SONODENT DENTAL CLINIC
PATIENT CLARIFICATION TEXT AS REGARDS PROTECTING AND PROCESSING PERSONAL DATA
We, as SONODENT SAĞLIK HİZMETLERİ ANONİM ŞİRKETİ (“Sonodent” and/or “Clinic”) – the Data Controller, hereby would like to inform you to protect your personal data in line with the right of privacy, transparency and accountability under following Turkish legislation: 6698 numbered Personal Data Protection Law, the Communique on the Procedures and Principles to Fulfil the Obligation to Notify and the Regulation Regarding the Personal Health Data.
Depending on the law of personal data protection, some terms and their explanations used in this Clarification Text are as follows:
Personal Data: Any information relating to an identified or identifiable natural person
Special Categories of Personal Data: Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other belief, appearance, membership to associations, foundations or trade-unions, data concerning health, sexual life, criminal convictions and security measures, and the biometric and genetic data are deemed to be special categories of personal data
Processing Of Personal Data: any operation which is performed on personal data, wholly or partially by automated means or non-automated means which provided that form part of a data filing system, such as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, preventing the use thereof.
Data Controller: the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system,
Data subject/natural person concerned: the natural person, whose personal data are processed,
Data Processor: the natural or legal person who processes personal data on behalf of the data controller upon its authorization.
- The ID of the Data Controller
The Data Controller who is obliged to clarify and registered to the Istanbul Trade Registry with 719243-0 registry number and 774058391100001 Mersis number and has a registered office at “Caddebostan Mahallesi, Bağdat Cad., Birgen İş Merk. No:226/16 Kadıköy/İstanbul”, is SONODENT SAĞLIK HİZMETLERİ ANONİM ŞİRKETİ carries on business under “Sonodent” trademark and business organization.
- The Personal Data to be Processed
- ID info: including but not limited to your name, surname, parental name, ID serial number, T.R. identification number, passport number etc. any identifier data along with the data such as your gender, birth date and marital status; your nicknames in case you get in touch with us via your social media accounts,
- Communication info: your address, phone numbers, e-mail addresses, social media account info,
- Audio and video recordings: audio records while voice calling with our call center, security footages of the VCR, medical imaging records,
- Financial and Insurance Info: Bank account number, IBAN number, credit card info, financial info needed for drawing up an invoice, SSI or private insurance data,
- Health data: any kind of record regarding the medical operation while medical diagnosis and treatment in our clinic, including but not limited to your laboratory results, test results, check-up data, appointment data, prescription info, medical imaging info, health data belong to previous terms, health data acquired while diagnosis and/or treatment,
- Electronic data processing security data and cookie data you shared with us through our web site, Instagram account, facebook account,
In addition to the above mentioned, it is possible to acquire other personal data and process them for the limited below purposes and to medical diagnosis and treatment procedure, to make necessary planning, to get contact with you, to inform you for the subjects you are interested, to keep you posted about the campaigns and innovations and to fulfil our obligations arise from contract and/or legislation.
- The Method of Acquiring Data
Part of your personal data is acquired by you while others are by in written or electronically via close circuit CCTV recordings, visitor records taken in entrances and exits. The personal data that are processing and the method of acquiring them are as follows but not limited to:
The Personal Data Being Collected Automatically: CCTV and audio recordings, cookies and other data processing security tools that are collecting automatically.
The Personal Data Provided by the Data Subject: Personal data that you shared with us physically or through phone call, social media accounts, WhatsApp, web site, corporate e-mail and other communication channels.
The Personal Data Collected by Other Sources: The personal data that are transferred by third parties (under your permission taken before by third parties) such as business partners, medical imaging centres, laboratories.
- The Reason and Legal Ground of Processing Personal Data
Your personal data including your sensitive personal data as regards your health info, are being processed under the aim of providing treatment and care services; administering treatment in line with your medical needs; monitoring your situation by the Clinic personnel after treatments to be applied; conducting invoice, accounting and insurance transactions; increasing the quality of the services provided by the Clinic and maintaining its supervision; carrying out the PR activities of the Clinic and its services; maintaining the Clinic’s obligations arising from legislation and contracts; and sustaining physical security.
Moreover, your personal data are not being processed without your explicit consent and without the clarification needed excluding the exceptions determined in the legislation.
