CLARIFICATION TEXT ON PROCESSING PERSONAL DATA

ÖZLEM BİÇER CLINIC

CLARIFICATION TEXT ON PROCESSING PERSONAL DATA

This Clarification Text has been prepared for the purpose of enlightening the data owners on the principles and procedures with respect to processing the Personal Data of the patients/clients who apply to Dr. Özlem Biçer Clinic (“Dr. ÖZLEM BİÇER”) in accordance with the Law of Protection of Personal Data numbered 6698 (“Law of Protection of Personal Data”) and the European Union Bylaw of Protection of General Data (“Bylaw of Protection of General Data”) contained in the Turkish Law legislation.

It is one of the prioritized targets of Dr. ÖZLEM BİÇER to provide security of the Personal Data of the patients/clients. For this reason, the necessary security measures are taken by Dr. ÖZLEM BİÇER for safe processing of the Personal Data of the patients/clients and preventing any unlawful access or penetration to those data, in conformity with the legislation in force.

DATA CONTROLLER

Your Personal Data shall be processed by Dr. ÖZLEM BİÇER operating at the address of “Barbaros Mah. Menekşe Sok. Deluxia Suit K:17 No:209 Batı Ateşehir/Istanbul” within the scope of the Law of Protection of Personal Data numbered 6698 and the Bylaw of Protection of General Data. Dr. ÖZLEM BİÇER shall be deemed as the “Data Controller” within the scope of the Law of Protection of Personal Data and the “Controller” within the scope of the Bylaw of Protection of General Data.

Dr. ÖZLEM BİÇER has contracted with Attorney Sinem Dökmeci, Personal Data Protection Specialist as “Data Protection Official” within the scope of the Bylaw of Protection of General Data and the Process of Adaptation for Personal Data Protection in Dr. ÖZLEM BİÇER CLINIC was realized under the consultancy and guidance of SİNEM DÖKMECİ LAW OFFICE within the scope of the Law of Protection of Personal Data and the Bylaw of Protection of General Data.

YOUR PERSONAL DATA TO BE PROCESSED

Your Personal Data below shall be processed by Dr. ÖZLEM BİÇER, in conformity with the fundamental principles stipulated in the Law of Protection of Personal Data, article 4 and the Bylaw of Protection of General Data, article 5, on the basis of the Personal Data Processing Conditions and Purposes specified in articles 5 and 6 of the Law of Protection of Personal Data as well as articles 6 and 9 of the Bylaw of Protection of General Data and provided to be kept in the scope of the purposes contained in this Clarification Text, in connection with the intended purpose of processing, as limited and measured, considering the principle of justice and transparency, correctly and actually, taking all sorts of technical and administrative measures stipulated in the legislation for the purpose of providing data security.

1-YOUR IDENTITY DETAILS: Your name and surname, T.R. Identity Number and/or Passport Number and/or Provisional T.R. Identity Number, your place and date of birth, civil status, profession, signature and other identity details that could identify you.

2-YOUR CONTACT DETAILS: Your address (residence place/business place), telephone number (home/ business place fixed and/or mobile telephone numbers that you may notify), electronic mail address, IP address, social media accounts and other similar contact data.

3-YOUR HEALTH DETAILS: Your blood type, allergies, chronic diseases, venereal diseases, infectious diseases, your data on the previous operations, your permanently used medical drugs, your data of Covid-19, your medical treatments, anesthesia details, harmful habits and other health data necessary for the treatments and operations to be applied to you.

4- YOUR PHOTOGRAPHS AND VIDEO IMAGES: Your photographs and/or videos taken before the medical transaction, during the medical transaction and/or after the medical transaction, your video image data obtained from the cameras recording for 7 days, 24 hours in the clinic and your voice recording data.

5-YOUR FINANCIAL DATA: Your bank account number, IBAN number, your credit card details, your invoicing and invoice information and other similar financial data.

