Information Notice on the Processing of Personal Data

As Smile Antalya Oral and Dental Health Private Health Services Trade Ltd. Co. (Smile Antalya Ağız ve Diş Sağlığı Özel Sağlık Hizmetleri Tic. Ltd. Şti.), referred to as the COMPANY and the data controller, we are committed to the “Personal Data Protection Law No. 6698” (hereinafter referred to as KVKK).

This information notice has been prepared within the framework of Article 10 of the KVKK, titled “Obligation of the Data Controller to Inform.” While obtaining your personal data, we aim to transparently inform you about the purposes for which your personal data will be processed, to whom and for what purposes the processed personal data may be transferred, the method and legal reasons for collecting your personal data, and your rights as the data subject under Article 11 of the relevant law.
Your personal data will be collected, processed, stored, updated in case of any changes, transferred to third parties in accordance with the law, and classified by the COMPANY as the data controller under the conditions explained below. The explanations made for “Your Personal Data” in this Information Notice also cover your “Special Categories of Personal Data.”

1. PERSONAL DATA COLLECTED FROM YOU AS THE DATA SUBJECT

The personal data requested from you are not based on the condition of providing service.

For Patients Who Will Be Examined or Treated:
i) Your Identity Information:

• If you are a Turkish citizen:
  
  1. Your name, surname, Turkish ID number, gender, date of birth, identity number
• If you are not a Turkish citizen:
  2. Your name, surname, nationality, temporary identity number or passport number, gender, date of birth,

ii) Your Contact Information:
3. Your address in Turkey

4. Your GSM number, email address
   (THE DATA LISTED IN ITEMS 1-4 ARE PROCESSED WITH YOUR EXPLICIT CONSENT UNDER ARTICLE 5/1 OF KVKK.)

iii) Test/Analysis Results Obtained During Examination and Treatment:
5. Laboratory and imaging results, dental X-rays, test results, examination data, prescription information, past illnesses, chronic conditions, blood type, medical diagnosis, and health data obtained during the provision of medical diagnosis, treatment, and care services are processed to monitor the process in the patient follow-up file created within the COMPANY (processed for the purpose of carrying out medical diagnosis, treatment, and care services under Article 6/3f of KVKK).

6. Financial data such as payment and billing information

7. Private health insurance and SGK data

8. Data related to your private health insurance and Social Security Institution data for the purpose of financing and planning health services

9. Social Security Institution data within the scope of services financed by the SGK
   (THE DATA LISTED IN ITEMS 5-9 ARE PROCESSED FOR THE PURPOSE OF FULFILLING LEGAL OBLIGATIONS UNDER ARTICLE 5/Ç OF KVKK.)

10. Comments, responses, and evaluations you have made on the COMPANY’s website and social media accounts (processed because it is made public by the data subject under ARTICLE 6/D OF KVKK).

11. Closed-circuit camera images taken during your visits for examination and treatment processes within the COMPANY (each camera within our hospital has a QR code to direct you to this information notice that you can see).

12. Personal data, location information shared with us in forms and surveys filled out on the website https://smileantalya.com.

For Visitors:
13. Your degree of kinship to the patient,

14. Closed-circuit camera images taken during your visits to the COMPANY (each camera within the COMPANY has a QR code to direct you to the information notices you can see).

For Employees and Physicians:
Personal Data Collected During Job Application

15. Your name, surname, gender,
16. Undergraduate and Associate Degree education information,
17. Your field of expertise,
18. Your GSM number, email address,
19. Your foreign language proficiency level,
    (THE DATA LISTED IN ITEMS 11-19 ARE PROCESSED WITH YOUR EXPLICIT CONSENT UNDER ARTICLE 5/1 OF KVKK.)

Personal Data Collected from Employees and Physicians
20. Your name, surname, gender, Turkish ID number, identity or passport photocopy

21. Your address,
22. Your GSM number, email information,
23. Your bank account number/IBAN number where the salary will be deposited (financial data),
24. Your health committee report showing that there is no obstacle to performing the profession,
25. Your field of expertise (THE DATA LISTED IN ITEMS 20-25 ARE PROCESSED FOR THE PURPOSE OF FULFILLING LEGAL OBLIGATIONS UNDER ARTICLE 6/Ç OF KVKK.)

2. PURPOSE OF PROCESSING YOUR PERSONAL DATA

• Processed with your explicit consent under Article 5/1 of KVKK.
• Processed for the purpose of fulfilling legal obligations under Article 5/1ç of KVKK.
• Processed for the purpose of making it public by the data subject under Article 5/1d of KVKK.
• If you apply for a job at the COMPANY, during and after the hiring process; checking the compliance of experience, knowledge, and skills with the required criteria,
• For the employees of the COMPANY, fulfilling obligations arising from employment contracts and/or legislation,
• Ensuring the security of the COMPANY’s assets and/or resources,
• Ensuring the execution of contracts signed between the parties and the control of the authorities of the signing parties, planning commercial and/or business strategies in accordance with COMPANY procedures and/or relevant legislation, ensuring commercial business security,
• Ensuring the accuracy and updating of data collected from visitors, patients, employees, physicians, and business partners with whom the COMPANY has a business relationship,
• Planning and execution of talent and career development activities for employees and physicians working within the COMPANY,
• Creating and monitoring visitor and patient records by the COMPANY, ensuring the discipline, security, and supervision of the company’s premises,
• Informing authorized public institutions and organizations upon request in cases required for public security,
• Performing necessary tasks and procedures for the benefit of the parties within the framework of business relationships such as service provision or employer-employee relationships with contracted legal entities,
• Ensuring the execution of necessary operational activities within the COMPANY,
• Managing human resources,
• Taking necessary steps for making, implementing, and realizing commercial decisions,
• Planning and managing internal operations by the Company Management,
• Analyzing health services to improve them by departments such as Quality, Patient Experience, and Information Systems.

