasons.

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, planning and management of health services and financing. may be processed by persons or authorized institutions and organizations under the obligation to keep secrets without seeking the explicit consent of the person concerned.

Estefavor may transfer your Personal Data collected through the channels mentioned in this Clarification Text to third parties or abroad within the scope of the Personal Data Protection Law and other legislation and for the purposes mentioned in this Clarification Text.

Storage, archiving, information technology support (server, hosting, program, cloud computing) in the country and abroad, especially in EU countries, America, England, OECD countries, India, China and Russia, in case of the existence of processing purposes that do not require your express consent, with third parties that we receive support in areas such as security, call center, Group Companies, business partners, supplier companies, banks, financial institutions, law, tax, etc. It can be transferred to consultancy firms that receive support in similar fields and other related parties and authorized institutions and organizations where transfer is required for specified purposes. Apart from this, the Ministry of Health and its affiliates, Private insurance companies, Social Security Institution, Ministry of Family, Labor and Social Policies, General Directorate of Security and law enforcement units, General Directorate of Population and Citizenship Affairs, other authorized official institutions and organizations, Turkish Pharmacists Association, Judicial authorities , enforcement offices, mediators, Laboratories in the country or abroad with which we cooperate for medical diagnosis and treatment, medical centers, ambulances, medical devices and institutions providing health services, The health institution to which the patient is referred or the patient himself applies, Authorized in writing It can be shared with legal representatives, parents and guardians, Regulatory and supervisory institutions and official authorities, Our business partners and business contacts, Our Shareholders and natural or legal persons with whom shareholder interviews are held, Outsourcing service providers, Cargo or courier companies, Air, land or sea passenger transport companies. .

Apart from this, only on the condition that your explicit consent is obtained, Group Companies located in the country and in the countries mentioned above can be transferred to third parties who provide marketing and sales support, and can process personal data based on your express consent specified above, based on your express consent. In addition, in the event that some of Estefavor’s parts or assets (including but not limited to brand, domain name and other commercial business elements) are sold based on your express consent, natural or legal persons who have taken over your Personal Data, including their stakeholders, business partners, agents, consultants. It can be transferred to third parties at home and abroad to the extent required by the transfer, may be processed to a limited extent by making the necessary evaluation by these third parties during the transaction process, and in case of transfer, the transferee may continue to process your Personal Data, which are the assets attached to these assets, together with the assets.

6. Our Commitments Regarding Your Personal Data

Estefavor, as the data controller, 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.

Estefavor has taken all kinds of administrative and technical measures to protect your personal data, as recorded in VERBIS and included in the Personal Data Inventory.

Estefavor 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.

Estefavor will not disclose the personal data it has obtained to anyone else 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.

Estefavor 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.

7. Access to Your Personal Data and Your Rights Under KVKK

By applying to Estefavor in accordance with article 11 of the Personal Data Protection Law;

(a) Learning whether your Personal Data is processed,

(b) If your Personal Data has been processed, requesting information about it,

(c) To learn the purpose of processing your Personal Data and whether they are used in accordance with its purpose,

(d) Knowing the third parties to whom your Personal Data is transferred, in the country or abroad,

(e) Request correction of your Personal Data if it is incomplete or incorrectly processed,

(f) To request the deletion or destruction of your Personal Data in case the reasons requiring the processing of your Personal Data disappear, in order to be evaluated within the principles of purpose, duration and legitimacy,

(g) In case of correction, deletion or destruction of your Personal Data, requesting that these transactions be notified to the third parties to whom the Personal Data has been transferred,

(h) Objecting to this result if a result arises against you in case your processed Personal Data is analyzed exclusively through automated systems,

(i) You have the right to demand the compensation of the damage in case your Personal Data is processed unlawfully and you suffer damage for this reason.

In this context, by creating your applications regarding your rights above in a way that meets the conditions determined by the Personal Data Protection Authority, by sending an e-mail from your e-mail address registered in our system or by sending an e-mail to our e-mail address given below, or to our cap address with secure electronic signature, or again below. You can deliver it by hand or through a notary public with a wet-signed petition to our mailing address, which may change from time to time, and send it by other methods determined by the Personal Data Protection Authority, which may be added to these in the future. Estefavor will conclude the request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. Estefavor may request the fees in the tariff determined by the Personal Data Protection Board, in case of additional costs related to the conclusion of the requests by Estefavor.

Postal address: Ataköy 7-8-9-10. Kisim Mah. Cobancesme E-5 Yan Yol Cad. Atakoy Towers A Blok No: 20/1 Inner Door No: 109 Bakirkoy, Istanbul

E-mail address: [email protected]

Phone: +90 542 120 20 30