Privacy Notice

1. DATA CONTROLLER

Pursuant to Law No. 6698 on the Protection of Personal Data (“Law No. 6698”), your personal data may be processed within the scope described below by Özel Küçükçekmece International Plus Ağız ve Diş Sağlığı Polikliniği – License Holder Bfr Ağız Ve Diş Sağlığı Hizmetleri A.Ş., acting as the data controller.

Address: Halkalı Merkez Mah. Basın Ekspres Cad. Capıtal Tower No: 9 Ic Kapı No: 5 Küçükçekmece İstanbul

Website: https://www.internationalplusclinic.com

Özel Küçükçekmece International Plus Ağız ve Diş Sağlığı Polikliniği (hereinafter referred to as “International Plus” or the “Clinic”) and its staff attach great importance to the security of your personal data provided to us during the healthcare services offered to you. Accordingly, all personal data held within our organization is processed, stored, and transferred in compliance with Law No. 6698 on the Protection of Personal Data (the “Law”). This notice has been prepared by International Plus, in its capacity as “Data Controller,” pursuant to Article 10 of the Law, titled “Obligation of the Data Controller to Inform,” regarding the personal data collected, stored, and processed by us.

2. PERSONAL DATA AND THE PURPOSE OF PROCESSING PERSONAL DATA

Your personal data is collected by International Plus in verbal, written, visual, or electronic form for the purpose of planning and executing medical diagnosis, examination, treatment, and care services, as well as planning and managing healthcare services and their financing, in a manner consistent with the scope of International Plus’s activities. Your personal data — including your sensitive personal data and general personal data, particularly your health data — may be processed by the Clinic in connection with, and limited and proportionate to, the purposes set forth in this article, including but not limited to the data listed below:

Personal Data:

• Identity Data: Your name and surname, Turkish ID number, passport number or temporary Turkish ID number, nationality, place and date of birth, marital status, gender, insurance or patient protocol number, and other identity data that may identify you
• Contact Data: Your address, telephone number, a relative’s telephone number, your e-mail address
• Financial Data: Your bank account number, IBAN number, credit card information
• Data relating to private health insurance for the purposes of planning and financing healthcare services, and Social Security Institution data
• Health Data: Blood type, the patient’s complaint, examination data, radiological examination information, test results, diagnosis and operation information, medical history data, family medical history data, surgical history, appointment information, prescription information, information on medications used, infectious disease information, allergy information, pre-examination consultation, and all health-related personal data shared with your doctor or the Clinic during the diagnosis, treatment, and follow-up process — including but not limited to digital channels (e-mail, SMS, social media, digital messaging platforms, etc.) — or obtained as a result thereof
• Visual and Audio Data: Data obtained from security camera recordings maintained for security and audit purposes during your visit to our facility, voice call recordings maintained by customer representatives or patient services in accordance with call center standards, photograph and video data taken before, during, and after treatment, and your clinical follow-up videos
• Browsing information, IP address, browser information, surveys, form data, and other personal data on the website at https://www.internationalplusclinic.com

All personal data collected by International Plus (including but not limited to sensitive personal data) may be processed for the following purposes:

• Verifying your identity
• Planning and executing medical diagnosis, examination, treatment, and care services; planning and managing healthcare services and their financing
• Creating a patient file; conducting storage and archiving activities
• Executing international patient coordination processes
• Planning organizations within the scope of health tourism
• Planning and managing the Clinic’s internal operations and daily procedures
• Ensuring appointment scheduling
• Responding to any questions and complaints regarding the healthcare services you have received
• Sharing information required by the Ministry of Health and other public institutions and authorities, and fulfilling reporting and notification obligations in accordance with applicable regulations
• Responding to requests from authorized public institutions and organizations
• Fulfilling obligations arising from applicable legislation
• Fulfilling the burden of proof in potential legal disputes
• Measuring, improving, and researching patient satisfaction by the patient management, patient rights, and patient experience departments
• Providing information about the services you are receiving, complementary services, and new services
• Conducting analyses for the purpose of developing healthcare services
• Covering your health service costs, diagnostic, and treatment expenses by the Patient Services, Financial Affairs, and Marketing departments; sharing information required within the scope of eligibility queries with private insurance companies
• Executing billing and accounting operations
• Sharing information required with private insurance companies within the scope of financing healthcare services, and confirming your relationship with contracted institutions
• Participating in campaigns and providing campaign information, conducting advertising activities, designing and delivering customized content, tangible and intangible benefits through web and mobile channels by the Marketing, Media and Communications, and Call Center departments. Personal data processing activities for campaign, discount, promotional, and advertising purposes are carried out exclusively with the explicit consent of the data subject. If explicit consent is not provided, data shall not be processed for these purposes.

Under the Law, personal data is defined as any information relating to an identified or identifiable natural person. All data falling within this scope shall be evaluated in accordance with the applicable legislation within the Clinic.

3. METHOD OF COLLECTION AND LEGAL BASIS FOR PERSONAL DATA

Method of Collection of Personal Data; Personal data is collected:

• through international patient consultants and intermediary organizations
• through our company’s website
• through social media platforms
• through mobile applications
• through physical patient registration forms
• through electronic patient registration systems
• through telephone and e-mail
• through security cameras
• through interviews

and through all other verbal, written, or electronic means, without limitation.

The legal bases for the collection of your personal data are:

• Necessity for the performance of the contract concluded with you
• Necessity for the processing of your personal data to fulfill our legal obligations
• Necessity for the exercise or protection of our legal or contractual rights
• Necessity of processing your personal data for our legitimate interests, provided that such processing does not harm your fundamental rights and freedoms

 

Your personal data may be collected, updated, and processed while you are benefiting from the healthcare services of our Clinic, when you call the Clinic’s call center, when you visit the Clinic’s premises, website, WhatsApp line, or social media accounts.

The personal data we collect through the above methods may also be processed without your explicit consent, where at least one of the following conditions is met:

• The processing is required by the provisions of laws and regulations in force in the Republic of Turkey
• It is necessary to protect the life or bodily integrity of yourself or another person where you are physically unable to provide your explicit consent
• Your personal data has been made publicly available by yourself
• It is necessary for the establishment, exercise, or protection of a right
• It is necessary for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and the planning, management, and financing of health services, by persons subject to an obligation of confidentiality or by competent institutions and organizations
• It is necessary for the fulfillment of legal obligations in the fields of employment, occupational health and safety, social security, social services, and social assistance

4. TRANSFER OF PROCESSED PERSONAL DATA

International Plus may share your personal data, for the purposes described above, with the following parties in accordance with Articles 8 and 9 of Law No. 6698 and other applicable regulations:

• With contracted intermediary organizations operating within the scope of health tourism
• Within the scope of contracts with Clinic employees, physicians employed at the Clinic, subcontractor clinics providing services on a permanent or temporary basis, business partners, or third parties cooperated with, to the extent and for the duration required by the nature of the work, in order to continue the Clinic’s activities and business processes
• Data may be transferred to official authorities and public institutions where necessary

Your collected personal data may be shared — for the reasons, purposes, and regulatory framework specified above — not only for internal use by the Clinic, but also with the Social Security Institution, the Ministry of Health and its affiliated units, contracted physicians and private hospitals, private health insurance companies, contracted laboratories, law enforcement agencies and all judicial authorities, your authorized representatives, lawyers, tax and financial advisors and auditors including third parties from whom we receive consultancy services, regulatory and supervisory authorities, domestic/foreign service providers from whom we receive IT support (server, hosting, software, cloud computing, etc.), institutions and organizations with which we cooperate to conduct our activities, domestic/foreign companies from which we receive services for sending commercial electronic messages, contracted banks, various domestic/foreign advertising companies, agencies and survey firms, other domestic/foreign business partners, and legally authorized public institutions and private persons, both domestically and abroad, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of Law No. 6698.