PURPOSE OF PROCESSING YOUR PERSONAL DATA

Your Personal Data are processed by Dr. ÖZLEM BİÇER in conformity with the Law of Protection of Personal Data and the Bylaw of Protection of General Data for the purposes of creating patient file, executing your services of examination, medical diagnosis, treatment and care, performing your controls following the medical diagnosis and treatment processes, contacting you one-to-one, managing the appointment processes, realizing patient satisfaction and claim management, fulfilling the legal and contractual obligations, preserving the information on your health data to be stored in accordance with the relevant legislation, providing clinic safety, receiving consultation from another concerned specialist physician in order to be able to perform your treatment correctly, fulfilling the legal obligations within the scope of health tourism in conformity with the legislation, planning the transfer and accommodation services of patients/clients coming within the framework of health tourism, announcing the innovations with respect to medical treatment and practices, informing 3^rd parties with respect to the medical transaction applied, planning and managing health services and financing, fulfilling the legal responsibilities arising from the legal relationship established between the doctor and the patient, fulfilling the financial and administrative obligations, providing technical and commercial safety and fulfilling public obligations.

Your Personal Data shall be processed in the following situations and conditions by Dr. ÖZLEM BİÇER within the scope of the Law of Protection of Personal Data and the Bylaw of Protection of General Data:

Your Identity Data shall be processed for the purposes of planning the transfer and accommodation services of patients/clients coming within the framework of Health Tourism, executing the services of examination, medical diagnosis, treatment and care, creating patient file, realizing patient satisfaction and claim management.
Your Contact Data shall be processed for the purposes of performing your controls following the medical diagnosis and treatment processes, managing the appointment processes, promoting, informing and announcing the innovations with respect to medical treatment and practices.

Your Health Data shall be processed for the purposes of successfully realizing your medical treatments, receiving consultation from another specialist physician in your treatment process if deemed necessary, creating patient file, preserving the information on your health data to be stored in accordance with the relevant legislation for the required period, fulfilling the legal obligations within the scope of Health Law and Health Tourism Legislations in force.
Your Photograph, Video and Voice Recording Information shall be processed by Dr. ÖZLEM BİÇER for the purposes of observing and managing the treatment process, informing 3^rd parties with respect to the medical transaction applied, providing clinic safety.
Your Financial Data shall be processed for the purposes of realizing the control of your fee payments and return of fee in the case of any excess fee.

Your abovementioned personal data shall be processed again on the basis of the abovementioned purposes and the legislation in order to realize your medical treatment and fulfill the obligations with respect to your treatment. In the case that you fail to provide your personal data, the legal obligations imposed on Dr. ÖZLEM BİÇER who will serve in the capacity of doctor in your medical treatment shall not be able to be fulfilled as required and your treatment and/or your recovery processes shall not be able to be executed successfully.

METHOD OF COLLECTION OF PERSONAL DATA

Your Personal Data shall be collected;

by means of a communication form that you complete via Dr. ÖZLEM BİÇER’s institutional web site ozlembicer.com,
by means of your messages and/or comments to Dr. ÖZLEM BİÇER’s social media (instagram, youtube, facebook, twitter, linkedin etc.) accounts,
by means of your health reports, laboratory and visualization results, analyses and your statements on your health data that you provide by coming to Dr. ÖZLEM BİÇER’s clinic for examination and treatment purposes and which you submit for performance of the medical assessment with respect to the treatment to be applied to you,
by means of completing “Patient Information and Approval Form” with respect to the treatment to be applied by Dr. ÖZLEM BİÇER,
by means of the service providers of remote connection applications established for performance of your diagnoses and controls by Dr. ÖZLEM BİÇER (whatsapp/zoom.us/facetime/skype/messanger, google etc.),
by means of the electronic which you will send to Dr. ÖZLEM BİÇER’s institutional e-mail address (info@ozlembicer.com),

depending on the health service offered by Dr. ÖZLEM BİÇER and shall be processed to allow Dr. ÖZLEM BİÇER to fulfill her contractual and legal obligations fully and duly throughout the examination, medical diagnosis, treatment and care services in accordance with the Law of Protection of Personal Data and the Bylaw of Protection of General Data.

PURPOSE AND METHOD OF AND LEGAL REASON FOR PROCESSING YOUR PERSONAL DATA

Your Personal Data can further be processed separately taking you clear consent by the natural persons or legal entities authorized by Dr. ÖZLEM BİÇER in the capacity of “DATA PROCESSOR/PROCESSOR”; verbally, in writing, taking camera and photograph recording by electronically recording after taking the necessary technical and administrative measures, in situations stipulated in the relevant provisions of the Law of Protection of Personal Data and the Bylaw of Protection of General Data.

