Personal Data Protection

  • General Disclosure Text On The Protection of Personal Data
  • Patient Disclosure Text On The Protection Of Personal Data
  • Personal Data Request Form

Identity of Data Controller 

 

Badge Sağlık Danışmanlık Ticaret A.Ş. (hereinafter referred to as Badge Clinic) prepared this Disclosure Text in order to inform you about what personal data we process and for what purposes.

As data controller, we hereby openly inform you that your personal data, obtained in the following manner within the limits of the legislation, will be protected, recorded, stored and kept, reorganized, in line with the purpose that require the processing of such data and in a connected, limited and measured manner according to such purpose within the framework of our commercial activities or within the framework of the service relationship with you, and transferred to institutions authorized by law to request your personal data, and transferred, transmitted to domestic or foreign third parties under the conditions stipulated in the Law, or may be classified and processed in other ways cited in the Law.

 

Collection and Processing of Personal Data, and the Reason for Processing

 

Badge Clinic processes and stores your personal data in accordance with the legal provisions of the Personal Data Protection Law and ancillary legislation pertaining thereto. Your personal data is collected for the purpose of providing medical services as required by law and in this context to enable Badge Clinic to fully and properly comply with its contractual obligations and other legal obligations. Although personal data is shaped depending on the medical services provided, it is collected orally, in writing or electronically, by automatic or non-automatic methods, through the website, social media channels, online services, WhatsApp and similar means. As long as your relationship with Badge Clinic continues, your personal data may be created and updated, processed and retained in both digital and physical environments.

 

The following will be processed by Badge Clinic:

 

Your name, surname, TR identity number, passport number or temporary TR identity number, place and date of birth, marital status, patient records created by our clinic, and other identifying information that allows us to identify you, your address, phone number, email address and other contact information, your financial information such as payment details, credit card, bank and billing information, audio and/or digital information we receive from time to time through electronic or non-electronic methods, your video camera footage obtained and/or to be obtained during your visit to Badge Clinic, your general and sensitive personal data, particularly personal health data obtained during the execution of all medical diagnosis, examination, treatment and care services, all data that may be required, including but not limited to, your health and identity data, financial data such as payment details and billing information that you submit through our website.

 

Your personal data will be processed in accordance with the conditions and purposes of the processing of personal data set forth in Articles 5 and 6 of KVKK. Your sensitive personal data and general personal data, in particular your health data, may be processed by our Clinic for the following purposes:

 

Your personal data including sensitive personal data may be processed for the following purposes, including but not limited to:

 

– Fulfilling our legal obligations under Health Services Fundamental Law No. 3359, the Decree on the Organization and Duties of the Ministry of Health and its Affiliated Organizations, the Regulation on the Processing and Protection of Personal Health Data and other relevant regulations;

 

– Protection of public health, preventive medicine, medical diagnostics, treatment and care services;

– Financial settlement with in-network institutions with respect to the medical services offered to you;

– Informing you about your appointment when you make an appointment;

– Sending campaign offers and notifications by message, email or other ways;

– Monitoring and preventing misuse and/or unauthorized transactions;

– Answering any questions or complaints you may have about our medical services;

– Taking all necessary technical and administrative measures within the scope of data security of our clinic systems and applications;

– Analyzing your use of medical services to develop and improve the medical services we provide to you and retaining your health data that is required to be retained under the relevant legislation;

– Measuring patient satisfaction.

 

Persons and Organizations To Whom Your Personal Data Can Be Transferred

 

Your personal data shall be disclosed to the following parties, in accordance with the Law and similar legislation and for the purposes stated above:

– Ministry of Health and its subunits;

– General Directorate of Security and similar law enforcement agencies;

– Chief Public Prosecutors, Courts, arbitrator or arbitrators in arbitration proceedings;

– Judicial organs and/or administrative authorities (in the sense of fulfilling the requested information and document requests)

– The healthcare facility to which the patient was referred or to which the patient was admitted of their own accord;

– Third parties we get consultancy services from, including attorneys, tax advisors and auditors;

– Regulatory and supervisory institutions, official authorities

– Responsible and authorized public institutions and organizations and professional organizations that are regarded as public institutions (in the sense of performing the auditing and/or regulatory tasks to be performed)

– Our suppliers, support service providers and business partners and other third parties from whose services we benefit or with whom we cooperate, under the conditions and for the purposes of the processing of personal data set forth in Articles 8 and 9 of KVKK.

 

Method(s) of and Legal Reason(s) for Collecting Personal Data

 

Your personal data will be collected in all types of oral, written or electronic media within the framework of the principles established in KVKK for the above purposes and for the purpose of providing medical services within the established legal framework and, to fully and properly fulfill the contractual and legal obligations of Badge Clinic.