3. TO WHOM AND FOR WHAT PURPOSES YOUR PERSONAL DATA MAY BE TRANSFERRED

Your personal data may be shared and transferred in accordance with the provisions of the Health Services Basic Law No. 3359, Decree-Law No. 663 on the Organization and Duties of the Ministry of Health and Its Affiliates, the Private Hospitals Regulation, the Regulation on the Processing and Protection of Personal Health Data, regulations of the Ministry of Health, Articles 8 and 9 of KVKK, and other relevant legislation, within the scope of the purposes specified in Article 2;
• Ministry of Health, affiliated subunits, and family medicine centers,
• Private insurance companies,
• Social Security Institution,
• General Directorate of Security and other law enforcement agencies,
• General Directorate of Population and Citizenship Affairs,
• Turkish Pharmacists’ Association,
• Judicial authorities (Courts and Enforcement Offices),
• Laboratories, medical centers, ambulance services, medical device companies, and healthcare service providers cooperating with the COMPANY for medical diagnosis and treatment,
• The healthcare institution to which the patient is referred or the institution the patient applies to,
• Your authorized legal representatives explicitly authorized by you,
• Lawyers, tax consultants, and auditors with whom the COMPANY collaborates,
• Regulatory and supervisory institutions and official authorities,
• Suppliers with whom the COMPANY collaborates or receives services,
• Cloud service providers with servers located in Turkey for storing personal data.

No data transfer is made abroad.

4. METHODS AND LEGAL REASONS FOR COLLECTING YOUR PERSONAL DATA

Your personal data are collected electronically or physically, either partially or fully automatically, or non-automatically as part of any data recording system, in accordance with Articles 5 and 6 of KVKK.
The legal reasons for collecting and processing your personal data detailed in Article 1 are:
• Private Hospitals Regulation,
• Regulation on the Processing and Protection of Personal Health Data,
• Health Services Basic Law No. 3359,
• Decree-Law No. 663 on the Organization and Duties of the Ministry of Health and Its Affiliates,
• Regulations of the Ministry of Health,
• Turkish Code of Obligations No. 6098,
• Enforcement and Bankruptcy Law No. 2004,
• Labor Law No. 4537,
• Social Insurance and General Health Insurance Law No. 5510,
• Turkish Commercial Code No. 6102,
• Turkish Penal Code No. 5237, and other relevant legislation.

5. YOUR RIGHTS AS THE DATA SUBJECT

Under Article 11 of KVKK, titled “Rights of the Data Subject,” and the additional paragraph dated 07/05/2010 of Article 20 of the Constitution of the Republic of Turkey, titled “Privacy of Private Life,” as the data subject, you have the right to request from the COMPANY:
• To learn whether your personal data is processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing your personal data and whether they are used appropriately for their purpose,
• To know the third parties to whom your personal data is transferred domestically or abroad,
• To request the correction of your personal data if it is incomplete or incorrectly processed,
• To request the deletion or destruction of your personal data under the conditions set forth in Article 7 of KVKK,
• To request that the third parties to whom your personal data has been transferred be informed of the actions taken under Article 11/e and 11/f,
• To object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,
• To request compensation for damages if you suffer damage due to the unlawful processing of your personal data.

6. APPLYING TO THE COMPANY AS THE DATA SUBJECT

Your applications regarding your rights listed above will be answered within 30 days in accordance with Article 13 of KVKK. The application process is generally free of charge. However, if a cost arises due to the completion of the application, the COMPANY may charge you a fee. You can submit your application via:
• Address: Kemerağzı Mah. Yaşar Sobutay Bulv. Tekin Plaza No: 304/23 Aksu/Antalya,
• KEP Address: smileantalya@hs01.kep.tr
• E-mail: info@smileantalya.com
• Web: Smile Antalya

7. COMPANY INFORMATION (DATA CONTROLLER)

• Company Name: Smile Antalya Oral and Dental Health Private Health Services Trade Ltd. Co.
• Address: Kemerağzı Mah. Yaşar Sobutay Bulv. Tekin Plaza No: 304/23 Aksu/Antalya
• Phone: +90 544 733 77 71
• KEP Address: smileantalya@hs01.kep.tr
• E-mail: info@smileantalya.com
• Web: Smile Antalya

Full Name: ____________________________
Signature: ______________
Date: __________

“Confirmed that I have read and understood”: ___________________________________

If the patient is under the age of 18, what is your relationship to the patient?

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Relative’s Full Name: ____________________________
Signature: ______________
Date: __________

“Confirmed that I have read and understood”: ___________________________________

TRANSLATOR

Full Name: ____________________________
Signature: ______________
Date: __________

“I confirm that the patient/relative of the patient has stated that they understand all the information I translated for them.”
(A copy of this form will be provided to you as needed.)