SITUATIONS REQUIRING RECEIVING YOUR CLEAR CONSENT STATEMENT:

In accordance with the Bylaw of Protection of General Data, article 6/1/a and the Law of Protection of Personal Data, article 5/1, your Personal Data can be processed only by receiving your clear consent in the following situations;

It shall only be possible by receiving your clear consent to send you sms message and/or e-mail and to establish mobile communication for the purpose of promotion, announcement and information on the medical services provided by Dr. ÖZLEM BİÇER.
It shall only be possible by receiving your clear consent to share your photographs and/or video records taken for the purpose of observing development of the treatment before the medical transaction, during the medical transaction and/or after the medical transaction in ÖZLEM BİÇER’s social media accounts (instagram, youtube, facebook, twitter, linkedin vs.) and institutional web sites.
In the case that you are contacted via the remote connection application service providers (whatsapp/ zoom.us/ facetime/ skype/messanger/google etc.) the server of which is in a foreign country for the purpose of allowing Dr. ÖZLEM BİÇER to perform your diagnoses and controls; diagnosis and control service through remote access could only be provided by receiving your clear consent since your data shall be deemed to be transferred to a foreign country and transfer to a foreign country requires clear consent, since the servers of the aforementioned service providers are in a foreign country and condition of clear consent is required for transfer to a foreign country.

SITUATIONS WHERE YOUR DATA COULD BE PROCESSED WITHOUT SEEKING CLEAR CONSENT STATEMENT:

In accordance with the Bylaw of Protection of General Data, article 9/2/h and the Law of Protection of Personal Data, article 6/3;

Your Health Data deemed to be Personal Data of Special Nature shall be processed by ÖZLEM BİÇER under the obligation of keeping secret in accordance with the law for the purpose of executing the services of examination, medical diagnosis, treatment and care without seeking for your clear consent.

In accordance with the Bylaw of Protection of General Data, article 6/1/b and Law of Protection of Personal Data, article 5/2/c;

Your Personal Data shall be processed by ÖZLEM BİÇER without seeking for your clear consent for the purpose of realizing your controls after the processes of medical diagnosis and treatment, to contact you directly, to manage the appointment processes.

In accordance with the Bylaw of Protection of General Data, article 6/1/f and Law of Protection of Personal Data, article 5/2/f, with reference to your legitimate interests;

Your Personal Data shall be processed by ÖZLEM BİÇER without seeking for your clear consent for the purpose of providing clinic safety, realizing patient satisfaction and claim management.

In accordance with the Bylaw of Protection of General Data, article 6/1/c, Law of Protection of Personal Data article 5/2/a and Law of Protection of Personal Data, article 5/2/ç, with reference to legal obligations, your Personal Data shall be processed without receiving your clear consent in the following conditions;

Creating the patient file.
Preserving the information on your health data to be stored in accordance with the relevant legislation.
Realizing control of your fee payments and issuing invoice.
Performing tax payments.
Performing obligations required by the Health Tourism Legislation.
Providing your data safety.
Performing legal obligations with Judiciary Authorities.
Performing administrative obligations with Administrative Institutions and Entities.

TRANSFER OF YOUR PERSONAL DATA, TO WHOM AND FOR WHICH PURPOSES THEY WILL BE TRANSFERRED

Your Personal Data collected for the purposes and subjected to the conditions contained in the scope of Personal Data Processing Conditions specified in Articles 5 and 6 of the Law of Protection of Personal Data numbered 6698 and Articles 6 and 9 of the Bylaw of Protection of General Data could be transferred to 3^rd party individuals and institutions in conformity with articles 8 and 9 of the Law of Protection of Personal Data and articles 45 and 49 of the Bylaw of Protection of General Data, for the purpose of executing Dr. ÖZLEM BİÇER’s examination, medical diagnosis, treatment and care services, developing the same, communicating with patients, planning and managing health services and financing, fulfilling the legal responsibilities arising from the legal relationship established between the doctor and the patient, fulfilling the financial, legal and administrative obligations, providing technical and commercial safety and fulfilling public obligations. Within this scope, your Personal Data processed by Dr. ÖZLEM BİÇER shall be transferred to;

Other specialist doctors for consultation purposes,
Her Insured Employees,
Her Suppliers,
Financial Consultant, Tax and Finance Consultants and Auditors
Legal Consultant
Database (Server) Providers
Translators
Foreign Promotion Consultant
Support Management System (DYS) Authorized Person
Data Protection Official
IT Consultant
Tourism Agencies

Public Institutions and Entities authorized under Laws and Judiciary Authorities.