 

Data Processing Time

 

Your personal data will be processed in accordance with the data processing and limitation periods cited in the legislation and all relevant laws to which Badge Clinic is subject and other legal regulations, limited to the purposes specified in this Disclosure Text. In the event of changes to the legal deadlines for data processing, the newly established deadlines will be used as a basis.

 

Your rights

 

Within the scope of KVKK, you have the following rights regarding your personal data:

 

    • To find out whether your personal data has been processed;

    • To request information if your personal data has been processed;

    • To find out why your personal data has been processed and whether it has been used for the intended purpose;

    • To find out the third parties to whom personal data is transferred at home or abroad;

    • To request correction in the event personal data is processed incompletely or incorrectly;

    • To request the deletion or destruction of personal data in the event that the reasons for the processing of such data no longer exist;

    • To request that your information corrected or deleted upon your request be disclosed to third parties to whom personal data has been transferred, if any;

    • To object to the outcome of a result against you made through the analyzing of processed data exclusively via automatic systems;

    • To request compensation in the event you face damages due to the illegal processing of your personal data.

 

In order to exercise these rights, you can send your written request with the necessary information to verify your identity and describing the right you wish to exercise, appended with an original signature, and clearly stating that the subject is related to KVKK, to “Badge Sağlık Danışmanlık Ticaret A.Ş. – Muratreis Mah. Nuhkuyusu Cad. No:299 A D:1 Üsküdar/Istanbul” or by filling out the “Personal Data Request Form” published on our website, and email it to kvkk@badgeclinic.com.For requests, the following must be included: name, surname and, signature, in case of a written request, TR identity number for citizens of the Republic of Turkey, nationality, passport number/identity number for foreigners, residential or work address to receive notifications, email address to receive notifications, if available, telephone or fax number and subject matter of the request.

 

In your application containing your explanations regarding the right that you have as the personal data owner, which you make to use the abovementioned rights, and which should clearly state the right you wish to exercise, your request must be clear and understandable, the subject you are requesting must relate to you or if you are acting on behalf of another person, you must be expressly authorized to do so and your authorization must be documented, the request must include identity and address information, and documents proving your identity must be attached to the request.

 

Any applications you will make in this context will be finalized as soon as possible and within 30 days at the latest. However, in the case the procedure requires an additional cost, a fee determined by the Board of Personal Data Protection may be payable. If the response to the request is provided on a recording medium such as a CD or flash drive, the fee that may be charged by Badge Clinic shall not exceed the cost of the recording medium.

 

Contact Details

 

Badge Sağlık Danışmanlık Ticaret A.Ş.

Muratreis Mah. Nuhkuyusu Cad. No:299 A D:1 Üsküdar/Istanbul

kvkk@badgeclinic.com

 

Identity of Data Controller

 

Badge Sağlık Danışmanlık Ticaret A.Ş. (hereinafter referred to as Badge Clinic) prepared this Disclosure Text in order to inform you about what personal data we process and for what purposes.

 

As data controller, we hereby openly inform you that your personal data, obtained in the following manner within the limits of the legislation, will be protected, recorded, stored and kept, reorganized, in line with the purpose that require the processing of such data and in a connected, limited and measured manner according to such purpose within the framework of our commercial activities or within the framework of the service relationship with you, and transferred to institutions authorized by law to request your personal data, and transferred, transmitted to domestic or foreign third parties under the conditions stipulated in the Law, or may be classified and processed in other ways cited in the Law.

 

Your personal data processed

 

Personal data about patients provided to us by them or automatically obtained may be processed by us. The following are examples of personal data we may process:

 

Personal Data Category Personal Data Where the Personal Data is Obtained from
Identity Data Name Surname, TR Identity Number, Date of Birth, Place of Birth, Passport Number, Name and Surname of Friend/Family Member Provided by you (data owner)
Contact Data Phone Number, Address, Email Provided by you (data owner)
Visual and Audio Data Patient Photos Given by you (data owner) and by our Photographer.
Appearance Height, Weight Provided by you (data owner)
Physical Space Security Data Camera Footage Recorded Automatically by the Camera Recording System.
Transaction Security Guest Network Logs Recorded Automatically by the Firewall.
Sensitive Personal Data Diagnosis , Medications Taken , Chronic Disease , Allergy , Infectious Disease , Continuously Used Medicines , Susceptibility to Bleeding , Skin Disease , Pregnancy Risk , Infection Given by you (data owner) and by your Doctor.

