What personal data may we collect from you?

When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual.

Accordingly, we may hold and use personal data about you as a customer, a patient or in any other capacity, for example, when you visit one of our websites, complete a form, access our services or speak to us. Depending on what services you receive from us this may include sensitive personal data such as information relating to your health.

Personal data we collect from you may include the following:

• Information that you give us when you enquire or become a customer or patient of us or apply for a job with us including name, address, contact details (including email address and phone number)
• The name and contact details (including phone number) of your next of kin
• Details of referrals, quotes and other contact and correspondence we may have had with you
• Details of services and/or treatment you have received from us or which have been received from a third party and referred on to us
• Information obtained from customer surveys, promotions and competitions that you have entered or taken part in
• Recordings of calls we receive or make notes and reports about your health and any treatment and care you have received and/or need, including about clinic and hospital visits and medicines administered
• Patient feedback and treatment outcome information, you provide
• Information about complaints and incidents
• Information you give us when you make a payment to us, such as financial or credit card information
• Other information received from other sources, including from your use of websites and other digital platforms we operate (apps) or the other services we provide, information from business partners, advertising networks, analytics providers, or information provided by other companies who have obtained your permission to share information about you.

Where you have named someone as your next of kin and provided us with personal data about that individual, it is your responsibility to ensure that that individual is aware of and accepts the terms of this Privacy Policy.

Where you use any of our websites, we may automatically collect personal data about you including technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,

The data that we request from you may include sensitive personal data. This includes information that relates to the mental or physical health or racial or ethnic origin (which may include children’s data). By providing us with sensitive personal data, you give us your explicit consent to process this sensitive personal data for the purposes set out in this Privacy Policy.

When do we collect personal data about you?

We may collect personal data about you if you:

• Visit one of our websites
• Enquire about any of our services or treatments
• Register to be a customer or patient with us or book to receive any of our services or treatments
• Fill in a form or survey for us
• Carry out a transaction on our website
• Participate in a competition or promotion or other marketing activity
• Make payments
• Contact us, for example by email, telephone, online websites or social media
• Participate in interactive features on any of our and partner websites.
• In the interests of training and continually improving our services, calls to the Doctor and its agents may be monitored or recorded.

What personal data we may receive from third parties and other sources?

• We may collect personal data about you from third parties;
• We may be passed medical information usually in the form of a referral for the purposes of your treatment with the Doctor or a third-party consultant;
• Consultants may need to share your personal data and medical records with the Doctor;
• Insurance providers will pass the Doctor personal data of patients who have commenced a claim and require medical treatment with the Doctor. This will normally be in the form of a referral and may consist of basic details e.g full name, date of birth, address, contact number and email address and the type of procedure/treatment they require.

How do we use your personal data?

Your personal data will be kept confidential and secure and will, unless you agree otherwise, only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws, clinical records retention periods and clinical confidentiality guidelines.

Sensitive personal data related to your health will only be disclosed to those involved with your treatment or care, or in accordance with Turkish laws and guidelines of professional bodies or for the purpose of clinical audits (unless you object). Further details on how we use health related personal data are given below. We will only use your sensitive personal data for the purposes for which you have given us your explicit consent to use it. Please note that, although we have set out the purposes for which we may use your personal data below, we will not use your sensitive personal data for those purposes unless you have given us your explicit consent to do so.

We may use your personal data to:

• Enable us to carry out our obligations to you arising from any contract entered into between you and us including relating to the provision by us of services or treatments to you and related matter such as, billing, accounting and audit, credit or other payment card verification and anti-fraud screening
• Provide you with information, products or services that you request from us
• Provide you with information about products or services we offer that we feel may interest you.
• Allow you to participate in interactive features of our services, when you choose to do so
• Notify you about changes to our products or services
• Respond to requests where we have a legal or regulatory obligation to do so
• Check the accuracy of information about you and the quality of your treatment or care, including auditing medical and billing information for insurance claims as well as part of any claims or litigation process
• Support your personal doctor (PD), nurse or other healthcare professional
• Assess the quality and/or type of care you have received (including giving you the
• Opportunity to complete customer satisfaction surveys) and any concerns or complaints you may raise, so that these can be properly investigated
• To conduct and analyze market research
• To ensure that content from any of our websites is presented in the most effective manner for you and for your computer.

The security of your personal data

We protect all personal data we hold about you by ensuring that we have appropriate organizational and technical security measures in place to prevent unauthorized access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged. We conduct assessments to ensure the ongoing security of our information systems.

Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable Turkish laws.

Personal data that we collect from you may be transferred to, and stored at, a destination outside Turkey. It may also be processed by staff operating outside Turkey who work for us or for one of our suppliers. Where we transfer your personal data outside Turkey, we will ensure that there are adequate protections in place for your rights, in accordance with Data Protection Laws. By submitting your personal data, and in providing any personal data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

All information you provide to us is stored securely. Any payment transactions will be processed securely by third party payment processors. If we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

The transmission of information via the internet cannot be guaranteed as completely secure. However, we ensure that any information transferred to our websites is via an encrypted connection. Once we have received your information, we will use strict procedures and security features for prevention of unauthorized access.

At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so at your own risk.

Disclosure of your personal data

In the usual course of our business, we may disclose your personal data (to the extent necessary) to certain third-party organizations that we use to support the delivery of our services. This may include the following:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you,
• Organizations providing IT systems support and hosting in relation to the IT systems on which your information is stored,
• Third party debt collectors for the purposes of debt collection,
• Delivery companies for the purposes of transportation,
• Third party service providers for the purposes of storage of information and
• Confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.

Where a third-party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.

We may also disclose your personal data to third parties in the event that we sell or buy any business or assets or where we are required by law to do so.