Your sensitive personal data are being processed without your explicit consent if and only under legal obligations and limited with the goals of protecting public health, maintaining treatment and care services, planning health services and its financing by the ones under confidentiality obligation or authorized institutions and institutions.
Your personal data are processed measurably and with the limitation of the Art. 5 of the PDPL of which states Personal data may be processed without seeking the explicit consent of the data subject only in cases where one of the following legal conditions is met: “obligatory for the legitimate interest of the data controller provided not to damage the fundamental rights and freedoms of the data subject”, “mandatory for the controller to be able to perform his legal obligations”, “data processing is mandatory for the establishment, exercise or protection of any right” and “processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract” and for planning and management of health-care services as well as their financing under Art. 6 of the Law, to contact with you , to inform you for the subjects that may concern you and inform you about the campaigns and innovations to be made.
The Retention Period of the Personal Data:
Your personal data shall be retained as long as the relation between you and the Clinic while it lasted and upon the periods mentioned in the legislation. In case there is no regulation in the legislation regarding the periods, the personal data shall be processed for the period of actualizing the activity goal while processing data, and then deleted, annihilated, or anonymized.
Your sensitive personal data shall be processed with the limitation of the processing goal of medical diagnosis and treatment and then retained as the legislation necessitate and until the retention aim is over.
The CCTV records are retained for the period of maximum 6 months and then deleted. The detailed info and explanations regarding retention and annihilation of the personal data within the Clinic, are took place in the Retention and Annihilation Policy.
Sufficient and reasonable all measures are taken for both physically and digitally retained data and liability regarding the protection of the all processed data belongs to us.
Within this scope, necessary infrastructure work in line with the opinions and communiques of the Personal Data Protection Board is made regarding both physical and electronical media where your sensitive personal data are processed and retained. All our personnel are attended regular trainings and necessary audits and controls are made in order to maintain data security.
Transfer of the Data to Third Parties and/or Abroad:
Your personal data to be collected/acquired by the Clinic, are shared with the doctors and other health personnel engaged with the Clinic to consult about your health situation under Art. 8 and 9 of the Law and the abovementioned goals and in line with the fundamental principles foreseen in the Law.
Some of your personal data are shared with institutions such as tax department for fulfilling our obligations e.g. making out invoices, submitting tax declarations etc. Your personal data under identity, contact and process security categories are shared with the firm we receive social media consultancy.
Except for the above listed obligations, some of your personal data shall be shared with counselling firms, business partners, lawyers and CPAs for the reasons of calculating incentives and costs and in any event limited with the goals determined in the Art. 4 of this Clarification Text.
Your sensitive personal data shall be shared with the doctors employed in our clinic or not and laboratories and medical imaging centres limited with the reasons of consideration and consultation and in an absolute necessity condition for medical diagnosis and treatment; and with private health insurance firms and social security insurance for financing health services etc.
Your personal data including sensitive ones, shall be shared when required with administrative bodies such as security units and T.R. Health Ministry being in the first place under statutory obligations and in line with the legislation.
Your personal data is not transferred abroad.
Your Rights Under PDPL:
According to the Art. 11 of the PDPL with the title of “rights of the data subject”, we would like to remind you that you have a right to apply our Clinic and learn whether your personal data are processed or not; request information if your personal data are processed; learn the purpose of data processing and whether this data is used for intended purposes; know the third parties to whom personal data is transferred at home or abroad; request the rectification of the incomplete or inaccurate data (if any); request the erasure or destruction of personal data under conditions laid down in Art.7; request notification of the operations carried out to third parties to whom his personal data has been transferred; object to the processing, exclusively by automatic means, of his personal data, which leads to an unfavourable consequence for the data subject; request compensation for the damage arising from the unlawful processing of his personal data.
You may transmit any kind of your request to our below mentioned e-mail via return receipt post or your direct written application or via secured e signed or KEP, with the documents that authenticate your identity. In case of any suspect, it is possible to contact you through phone or other sources to affirm that you are the right holder as the applicant.
We care to develop ourselves with your comments and suggestions. You may immediately contact us about any info or transaction took place in this text, we are ready to find solutions to the full extent permitted by the law.
SONODENT SAĞLIK HİZMETLERİ ANONİM ŞİRKETİ
Address: Caddebostan Mah. Bağdat Cad. Birgen İş Merk. No:226/16 Kadıköy/İstanbul