 

Method(s) of and Legal Reason(s) for Collecting Data

 

Your personal data is collected by Badge Clinic through the camera recording system, firewall, patient registration system, patient forms and similar channels in order to carry out our activities, and improve the services we offer and to carry out our commercial activities, based on the legal grounds mentioned below. In this context, your personal data may be processed and transferred in light of the principles provided for in Article 4.2 of KVKK and after obtaining explicit consent or without obtaining explicit consent in the event of the existence of circumstances referred to in Articles 5.2 and 6.3.

    • Personal Data Protection Law No. 6698;

    • Health Services Fundamental Law No. 3359;

    • Decree No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Organizations;

    • Patient Rights Regulation;

    • Regulation on the Processing of Personal Health Data and Protection of Privacy;

    • Ministry of Health regulations and other legislative provisions.

 

Purposes of Processing Personal Data

 

    • To fulfill our legal obligations under Health Services Fundamental Law No. 3359, the Decree No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Organizations, Patient Rights Regulation, Private Hospitals Regulation, the Regulation on Personal Health Data and other relevant regulations;

    • Protection of public health, medicine, medical diagnostics, treatment and care services;

    • Execution of medical services, medical diagnosis, examination, treatment and care services;

    • Procurement of drugs, consumables and specialty materials;

    • To inform you about your appointment when you make an appointment;

    • ID verification;

    • Billing;

    • Fast and accurate planning, management, monitoring of your transactions;

    • To measure patient satisfaction after provision of medical services, and increase patient satisfaction;

    • To be able to answer all your questions and complaints;

    • To contact you to give information regarding our services;

    • To research and analyze your use of medical services in order to improve the services we offer;

    • To share your photos on our social media and websites, run special promotional and informational activities, and make sure you benefit from these;

    • To ensure Badge Clinic’s Physical Space Security;

    • Execution of Information Security Processes;

    • To inform Your Relatives About Your Health Status

 

Circumstances in which Explicit Consent is not Sought for Personal Data Processing

 

In at least one of the situations listed below, it is possible to process your personal data without your Explicit Consent.

    • It is clearly stipulated in the law;

    • It is necessary to protect the life or bodily integrity of the person themselves, who is not in a state to express their consent due to physical impossibility or whose consent has no legal validity;

    • It is necessary to process personal data of parties to a contract, provided that the processing is directly related to the establishment or execution of that contract;

    • It is compulsory for Badge Clinic to fulfill its legal obligation;

    • It is publicized by the related party themselves;

    • Data processing is necessary in order to establish, use or protect a right;

    • Data processing is necessary for Badge Clinic’s legitimate interests, provided that it is not to the detriment of the related party’s fundamental rights and freedoms.

 

Transfer of Your Personal Data to Domestic or International Parties

 

Your personal data with respect to our service areas may be shared with the following to make sure necessary work is done by business units in order to make sure data subjects benefit from services offered by Badge Clinic, execution of related business processes, planning and execution of Badge Clinic’s commercial or scientific strategies, ensuring the legal, technical and commercial security of people who are in contact with Badge Clinic: Ministry of Health and its subunits, General Directorate of Security and other law enforcement agencies, Pharmacists Association of Turkey, courts and all types of judicial authorities, central and other third parties, third parties we get consultancy services from including your authorized representatives, attorneys, tax and financial advisors and auditors, our business partners and other third parties with whom we cooperate to develop or carry out medical services for the abovementioned purposes, including regulatory and supervisory institutions, official authorities, third parties at home/overseas within the framework of the personal data transfer conditions and purposes specified in Articles 8 and 9 of the Law.

 

Your rights

 

Within the scope of KVKK, you have the following rights regarding your personal data:

 

    • To find out whether your personal data has been processed;

    • To request information if your personal data has been processed;

    • To find out why your personal data has been processed and whether it has been used for the intended purpose;

    • To find out the third parties to whom personal data is transferred at home or abroad;

    • To request correction in the event personal data is processed incompletely or incorrectly;

    • To request the deletion or destruction of personal data in the event that the reasons for the processing of such data no longer exist;

    • To request that your information corrected or deleted upon your request be disclosed to third parties to whom personal data has been transferred, if any;

    • To object to the outcome of a result against you made through the analyzing of processed data exclusively via automatic systems;

    • To request compensation in the event you face damages due to the illegal processing of your personal data.

 

In order to exercise your above rights, you can send your written request with the necessary information to verify your identity and describing the right you wish to exercise, appended with an original signature, and clearly stating that the subject is related to KVKK, to “Badge Sağlık Danışmanlık Ticaret A.Ş. – Muratreis Mah. Nuhkuyusu Cad. No:299 A D:1 Üsküdar/Istanbul” or by filling out the “Personal Data Request Form” published on our website, and email it to kvkk@badgeclinic.com. For requests, the following must be included: name, surname and, signature, in case of a written request, TR identity number for citizens of the Republic of Turkey, nationality, passport number/identity number for foreigners, residential or work address to receive notifications, email address to receive notifications, if available, telephone or fax number and subject matter of the request.

