As Dr. Dt. Ebru Çetinkaya Tokmak (referred to under the applicable legislation as the “Data Controller: Dr. Dt. Ebru Çetinkaya Tokmak”), we attach great importance to the security and privacy of the personal data of our patients and website visitors. We endeavour to implement the highest reasonably available technical and administrative security measures for the processing and protection of such data.
We process your personal data in our capacity as the “data controller” within the scope of the Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and the relevant legislation, as explained below. In accordance with the KVKK and secondary legislation, we fulfil our responsibilities regarding the collection, purposes of use, processing, transfer, retention periods, confidentiality and protection of personal data.
This Privacy Notice has been prepared in accordance with Article 10 of the KVKK concerning the data controller’s obligation to inform. Its purpose is to provide you with transparent information regarding the identity of the data controller, the methods and legal grounds for collecting your personal data, the purposes for which such data may be processed, the persons or organisations to whom such data may be transferred and for what purposes, the duration of data processing, and your rights under Article 11 of the KVKK.
References in this Privacy Notice to “Personal Data” also include “Special Categories of Personal Data”, including health data.
1. COLLECTION, PROCESSING AND PURPOSES OF PROCESSING PERSONAL DATA
Dr. Dt. Ebru Çetinkaya Tokmak processes and retains your personal data in accordance with the requirements of the Law on the Protection of Personal Data and the applicable secondary legislation.
Your personal data is collected for purposes including the lawful provision of healthcare services, carrying out examination, diagnosis and treatment processes, and properly fulfilling contractual and other legal obligations.
Depending on the healthcare services provided, your personal data may be collected by automated or non-automated means, verbally, in writing or electronically, through channels including the call centre, website (ebrucetinkaya.com), social media platforms, online services, WhatsApp, email and similar communication channels.
Your personal data may continue to be created, updated and processed throughout your relationship with our clinic and may be retained in both digital and physical environments.
Personal Data We Process
Identity Information: Your name, surname, Turkish Republic identification number, passport number or temporary Turkish Republic identification number, place and date of birth, marital status, gender and information contained in the patient file created by our clinic.
Contact Information: Your address, telephone number, email address and other contact details.
Financial Information: Payment information, credit card information, banking information and billing details.
Visual and Audio Information: Audio and/or digital information obtained through electronic or non-electronic means at various times, as well as video and/or audio recordings obtained during your visits to our clinic.
Health Data and Special Categories of Personal Data: Personal health data obtained during the provision of medical diagnosis, examination, treatment and care services, including orthodontics, clear aligner treatment and other orthodontic treatment services, as well as information relating to private health insurance and the Social Security Institution.
Purposes for Processing Your Personal Data
- Fulfilling our legal obligations under Law No. 3359 on Basic Healthcare Services, regulations issued by the Ministry of Health and other applicable legislation,
- Protecting public health and carrying out preventive medicine, medical diagnosis, treatment and care services,
- Planning healthcare services and their financing,
- Issuing invoices for the services provided,
- Informing you about your appointment where an appointment has been made, including via SMS, email, telephone call or WhatsApp,
- Monitoring and preventing misuse and/or unauthorised transactions,
- Responding to questions and complaints regarding our healthcare services,
- Implementing the necessary technical and administrative measures to ensure the data security of our systems and applications,
- Measuring patient satisfaction and improving the healthcare services we provide.
2. PERSONS AND ORGANISATIONS TO WHOM YOUR PERSONAL DATA MAY BE TRANSFERRED
Your personal data may be transferred, within the scope of the KVKK and other applicable legislation and for the purposes described above, to the following persons and organisations:
- The Ministry of Health of the Republic of Türkiye and its affiliated units, including Provincial Directorates of Health,
- The Social Security Institution (SGK),
- Private insurance companies, including health, pension and life insurance providers,
- The General Directorate of Security and other competent law enforcement authorities,
- Public Prosecutors’ Offices, courts and other competent judicial authorities,
- Domestic and international laboratories, centres and suppliers with whom we cooperate for medical diagnosis, analysis, laboratory services, or the production of clear aligners and orthodontic appliances,
- Your authorised representatives or legal guardians,
- Other healthcare institutions to which the patient is referred or to which the patient independently applies,
- Third-party professional advisers from whom we receive services, including lawyers, tax advisers and auditors,
- Information technology suppliers, infrastructure providers and business partners whose services we use or with whom we cooperate.
Such transfers may be carried out in accordance with the conditions specified under Articles 8 and 9 of the KVKK.
3. METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
Your personal data is collected verbally, in writing or electronically in accordance with the principles set out in the KVKK, for the purposes stated above, to enable healthcare services to be provided within the applicable legal framework and to ensure the proper fulfilment of our contractual and statutory obligations.
4. DATA PROCESSING AND RETENTION PERIOD
Your personal data will be processed only for the purposes specified in this Privacy Notice and will be retained in accordance with the processing, retention and limitation periods prescribed by the healthcare legislation applicable to us and all other relevant laws.
If statutory data processing or retention periods are amended, the newly applicable legal periods will be taken into account.
5. YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA
Under the applicable legislation, you have the following rights in relation to your personal data:
- To learn whether your personal data is being processed and, if so, to request information regarding such processing,
- To access and request your personal health data,
- To learn the purpose for which your personal data is processed and whether it is being used in accordance with that purpose,
- To know the third parties in Türkiye or abroad to whom your personal data has been transferred,
- To request correction of your personal data where it has been processed incompletely or inaccurately,
- To request the deletion or destruction of your personal data in accordance with the conditions set out under the KVKK and to request that such actions be notified to third parties to whom the data has been transferred,
- To object to any outcome arising against you as a result of the analysis of processed personal data exclusively through automated systems,
- To request compensation for damages where you suffer loss as a result of the unlawful processing of your personal data.
You may submit requests concerning your rights under the KVKK through the communication channels available at ebrucetinkaya.com, deliver a signed application in person to Üründül Plaza, Ahmet Yesevi, Sanayi Cd. No:517C, 16140 Nilüfer/Bursa, send it through a notary public, or submit it using a secure electronic signature.
Your requests will be reviewed and answered in writing or electronically, depending on their nature, as soon as possible and no later than thirty days. Applications will be processed free of charge, subject to any fees or costs permitted under the applicable legislation.
Data Controller: Dr. Dt. Ebru Çetinkaya Tokmak
Website: https://ebrucetinkaya.com/
Address: Üründül Plaza, Ahmet Yesevi, Sanayi Cd. 517C, 16140 Nilüfer/Bursa