KVKK / Data Protection Notice

Dear Clients,

Being aware of how important all your rights relating to the privacy of your private life and confidentiality are, we respect them and take all necessary measures with the utmost care to protect these rights. For this reason, in order to protect your fundamental rights and freedoms, we hereby inform you, through this notice, about your rights concerning the collection, protection and processing of your Personal Data.

In accordance with Law No. 6698 on the Protection of Personal Data (KVKK), Law No. 3359 on Basic Health Services, Decree Law No. 663 on the Organisation and Duties of the Ministry of Health and its Affiliated Institutions, the Regulation on the Processing of Personal Health Data and Ensuring Confidentiality (the Regulation), the regulations of the Ministry of Health and other relevant legislation; the necessary information is provided to you by Özel Nova Pol Polyclinic within the scope of this Clarification Notice, for the lawful collection and processing of your Personal Data — including your special categories of Personal Data — that you have provided to us while benefiting from our healthcare services and other services.

Özel Nova Pol Polyclinic, in its capacity as data controller, may record, store, update your Personal Data as described in this Clarification Notice and, in cases permitted and/or required by legislation or agreements, may share, transfer, classify and process it with third parties (the relatives of the person receiving the service and/or the public and/or private legal entities of which the service recipient is an employee/insured, other public and/or private legal entities, and the third parties from whom our clinic receives services or with whom it cooperates in order to carry out the activities subject to the purposes specified in the legislation to which it is bound) in the manners set out in the KVKK and relevant legislation.

Your health data is considered special category data under the KVKK and, as a rule, cannot be processed without the explicit consent of the data subject. However, for the purposes of protecting public health, preventive medicine, medical diagnosis, the conduct of treatment and care services, and the planning and management of healthcare services and their financing, your health data may be processed without seeking the explicit consent of the data subject by persons under an obligation of confidentiality or by authorised institutions and organisations.

Your visual data relating to before and after treatment will be processed by being shared on our social media accounts and on our website, only where you have given your explicit consent, for the purpose of carrying out advertising/campaign/promotion activities.

Your Personal Data is obtained by Özel Novapol Polyclinic for the purposes of protecting public health, preventive medicine, medical diagnosis, the conduct of treatment and care services, the planning and management of healthcare services and their financing, and the conduct of advertising / campaign / promotion processes (where the data subject has given explicit consent); through written (patient identification form, patient information and consent form, etc.), verbal, visual, electronic, email, call centre, website and similar channels.

Your personal and special category personal Data, primarily your health data: your name, surname, Turkish ID number and/or passport number and/or temporary Turkish ID number, place and/or date of birth, marital status, gender, health insurance, occupation, insurance card number, workplace registration and/or patient ID number, and other identity data that may identify (render identifiable) you;

Your address, telephone number, email address and other contact data, the voice call recordings kept by customer representatives and/or patient services in accordance with call centre standards, and the Personal Data obtained when you contact us via email, letter and/or other means;

Your financial data such as bank account number, IBAN number, credit card information, billing and invoice information;

Your data relating to private health insurance for the purpose of the financing and planning of healthcare services;

Including but not limited to patient medical reports, diagnostic data, biometric and genetic data, laboratory results, test results, examination data, doctor analyses and comments, appointment information and prescription information; all health information and data obtained during and/or as a result of the conduct of medical diagnosis, treatment and care services;

Your visual data contained in photographs and videos relating to before and after treatment;

It covers your health data, IP address, cookie data that you send and/or enter through all websites and online services belonging to Özel Novapol Polyclinic, as well as all kinds of Personal Data relating to your service contract; and may be processed by Özel Novapol Polyclinic in a manner that is connected, limited and proportionate to the purpose for which the information was obtained from you.

Your Personal Data may be processed by Özel Novapol Polyclinic for the purposes listed below.

Fulfilling our legal obligations set out in Law No. 3359 on Basic Health Services, Decree Law No. 663 on the Organisation and Duties of the Ministry of Health and its Affiliated Institutions, Law No. 6698 on the Protection of Personal Data, the Regulation on the Processing of Personal Health Data and Ensuring Confidentiality, and other relevant legislation,

Planning and managing the internal functioning of our polyclinic and daily practices (treatments)

Protecting public health, preventive medicine, the conduct of medical diagnosis, treatment and care services, and the planning and management of healthcare services and their financing,

Carrying out promotional and informational activities specific to you and enabling you to benefit from them,

Retaining information relating to your health data that must be stored under the relevant legislation,

Where you make an appointment, informing you about the appointment, providing information and/or sending appointment reminders,

Meeting legal and regulatory requirements,

Sharing and responding to the information obtained with the Ministry of Health and other public institutions and organisations in accordance with the legislation,

Issuing invoices in return for the services we provide,

Ensuring compliance with internal policies and principles,

Analysing your use of healthcare services and storing your health data in order to develop and improve the healthcare services we provide to you, and responding to your questions or complaints regarding our services,

Contacting you for the purposes of information and campaigns relating to the services performed by Özel Nova Pol Polyclinic and, without being limited to these, the conduct and development of medical diagnosis, treatment and care services, the planning and management of healthcare services and their financing, and the increase, investigation of patient satisfaction and related reasons.