 

In your application containing your explanations regarding the right that you have as the personal data owner, which you make to use the abovementioned rights, and which should clearly state the right you wish to exercise, your request must be clear and understandable, the subject you are requesting must relate to you or if you are acting on behalf of another person, you must be expressly authorized to do so and your authorization must be documented, the request must include identity and address information, and documents proving your identity must be attached to the request.

 

Any applications you will make in this context will be finalized as soon as possible and within 30 days at the latest. However, in the case the procedure requires an additional cost, a fee determined by the Board of Personal Data Protection may be payable. If the response to the request is provided on a recording medium such as a CD or flash drive, the fee that may be charged by Badge Clinic shall not exceed the cost of the recording medium.

 

Contact Details

 

Badge Sağlık Danışmanlık Ticaret A.Ş.

Muratreis Mah. Nuhkuyusu Cad. No:299 A D:1 Üsküdar/Istanbul

kvkk@badgeclinic.com

Badge Sağlık Danışmanlık Ticaret Ltd. Şti. attaches great importance to the privacy and security of your personal data and sensitive personal data.

 

Owners of personal data (hereinafter referred to as “Applicants”), who are defined as data subjects in the Personal Data Protection Law No. 6698 (“KVKK”), are entitled to make certain requests regarding the processing of their personal data pursuant to Article 11 of KVKK.

 

Pursuant to paragraph one, Article 13 of KVKK, the requests regarding these rights must be submitted to our Company acting as data controller in writing and according to the following methods established by the Board of Personal Data Protection (“Board”).

 

For “written” applications to our Company, a printout of this form may be taken and submitted to us through the following means:

 

    • Personal application by the Applicant;

    • Through a notary public;

    • Sending it to the Company’s registered email address with the Applicant appending their “secure electronic signature” as mentioned in the Electronic Signature Law No. 5070.

 

Below is information on how written applications are submitted to us, with reference to written application channels.

 

Application Method Address for Application Information to be Included When Sending Applications
·       Application in person (Applicant comes in person    to apply with documentation proving their identity) ·       Muratreis Mah. Nuhkuyusu Cad. No:299 A D:1 Üsküdar/Istanbul ·       “Information Request under the Personal Data Protection Law” must be written on the envelope.
·       Notification via a notary public ·       Muratreis Mah. Nuhkuyusu Cad. No:299 A D:1 Üsküdar/Istanbul ·       “Information Request under the Personal Data Protection Law” must be written on the notification envelope.
·       Via Registered Electronic Mail (KEP) by signing with a “secure electronic signature” ·       badgesaglik@hs01.kep.tr ·       kvkk@badgeclinic.com ·       “Information Request under the Personal Data Protection Law” must be written on the subject section of the email.

 

Your requests will be responded to within 30 days of our receipt of your request, depending on the nature of the request, in accordance with Article 13(2) of KVKK. Our responses will be communicated to you in writing or electronically in accordance with the provisions of Article 13 of KVKK.

 

 Applicant contact details:

 

Name & Surname
TR Identity Number (nationality, passport number or identity number for foreigners):
Phone Number:
Email: (We will be able to respond to you faster if you specify an address.)
Address:

 

*The above information is obtained in accordance with the Communiqué on the Procedures and Principles of Applying to the Data Controller.

 

Please indicate your relationship with our Company. (such as customer, business partner, employee candidate, third-party company employee, shareholder)

 

·       Patient ·       Employee ·       Employee Candidate ·       Other
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Please specify your request under KVKK in detail:

 

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Please choose how we should respond to your request:

    • I want the response sent to my address.

    • I want the response sent to my email address.

    • (We will be able to respond to you faster if you choose email.)

    • I would like to receive the response personally.

 

Our Company reserves the right to request additional documents and information (copy of ID card, driver’s license, other documents replacing official identity, etc.) for identification and authorization purposes, in order to eliminate legal risks that may arise from illegal and unfair disclosure of data and, in particular, to ensure the security of your personal data. In the event that the information regarding your requests submitted through the form is not accurate and up-to-date, or an unauthorized request is made, our Company will not be liable for such incorrect information or requests originating from unauthorized applications. Requests may be charged in accordance with Article 6(5) and Article 7 of the Communiqué on the Procedures and Principles for Applying to the Data Controller.

 

Applicant’s (Personal Data Owner) Name and Surname              : 

 

Application Date             :

 

Signature            :

 

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