PERSONAL DATA PROCESSING PERIOD

Your Personal Data shall be stored by Dr. ÖZLEM BİÇER to the degree and for the period that she is legally obligated to store them. Documentation and storage obligations arise from local norms related to trade, tax and health legislation. The following table contains the periods of storage of your Personal Data.

Your Personal Data	Periods of Storage
Your Identity Details	20 Years After Expiration of the Service Offered to the Service Purchaser
Your Contact Details	20 Years After Expiration of the Service Offered to the Service Purchaser
Your Health Details	20 Years After Expiration of the Service Offered to the Service Purchaser
Your Photograph and Video Information	20 Years After Expiration of the Service Offered to the Service Purchaser
Your Financial Information	5 Years After Expiration of the Service Offered to the Service Purchaser

DATA OWNER AGE LIMIT UNDER THE LEGISLATIONS

Patients/clients shall be able to give approval personally for processing personal data provided to be at least 18 years old within the scope of the Law of Protection of Personal Data. Approvals of the patients/clients under this age limit should be given by their legal guardians.

Within the scope of the Bylaw of Protection of General Data, citizens of the European Union and the patients/clients residing in the countries of the European Union may give their approvals for processing of their personal data personally provided to be minimum 16 years old or within the age limit conditioned in their countries. Approvals of the patients/clients under this age should be given by their legal guardians.

WITHDRAWAL OF CONSENT

We hereby inform you that in the case that you consent to Dr. ÖZLEM BİÇER for processing your Personal Data, you can withdraw your consent given for the abovementioned purposes at any time in accordance with the Bylaw of Protection of General Data, article 6/1/a and the Law of Protection of Personal Data, article 5/1. Your consent shall be withdrawn if you deliver your statement of withdrawal of consent to the following contact address, as indicated as follows.

RIGHTS OF DATA OWNERS IN ACCORDANCE WITH THE BYLAW OF PROTECTION OF GENERAL DATA

Your Personal Data are protected in accordance with the Bylaw of Protection of General Data as well, in the capacity of data owner. The Data Owners’ (citizens of the European Union or those residing in the countries of the European Union) rights are as follows if it is covered in the field of authorization of the Bylaw of Protection of General Data;

Access Right (Bylaw of Protection of General Data, article 15): The Data Owner is entitled to make application to Dr. ÖZLEM BİÇER and confirm whether the personal data related to him/her are processed and if the personal data is processed, he/she is entitled to learn the details contained in the Bylaw of Protection of General Data, article 15.
Correction Right (Bylaw of Protection of General Data, article 16): The Data Owner is entitled to make application any time and have his/her personal data in ÖZLEM BİÇER’s possession which have changed corrected.
Deletion Right (Bylaw of Protection of General Data, article 17): The Data Owner is entitled to request for deletion of his/her personal data in ÖZLEM BİÇER’s possession. In the case that the issues specified in the Bylaw of Protection of General Data, article 17 occur, your personal data shall be deleted without delay by Dr. ÖZLEM BİÇER.

Right to Restriction of Processing (Bylaw of Protection of General Data, article 18):
In the case that the Data Owners object to actuality of the Personal Data, they are entitled to request for restriction of use of the data in the capacity of Data Owner until its accuracy is confirmed by Dr. ÖZLEM BİÇER.
In the case that the Data Owner requests for deletion of his/her Personal Data because the activity of processing the Personal Data is unlawful, he/she is entitled to request for restriction of use of the data until his/her request is realized.
The Data Owner is entitled to request for restriction of use of the data in the case that Dr. ÖZLEM BİÇER no longer needs the personal data for processing purposes.
The Data Owners are entitled to request for restriction of use of the data until it is verified whether Dr. ÖZLEM BİÇER’s legitimate reasons for processing the data predominates the Data Owner’s legitimate reasons in the case that they object to the activity of processing in accordance with 21/1 article of the Bylaw of Protection of General Data.
Right to Transfer Data (Bylaw of Protection of General Data, article 20): The Data Owner is always entitled to make application and request for transfer of the Personal Data kept in ÖZLEM BİÇER’s possession to any other controller if possible technically. However this right could be exercised at times data processing is based on consent or in other cases required by the contract.