Health information collected during provision of treatment or services

Sensitive personal data (including information relating to your health) will only be disclosed to third parties in accordance with this Privacy Policy. That includes third parties involved with your treatment or care, or in accordance with Turkish laws and guidelines of appropriate professional bodies. Where applicable, it may be disclosed to any person or organization who may be responsible for meeting your treatment expenses or their agents. It may also be provided to external service providers and regulatory bodies (unless you object) for the purpose of clinical audit to ensure the highest standards of care and record keeping are maintained.

Medical professionals working with us: We share clinical information about you with our medical professionals as we think necessary for your treatment. Medical professionals working with us might be our employees, or they might be independent consultants in private practice. In the case of independent consultants, the consultant is the data controller of your personal data, either alone or jointly with us and will be required to maintain their own records in accordance with Data Protection Laws and applicable clinical confidential guidelines and retention periods. Where that is the case, we may refer you to that consultant to exercise your rights over your data. Our contracts with consultants require them to cooperate with those requests. In all circumstances, those individual consultants will only process your personal data for the purposes set out in this Privacy Policy or as otherwise notified to you.

External practitioners: If we refer you externally for treatment, we will share with the person or organization that we refer you to, the clinical and administrative information we consider necessary for that referral. It will always be clear when we do this.

Your Personal Doctor (PD): If the practitioners treating you believe it to be clinically advisable, we may also share information about your treatment with your PD. You can ask us not to do this, in which case we will respect that request if we are legally permitted to do so, but you should be aware that it can be potentially very dangerous and/or detrimental to your health to deny your PD full information about your medical history, and we strongly advise against it.

Your insurer: We share with your medical insurer information about your treatment, its clinical necessity and its cost, only if they are paying for all or part of your treatment with us. We provide only the information to which they are entitled. If you raise a complaint or a claim we may be required to share personal data with your medical insurer for the purposes of investigating any complaint/claim.

Medical regulators / Social Security Authorities (SAA): We may be requested – and in some cases can be required - to share certain information (including personal data and sensitive personal data) about you and your care with medical regulators for example if you make a complaint, or the conduct of a medical professional involved in your treatment is alleged to have fallen below the appropriate standards and the regulator wishes to investigate. We will ensure that we do so within the framework of the law and with due respect for your privacy.

From time to time we may also make information available on the basis of necessity for the provision of healthcare, but subject always to patient confidentiality.

In an emergency and if you are incapacitated, we may also process your personal data (including sensitive personal data) or make personal data available to third parties on the basis of protecting your ‘vital interest’ (i.e. your life or your health).

We will use your personal data in order to monitor the outcome of your treatment by us and any treatment associated with your care, including any SSA treatment.

We participate in national audits and initiatives to help ensure that patients are getting the best possible outcomes from their treatment and care. The highest standards of confidentiality will be applied to your personal data in accordance with Data Protection Laws and confidentiality. Any publishing of this data will be in anonymized, statistical form. Anonymous or aggregated data may be used by us, or disclosed to others, for research or statistical purposes.

Marketing

If you have consented to our processing your personal data for marketing purposes, in accordance with this Privacy Policy, we may send you information (via mail, email, phone or SMS) about our products and services which we consider may be of interest to you.

You have the right to ask us not to process your information in this way at any time.

Accessing and updating your information

By applying to us as the person concerned in accordance with the Law on the Protection of Personal Data article 11 you have the rights;

• To learn whether personal data is processed or not,
• To request information about personal data if it has been processed,
• To learn the purpose of processing personal data and whether they are used conforming the purpose,
• To know the third parties which personal data is transferred domestically or abroad,
• If your personal data is incomplete or improperly processed, request that they be corrected and that the transaction in this context be notified to third parties that your personal data has been transferred,
• In the event that the reasons for processing your personal data for consideration within the scope of the purpose, duration and constitutional principles are eliminated, you must request the deletion or destruction of your personal data and request that the transaction carried out in this context be notified to third parties to whom the personal data was transferred, even though it has been processed in accordance with,
• To object the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
• To claim damages in the event of a corruption due to the processing of personal data in a way that violates the law.

If you wish, your applications and requests regarding your personal data can be:

• By using the Application Form,
• By sending a petition with an original signature and a photocopy of identity to the address of Hakkı Yeten Cad. Unimed Center No.19 Kat 4 Fulya, Şişli, İstanbul, Turkey
• By applying to our company's commercial center address, Hakkı Yeten Cad. Unimed Center No.19 Kat 4 Fulya, Şişli, İstanbul, Turkey with a valid ID card.,
• By sending an email/application form to our e-mail address emre@emrebakircioglu.com  

In accordance with the communiqué on the procedures and principles of application to the data officer, the person concerned, name, last name in the application, if the application is written signature, ID number (in case of foreign applicant, passport number), notification mainly residential or business address on the basis of the notification e-mail address, telephone number, and fax number on the topic of demand information should be available.

The person concerned must clearly and explicitly state their claims in the application, which includes explanations of their rights to exercise the above-mentioned rights. Information and documents regarding the application must be attached to the application.

Although the subject of the request must be related to applicant, if the applicant is acting on behalf of someone else, the applicant must be specially authorized in this regard and this authority must be documented (special power of attorney). In addition, the application must contain identity and address information and documents confirming the identity must be attached to the application.

Requests made by unauthorized third parties on behalf of someone else will not be taken into consideration.

How Long Will Your Requests Regarding Processing Your Personal Data Be Answered 

Your requests regarding your personal data will be evaluated and answered within 30 days at the latest starting from the date they reach us. If your request is evaluated negatively, the reasons for the rejection are sent to the address you specified in the application via e-mail or mail.