Clarification Text on the Protection and Processing of Personal Data

As Private Beyaz İnci Oral and Dental Health Group (hereinafter referred to as “Beyaz İnci” and/or “Beyaz İnci Oral and Dental Health Polyclinic”), we carry out the collection, processing, purpose of use, transfer, and storage period of personal data, as well as the responsibility for data privacy and protection activities, in accordance with the “Personal Data Protection Law” No. 6698 (KVKK) and its secondary legislation. To this end, we take security measures and inform you of your rights; we attach great importance to the security of your personal data. We retain all personal data shared by our patients in a manner that respects patient privacy and by taking all necessary technical and administrative measures to ensure the appropriate level of security for your personal data.

Pursuant to the letter from the Ministry of Health, General Directorate of Health Information Systems, No. 75730711, regarding “Access to Health Data”.

This Clarification Text on the Protection of Personal Data explains our data protection and processing policy and how we collect, use, transfer, and protect your personal data during the performance of our services.

1. COLLECTION, PROCESSING, AND PURPOSES OF PROCESSING OF PERSONAL DATA

Beyaz İnci processes and stores your personal data within the framework of the legal regulations specified in the Personal Data Protection Law and the provisions of secondary legislation. Your personal data is collected so that healthcare services can be provided within the legal framework and so that Beyaz İnci can fully and properly fulfill its contractual and other legal obligations. While varying depending on the healthcare services provided, personal data is collected through automated or non-automated methods, via channels such as our call center, website, online services, WhatsApp, and similar means, whether verbally, in writing, or electronically.

Your Personal Data;

Your data that may be necessary, including but not limited to: Your name, surname, TR Identity Number, passport number or temporary TR Identity Number, place and date of birth, marital status, gender, and other identity data by which we can identify you, including the contents of the patient file created by our clinic; your address, phone number, email address, and other contact data; your financial data such as payment, credit card, bank information, and billing details; audio and/or digital information obtained by us at various times through electronic or non-electronic methods; video and/or audio camera footage obtained during your visit to our clinic; your general and special category personal data, especially personal health data obtained during the execution of all medical diagnosis, examination, treatment, and care services; your private health insurance data and Social Security Institution data; your health and identity data sent via our website; and your financial data such as payment and billing information, will be processed by our clinic as needed.

Furthermore, your personal data may also be processed when you use our call center or website to access Beyaz İnci’s online services, when you attend training, seminars, or organizations arranged by our clinic, or when you visit or browse our web pages.

Your personal data will be processed within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK. Your special category personal data (especially health data) and your general personal data may be processed by our clinic for the purposes stated below;

Your personal data, including your special category personal data, may be processed for the following purposes:

• Fulfilling our legal obligations under Basic Law on Health Services No. 3359, the Decree-Law on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Private Hospitals Regulation, the Regulation on the Processing and Privacy of Personal Health Data, and other relevant regulations,

• Protection of public health, preventive medicine, medical diagnosis, treatment, and care services,

• Planning the financing of healthcare services,

• Invoicing for our services,

• Sharing requested information with private insurance companies within the scope of healthcare financing,

• Ensuring financial reconciliation with the institutions we have agreements with regarding the healthcare services provided to you,

• Notifying you about your appointment if you have one,

• Communicating campaigns and information via text message, email, or other means,

• Planning the internal operations of your clinic,

• Monitoring and preventing abuse and/or unauthorized transactions,

• Conducting scientific research,

• Responding to all your questions and complaints regarding our healthcare services,

• Taking all necessary technical and administrative measures for data security within our clinic’s systems and applications,

• Analyzing your use of healthcare services to develop and improve the services we provide to you, and preserving your health data, as well as retaining information regarding your health data that must be stored as required by relevant legislation,

• And for similar purposes, including but not limited to measuring patient satisfaction.

Additionally, your personal data may be processed within the framework of Basic Law on Health Services No. 3359, Decree-Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Private Hospitals Law and Regulation, the Regulation on the Processing and Protection of the Privacy of Personal Health Data, Ministry of Health regulations, and other legislative provisions. It may be transferred to the physical archives and IT systems of Beyaz İnci Dental Clinic and/or our suppliers and kept in both digital and physical environments. Furthermore, the data of our clinic’s employees may be processed by us or by real or legal persons with whom we cooperate or whom we have authorized, for operational reasons such as increasing employee satisfaction and ensuring job security and peace, as required by the Labor Law, Social Security Legislation, and other current regulations, and as part of the employer’s right of management.

2. PERSONS AND ORGANIZATIONS TO WHOM YOUR PERSONAL DATA MAY BE TRANSFERRED

Your personal data, within the scope of the Law and similar legislation and for the purposes mentioned above, may be transferred to:

• The Ministry of Health and its affiliated sub-units, Family Health Centers,

• The Social Security Institution,

• Private insurance companies (health, pension, life insurance, etc.),

• The General Directorate of Security and similar law enforcement agencies,

• The Directorate of Population,

• The Turkish Pharmacists’ Association,

• The Turkish Dental Association,

• Public Prosecutor’s Offices, Courts, arbitrators in arbitration proceedings,

• Laboratories, centers, and similar third parties with whom we cooperate for medical diagnosis,

• Your authorized representatives,

• The healthcare institution to which the patient is referred or to which the patient applies,

• Third parties from whom we receive consultancy, including lawyers, tax advisors, and auditors,

• Regulatory and supervisory authorities, official bodies,

• Our suppliers, support service providers, business partners whose services we use or with whom we cooperate, and other third parties, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK.

3. METHOD AND LEGAL BASIS OF PERSONAL DATA COLLECTION

Your personal data is collected through any verbal, written, or electronic means, for the purposes stated above and to provide healthcare services within the determined legal framework, and for Beyaz İnci to fully and properly fulfill its contractual and legal obligations, in accordance with the principles set out in the KVKK.

4. YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

Regarding your processed personal data, under the legislation, you have the right to:

• Learn whether your personal data is being processed and, if so, request information about it,

• Access your personal health data and request this data, learn the purpose of the processing, and whether it is used in line with its purpose,

• Know the third parties to whom your personal data is transferred, both domestically and abroad,

• Request the rectification of incomplete or inaccurate personal data, and request the erasure or destruction of personal data,

• Request that the rectification, erasure, or destruction of personal data be notified to the third parties to whom the data was transferred,

• Object to the emergence of a result against you, exclusively through analysis by automated systems,

• Request compensation for damages incurred due to the unlawful processing of personal data.

Beyaz İnci protects your personal data in accordance with the legal regulations mandated by law. Our clinic has taken and will continue to take administrative and technical security measures to protect your personal data. You can submit your requests under the Law to the email address bilgi@beyazincidis.com, or by filling out the Application Form available at our centers and delivering it in person or sending it via a notary to Sırakapılar Mah. 495 Sk. No:11 Merkezefendi – DENİZLİ, or by sending it with a secure electronic signature to ozelbilimagiz@hs03.kep.tr.