The transfer of your personal data abroad shall be carried out to countries declared by the Personal Data Protection Board to provide adequate protection pursuant to Article 9 of Law No. 6698, or where adequate protection is not available in the relevant country, upon the submission of a written undertaking by the data controllers and the receipt of authorization from the Board.

 

Any transfer of personal data that is inconsistent with our activities and beyond the purposes stated above shall not be shared with third parties/institutions/organizations without the explicit consent of the data subject, except in cases of legal necessity.

5. DATA PROCESSING PERIOD

Your personal data shall be processed in accordance with the data processing and limitation periods set forth in the applicable legislation and all relevant laws and regulations to which the Clinic is subject, limited to the purposes set forth in this Privacy Notice. In the event of any amendment to the data processing periods stipulated by law, the newly determined periods shall be applied.

6. RIGHTS OF THE DATA SUBJECT WHOSE PERSONAL DATA IS PROCESSED

Pursuant to Article 11 of the Law, the personal data owner has the right to apply to the Clinic and:

• Learn whether their personal data is being processed
• Request information if their personal data has been processed
• Learn the purpose of processing their personal data and whether it is being used in accordance with its purpose
• Know the third parties to whom their personal data has been transferred domestically or abroad
• Request the correction of their personal data if it has been processed incompletely or inaccurately
• Request the deletion or destruction of their personal data within the framework of the conditions stipulated in Article 7 of Law No. 6698
• Request that third parties to whom their personal data has been transferred be notified of the operations carried out pursuant to subparagraphs (e) and (f) above
• Object to the occurrence of a result against themselves by means of analysis of their personal data exclusively through automated systems
• Request compensation for the damage suffered in the event that their personal data is processed in violation of the law

7. DATA SECURITY

The Clinic protects your personal data in full compliance with all technical and administrative security controls required under information security standards and procedures. Such security measures are provided at a level appropriate to the potential risk, taking into account technological capabilities. The Clinic applies technical and administrative measures such as access authorization, encryption, logging, regular auditing, PDPL training for employees, and recording of data processing activities, in order to protect personal data.

8. IF YOU WISH TO CONTACT US FOR YOUR REQUESTS

Your personal data is carefully protected within the scope of technical and administrative means, and the necessary security measures are provided at a level appropriate to possible risks, taking into account technological capabilities. You may submit your requests within the scope of the Law:

• By sending a petition bearing your wet signature, addressed to Halkalı Merkez Mah. Basın Ekspres Cad. Capıtal Tower No: 9 Ic Kapı No: 5 Küçükçekmece İstanbul Turkey, via cargo/mail, with the note “Information Request within the Scope of the Personal Data Protection Law” written on the envelope,
• Via notary,
• To the address bfragizdis@hs01.kep.tr via secure electronic or mobile signature, registered electronic mail address, or your e-mail address registered in our systems, and/or
• By filling out the “Application Form pursuant to the Personal Data Protection Law” at https://www.internationalplusclinic.com and submitting it to us in the manner specified in the form.

Requests submitted in this context shall be concluded by our Clinic within thirty days at the latest. In case the request is rejected, the reason(s) for rejection shall be communicated in writing or electronically with justification. The Clinic shall respond to such requests free of charge for up to ten pages if the response is to be provided in writing; for each page exceeding ten pages, a processing fee of 1 Turkish Lira shall be charged. In the event that the response to an application is provided on a recording medium such as a CD or flash drive, the fee that may be requested by the Personal Data Protection Authority shall not exceed the cost of the recording medium.

Your collected and processed personal data must be accurate and, where necessary, kept up to date in accordance with Article 4 of Law No. 6698. Therefore, in the event of any change in your personal data, you may notify us of the updated and accurate personal data through the methods specified above.