Right of Objection (Bylaw of Protection of General Data, article 21):

The Data Owner is entitled to object to processing the Personal Data on the basis of the justifications related to his/her special conditions including profiling within the scope of subparagraphs (e) or (f) of Article 6(1) of the Bylaw of Protection of General Data. Dr. ÖZLEM BİÇER cannot process the Personal Data if she cannot indicate a strong legitimate reason including one over the Data Owner’s interests, rights and freedoms or establishment, exercise or protection of a legal right.
The Data Owner is entitled to object to processing the Personal Data for marketing purposes in the case that the Personal Data is processed directly for marketing purposes, including profiling to the degree that it is directly related to marketing.
In the case that the Data Owner objects to processing the Personal Data directly for marketing purposes, Personal Data can no longer be processed for such purposes.

RIGHTS OF DATA OWNERS IN ACCORDANCE WITH THE LAW OF PROTECTION OF PERSONAL DATA

The rights which the natural persons the Personal Data of whom are processed have in accordance with article 11 of the Law of Protection of Personal Data are as follows;

To learn whether his/her personal data are processed,
If the personal data is processed, to request for information in this regard,
To learn the purpose of processing the personal data and whether they are used for the intended purpose,
To know the third parties within the homeland or abroad to whom personal data are transferred,
In the case that the personal data are processed deficiently or falsely, to request for correction of the same and to request for notification of the transaction performed within this scope to the third parties to whom personal data are transferred,
In the case that despite having been processed in conformity with the Law of Protection of Personal Data and other relevant law provisions, the reasons for processing the data are no longer valid, to request for deletion of the personal data and to request for notification of the transaction performed within this scope to the third parties to whom personal data are transferred,
To object to emergence of a result contrary to the person himself/herself by analyzing the data exclusively by means of the automatic systems,
To request for compensation of the loss in the case that the person incurs loss for unlawful processing of the personal data.

In the case that there are rights or claims that you want to exercise among the above listed rights of yours; you may come to the address of “Barbaros Mah. Menekşe Sok. Deluxia Suit K: 17 No: 209 Batı Ataşehir/Istanbul” contained in Dr. ÖZLEM BİÇER’s institutional web sites and personally submit by hand your written application where you indicate clearly and understandably which one of the rights specified in the articles of the Bylaw of Protection of General Data with respect to the rights of data owners and the rights specified in article 11 of the Law of Protection of Personal Data you request to exercise, with wet signature and together with documents evidencing your identity, send the same by means of a notary public or send the same to the e-mail address of “info@ozlembicer.com” signing with secure e-signature or send the same using other methods indicated in the Law of Protection of Personal Data as well. Your applications have to contain the name and surname, signature, T.R. Identity Number/Passport Number /temporary T.R. Identity Number, residence or business place address, e-mail address, telephone and fax number, elements subject of the request, in accordance with the “Communiqué on the Principles and Procedures for Application to the Data Controller”.

Dr. ÖZLEM BİÇER shall conclude the request as soon as possible and within no later than thirty (30) days depending on the nature of the request, free of charge. However, in the case that the transaction requires any further cost, the fee in the tariff determined by the Board of Personal Data Protection shall be collected.

Dr. ÖZLEM BİÇER notifies in the capacity of “DATA CONTROLLER” within the scope of the Law of Protection of Personal Data and in the capacity of “CONTROLLER” within the scope of the Bylaw of Protection of General Data.

Kind Regards.

I have understood and consent to the issues explained in the above clarification text and the issues of processing and sharing my personal data and personal data with special nature for the purposes specified on the basis of the provisions contained in the relevant legislation and transferring the same within the homeland and to any foreign country if necessary. (“I have read and understood” shall be written in the place where the section of Name and Surname is located.)

With respect to my General and Special Personal Data, I Consent – I Don’t Consent

For processing them :

For sharing them:

For transferring them within the homeland:

For transferring them to any foreign country if necessary:

Name and Surname : Name and Surname of the Legal Representative :

Date : Degree :

Signature : Date :

Signature :