Carrying out advertising, campaign and promotion services,

Your Personal Data obtained and processed under the relevant legislation may be kept under protection in both digital and physical environments, by being stored in the physical archives of Özel Nova Pol Polyclinic and/or transferred to computer environments.

The processing of your health data (Special Category Personal Data) is, as a rule, prohibited and may only be processed on a legal basis or with the consent of the data subject. There are exceptions whereby Special Category Personal Data may be processed without the explicit consent of the data subject. In the cases listed below (KVKK Art. 5 and Regulation Art. 7), your Personal Data may be processed without seeking explicit consent.

Where it is expressly provided for by law,

Where it is necessary to process your Personal Data for the protection of the life or physical integrity of yourself or another person, in cases where you are unable to give your consent as the data subject due to actual impossibility or where your consent is not legally valid,

Where it is necessary to process the Personal Data of the parties to a contract, provided that it is directly related to the conclusion or performance of that contract,

Where it is mandatory for the fulfilment of a legal obligation,

Where your Personal Data has been made public by you,

Where data processing is mandatory for the establishment, exercise or protection of a right, and

Where it is mandatory to process data for the legitimate interests of Özel Nova Pol Polyclinic, provided that it does not harm your fundamental rights and freedoms.

Data required for the protection of health, medical diagnosis, treatment or the management of healthcare services is not prohibited provided that it is processed by persons under an obligation of confidentiality.

Where it has been made public by the data subject themselves, your Personal Data may be processed without seeking explicit consent.

In the processing of special category personal data, where it is also determined that the sufficient measures specified by the Personal Data Protection Board have not been taken, it may be decided not to process the data even if the data subject has given explicit consent.

By ensuring that all necessary technical and administrative measures to provide an appropriate level of security are taken in accordance with the KVKK and the relevant health legislation, your Personal Data may, in line with the purposes set out in Section II, be transferred to third parties domestically as well as abroad, within the framework of the personal data transfer conditions and purposes set out in Articles 8 and 9 of the KVKK, to the persons/institutions and/or organisations permitted by Law No. 3359 on Basic Health Services, Decree Law No. 663 on the Organisation and Duties of the Ministry of Health and its Affiliated Institutions, Law No. 6698 on the Protection of Personal Data, the Regulation on the Processing of Personal Health Data and Ensuring Confidentiality and other relevant legislation; including private insurance companies, the Ministry of Health and its sub-units, the Social Security Institution, the General Directorate of Security and other law enforcement, the General Directorate of Population, the Turkish Pharmacists' Association, the courts and all kinds of judicial authorities, central and other third parties, the representatives you have authorised, the lawyers to whom you have given special power of attorney on the matter, the third parties from whom we receive consultancy including tax and financial advisors and auditors, regulatory and supervisory institutions, official authorities, our business partners with whom we cooperate to develop or carry out healthcare services for the purposes specified above, and other real and/or legal third parties.

Your visual data relating to before and after treatment may, where you have given explicit consent, be transferred abroad by being published on our social media accounts and on our website, due to the fact that it is transferred to the data centres of the relevant software.

Your Personal Data / Special Category Personal Data is collected through written (patient identification form, patient information and consent form, etc.), verbal, visual, electronic, email, call centre, website and similar channels, in line with the purposes set out in Section II, and is stored in physical or electronic environments.

To the extent that your Personal Data is processed, pursuant to Article 11 of the KVKK, by delivering in person to the Polyclinic centre located at Barbaros Mahallesi Halk Caddesi 85/1/A Ataşehir/İstanbul Türkiye where you received service, by sending via notary, by sending an email signed with your own secure electronic signature to info@novapol.com.tr, or by sending a “Word or PDF” file signed with a secure electronic signature to mcagroup@hs01.kep.tr via registered electronic mail (KEP);

To learn whether any of your Personal Data is being processed,

To request information regarding the processing activities of your Personal Data,

To learn the purposes of processing your Personal Data,

To learn the third parties/institutions and/or organisations to whom your Personal Data has been transferred, where it has been transferred domestically or abroad,

To request the correction/updating of your Personal Data where it has been processed incompletely or inaccurately,

To request the deletion or destruction of your Personal Data where the reasons requiring its processing have ceased to exist, or where Özel Nova Pol Polyclinic has no legal basis or legitimate interest to process the data in question,

To object to adverse outcomes that may arise as a result of the processing of your Personal Data by automated systems, and

Where you suffer damage due to the unlawful processing of your Personal Data, to demand the compensation of such damage.

Özel Nov Pol Polyclinic will conclude the request, depending on its nature, as soon as possible and at the latest within thirty days, free of charge or in return for the fee in the tariff determined by the Personal Data Protection Board. In the application containing your explanations regarding the right you wish to exercise, made in order to use the above-mentioned rights you hold as a data subject; the matter you request must be clear and comprehensible, the subject of your request must relate to you personally, or if you are acting on behalf of someone else you will be required to submit a notarised special power of attorney on this matter. In your applications, the inclusion of the elements of name-surname, signature, Turkish ID number, residence or workplace address, email address, telephone and fax number, and the subject of the request is mandatory pursuant to the “Communiqué on the Procedures and Principles of Application to the Data Controller.” Applications that do not contain these elements will be rejected by the clinic.