Clarification Text on the Protection and Processing of Personal Data

HEALTHY IN TURKEY

(A Trademark of AGM Stratejik Çözümler Turizm Sağlık ve Kreş Hizmetleri Dış Ticaret A. Ş.)

CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

All types of personal data are processed, stored and transferred by AGM Stratejik Çözümler Turizm Sağlık ve Kreş Hizmetleri Dış Ticaret A. Ş. (“AGM” or “Healthy in Turkey”) as the data controller in accordance with the Personal Data Protection Law No. 6698 (“Law”). This information hereby has been prepared according to Article 10 of the Law titled “Obligation of Date Controller to Inform” with respect to your personal data collected, stored and processed by AGM as the data controller.

1. IDENTITY OF THE DATA CONTROLLER

In accordance with the Law, your personal data can be processed by AGM Stratejik Çözümler Turizm Sağlık ve Kreş Hizmetleri Dış Ticaret A. Ş., located at the address of Birlik Mahallesi 488. Sokak No: 7 Çankaya/Ankara within the framework explained below.

2. PERSONAL DATA COLLECTED BY AGM

Your personal data is collected as to offer the medical examination, diagnosis, treatment and nursing intermediary services provided by AGM and received from the hospitals in Turkey. Your special category personal data, particularly your health data, and general category personal data can be processed by AGM as to be related, limited and measured with the purposes specified below.

  • Identity Information: Name, last name, passport number or temporary T.R. identity number, place and date of birth, marital status, sex, insurance or patient protocol number and other identity data to help identify,
  • Contact Information: Address, telephone number, electronic mail address and other contact data and personal data collected by AGM personnel through Healthy in Turkey web site, Healthy in Turkey online patient information forms, mobile phone messaging channels, electronic mail, telephone call or when contacted through other means,
  • Health Information: All types of personal data concerning health and sexual life collected before, during or as a result of the medical examination, diagnosis, treatment and/or nursing services including but not limited to the current/known disease and special health condition, medical history including the previous operations and treatments as well, drugs used, disease/phobia/allergy and other health and psychological states that might affect the medical diagnosis and treatment procedures in the hospitals in Turkey, pregnancy/breast-feeding information for women, laboratory results, test results, examination data, appointment information, check-up information and prescription information,
  • Companion(s) and Patient Relative Information: Name, last name, passport number, nationality, telephone numbers, electronic mail address and other contact information of the person/persons accompanying during your stay in Turkey and name, last name, degree, nationality, telephone numbers, electronic mail address and other contact information of the first relative to be contacted when required,
  • Health data and other personal data sent to AGM or entered in http://www.healthyinturkey.com/ and http://www.healthyinturkey.com/fr/ site over http://www.healthyinturkey.com/en/inquiry-form link, over http://www.healthyinturkey.com/fr/inquiry-form link, https://form.jotform.com/203165321639957 link or https://form.jotform.com/203172432612949 link,
  • Accounting Information: Financial data such as bank account number, IBAN number, credit card information and invoicing information and   
  • For the financing and planning of the healthcare services, data concerning private health insurance and data of the Social Security Institution abroad and/or in Turkey.

3. PERSONAL DATA PROCESSING PURPOSES

All types of personal data collected by AGM (including but not limited to the special category personal data) can be processed for the purposes and reasons specified below and purposes and reasons similar to those specified below:

  • To confirm the identity,
  • To offer the medical examination, diagnosis, treatment and nursing intermediary services to be received in the hospitals in Turkey,
  • To inform the hospital and/or healthcare facility in Turkey responsible for the medical examination, diagnosis, treatment and/or nursing services about the past/current health state and contact information of the companion and first relative to be contacted when required,
  • To plan and manage the internal functioning and daily operations of AGM,
  • To fulfill risk management and quality improvement studies,
  • To measure, increase and search patient satisfaction,
  • In case of getting an appointment from the hospitals/health-care facilities in Turkey, to inform about the appointment,
  • To fulfill the legal and regulatory requirements and
  • To inform about participation to Healthy in Turkey campaigns and campaign information and to design and send the special contents and tangible and intangible benefits.

4. STORAGE OF THE PERSONAL DATA

Your personal data collected and processed in accordance with the relevant legislation can be stored both in the digital environment and physical environment by transferring to the physical archives and/or information systems of AGM.

Your personal data can be stored as long as required by the processing purposes. In case of no other reason or legal reason, no international law or regulation or disappearance of the contractual obligations, your personal data, the processing purposes of which have disappeared, is erased, destroyed or anonymized. 

5. PARTIES TO WHICH THE PERSONAL DATA IS TRANSFERRED AND TRANSFER PURPOSES

Your personal data collected can be transferred by AGM, according to the fundamental principles envisaged in the Law and within the framework of the Law and other legislation, to the hospitals and/or health-care facilities in Turkey, Turkish and/or foreign national doctors and health personnel appointed in these hospitals and/or health-care facilities, insurance companies for the performance of the insurance transactions, business partners and suppliers of AGM, legally authorized public institutions and authorized real persons and legal entities in accordance with the purposes specified above within the framework of the personal data processing conditions and purposes specified in Article 8 and 9 of the Law.

6. PERSONAL DATA COLLECTION METHOD AND LEGAL REASON

Your personal data is collected by AGM for the realization of the purposes specified above and within the printed forms or surveys filled in the physical environment and in the electronic environment through e-mails, web sites, online patient information forms in foreign languages, social media accounts and verbal, written and similar channels.    

Your personal data collected will be processed for the purposes specified in this Clarification Text hereby with your explicit consent given within the framework of the first paragraph of Article 5 of the Law and within the framework of the second paragraph of the same Article, in accordance with the conditions of a) It is expressly provided for by the laws; b) It is necessary for the protection of life or physical integrity of the person himself/herself or of any other person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid; c) Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract; ç) It is necessary for compliance with a legal obligation to which the data controller is subject; d) Personal data have been made public by the data subject himself/herself; e) Data processing is necessary for the establishment, exercise or protection of any right and f) Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

The special category personal data except for the health and sexual life specified in the first paragraph of Article 6 of the Law will be processed without seeking explicit consent of the data subject in cases envisaged in the Laws. And personal data concerning health and sexual life will only be processed by the persons subject to secrecy obligation or authorized institutions and organizations for the protection of public health, performance of the preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services and their financing according to the third paragraph of the same Article without seeking explicit consent.

In cases requiring explicit consent according to the relevant articles, the explicit consent is received. However, as stated above, on condition of complying with the conditions specified in Article 5 of the Law, it is possible to process personal data without receiving the consent of the data subject.

7. AS THE DATA SUBJECT, YOUR RIGHTS SPECIFIED IN ARTICLE 11 OF THE LAW

As the data subject, we hereby inform that you are entitled to the below stated rights in accordance with Article 11 of the Law:

  • to learn whether your personal data has been processed or not;
  • to request information if your personal data has been processed;
  • to learn the purpose of the processing of your personal data and whether this personal data is used in compliance with the purpose;
  • to know the third parties to whom your personal data has been transferred in country or abroad;
  • to request the rectification of the incomplete or inaccurate data, if any, and to request the reporting of the transaction carried out within this framework to third parties to whom your personal data has been transferred;
  • Despite being processed according to the Law and other relevant legal provisions, in case of the disappearance of the reasons requiring processing, to request the erasure or destruction of your personal data and to request the reporting of the transaction carried out within this framework to third parties to whom your personal data has been transferred;
  • to object to the occurrence of a result against yourself by analyzing the data processed solely through automated systems and
  • to claim compensation for the damage arising from the unlawful processing of your personal data.

In case you request to contact us for your demands:

Within the framework of the Law No. 6698, in case you request to contact us, give feedback or address your questions, you can personally deliver by hand your petition including the documents certifying your identity and your demand to AGM Stratejik Çözümler Turizm Sağlık ve Kreş Hizmetleri Dış Ticaret A. Ş. located at the address of Birlik Mahallesi 488. Sokak No: 7 Çankaya/Ankara; send through notary to the same address or apply by sending an e-mail to kvkk@healthinturkey.com address.

The written applications made regarding the issue within this framework will be accepted following the identity authentication carried out by us and depending on the qualification of your demand, your applications will be finalized free of charge within the shortest time and within thirty days at the latest. However, in case the transaction requires an additional cost in accordance with the second paragraph of Article 13, a fee can be requested from your party based on the tariff to be determined by the Personal Data Protection Board.

 

EXPLICIT CONSENT TEXT REGARDING THE PROTECTION OF PERSONAL DATA IN ACCORDANCE WITH THE PERSONAL DATA PROTECTION LAW NO. 6698 (“KVKK”)

In accordance with the importance placed on the security of your personal data by AGM Stratejik Çözümler Turizm Sağlık ve Kreş Hizmetleri Dış Ticaret A. Ş. (“AGM”), your personal data, including all special category personal data, sent to us within the printed forms or surveys filled in the physical environment and in the electronic environment, through e-mails, web sites, patient information forms in foreign languages, social media accounts and verbal, written and similar channels are collected as to provide the medical examination, diagnosis, treatment and nursing intermediary services to be received in the hospitals in Turkey and for the purposes specified in the Clarification Text presented to you. Your special category personal data, particularly your health data, and general category health data are processed and stored by AGM in accordance with the Personal Data Protection Law No. 6698 and according to the legislation, can be shared with the hospitals and/or healthcare facilities in Turkey, Turkish and/or foreign national doctors and health personnel appointed in these hospitals and/or healthcare facilities, insurance companies for the performance of the insurance transactions, business partners and suppliers of AGM, legally authorized public institutions and authorized real persons and legal entities for the performance of your demand, procurement of our services and/or to the extent required by your agreement. We kindly request you to read the "Clarification Text" prepared in accordance with the Article of the Law titled “Obligation of Data Controller to Inform” with respect to your personal data collected, stored and processed by our Company and your rights within the framework of the relevant Law and other legislation.   


 

 

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