PERSONAL DATA PROTECTION LAW

PRIVACY NOTICE

Dear Patients and Visitors,

This Privacy Notice has been prepared by Prof. Dr. Şadıman Kıykaç Altınbaş, in her capacity as data controller, who operates the private medical practice providing healthcare services at Kızılırmak Mah. Dumlupınar Bulv. No: 3, Next Level Ofis, A Blok, Kat: 14, No: 69, 06510 Çankaya/Ankara, Türkiye, pursuant to the “Data Controller’s Obligation to Inform” set out in Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”).

In accordance with the KVKK and other applicable legislation, your personal data, particularly your health data, may be processed and shared with third parties within the limits explained below. This notice explains which personal data are processed, the purposes for which they are processed, the methods and legal grounds of collection, to whom and for what purposes the processed data may be transferred, and your rights against the data controller, Prof. Dr. Şadıman Kıykaç Altınbaş. We kindly ask you to read it carefully.

1. Personal Data Processed

Pursuant to Article 3 of the KVKK, “personal data” of our patients, visitors or other third parties includes:

Identity data: Name, surname, mother’s/father’s name, Turkish identification number and/or passport number, place and/or date of birth, marital status, gender, occupation, employee registration and/or patient identification number and other identity data;

Contact data: Address, telephone number, e-mail address;

Transaction data: Voice recordings kept by patient services; personal data obtained when contacting the medical practice by e-mail, letter, WhatsApp and/or other means; data relating to private health insurance and payer institutions such as the Social Security Institution (SGK) for the financing and planning of healthcare services; health coverage details, insurance card number, bank account number, IBAN, credit card details, billing and invoice information; and feedback such as surveys, letters of thanks, complaints and satisfaction results;

Health data: All kinds of health data, including but not limited to medical reports, diagnosis data, laboratory results, all kinds of medical test results, examination data, physician analyses and comments, appointment details and prescription details, obtained during and/or as a result of the provision of medical diagnosis, treatment and care services;

Transaction security: Data submitted through Prof. Dr. Şadıman Kıykaç Altınbaş’s website (www.drsadimankiykac.com), website traffic information (website entry and exit information, your IP address and the pages you visit) and data obtained through cookies;

Physical premises security: Visitor entry and exit records, and camera recordings continuously made in common areas for security purposes;

including but not limited to the above, and above all health data, “personal data” means any information relating to an identified or identifiable natural person obtained, directly or indirectly and in any form (including but not limited to written, oral, visual, electronic, magnetic or digital form), by Prof. Dr. Şadıman Kıykaç Altınbaş or her employees and assistants.

Pursuant to Article 6 of the KVKK, “special categories of personal data” means data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

Pursuant to Article 3 of the KVKK, “processing of personal data” means any operation performed on personal data, whether wholly or partly by automated means or by non-automated means forming part of a data filing system, such as collection, recording, storage, retention, alteration, reorganisation, disclosure, transfer, takeover, making available, classification or prevention of use.

Pursuant to Article 3 of the KVKK, “data subject” means the natural person whose personal data are processed.

Your personal data, including special categories of personal data, may be processed by Prof. Dr. Şadıman Kıykaç Altınbaş in a manner that is connected, limited and proportionate to the purposes set out below, and may be transferred to the persons, institutions and organisations listed below.

2. Purposes of Processing

Your personal data may be processed by Prof. Dr. Şadıman Kıykaç Altınbaş for the following purposes:

Fulfilling our legal obligations under the Basic Law on Health Services No. 3359, the Personal Data Protection Law No. 6698, the Regulation on Personal Health Data and other applicable legislation;

Protection of public health, preventive medicine, conducting medical diagnosis, treatment, follow-up and care services, and planning and managing healthcare services and their financing;

Procuring medicines and/or medical supplies and/or devices specific to you;

Informing you about, providing information on and/or reminding you of your appointments;

Sharing information with, and responding to, the Ministry of Health and other public institutions and organisations as required by law;

Verifying your entitlements with institutions/organisations contracted with Prof. Dr. Şadıman Kıykaç Altınbaş, or carrying out financial reconciliation with such institutions regarding the healthcare services provided to you;

Sharing information requested by contracted institutions/organisations, primarily private insurance companies, and verifying identity within the scope of financing healthcare services;

Issuing invoices for the services we provide;

Analysing your use of healthcare services and retaining your health data in order to develop and improve the services we provide, and responding to your questions or complaints about our services;

Providing the necessary information upon the requests and inspections of regulatory and supervisory authorities and official bodies;

Retaining information relating to your health data that must be kept under applicable legislation;

Measuring and improving patient satisfaction after you receive healthcare services;

Measuring and monitoring service quality during telephone calls;

Ensuring the security of the physical premises;

Publishing our website (www.drsadimankiykac.com) and improving user experience;

Carrying out other activities expressly permitted by legislation.

Pursuant to Article 6(3) of the KVKK, special categories of personal data such as your health data may be processed without your explicit consent by persons under a duty of confidentiality for the purposes of protecting public health, preventive medicine, conducting medical diagnosis, treatment and care services, and planning and managing healthcare services and their financing. Explicit consent is also not required where processing is expressly provided for by law, is necessary for the establishment, exercise or protection of a right, or is necessary to protect the life or bodily integrity of a person who is unable to give consent due to actual impossibility. Where none of these conditions applies (for example, the use of patient images for promotional purposes), your explicit consent will be obtained separately.

Your personal data other than special categories of personal data may be processed for the purposes listed above on the basis of the legal grounds set out in Article 5(2) of the KVKK.

3. Method and Legal Grounds of Collection

Your personal data may be collected by any means, including in particular forms completed by you in electronic or written form and procedures carried out to provide medical diagnosis, treatment, follow-up and care services; orally (in person, by telephone), in writing (forms, test results, e-mail, fax, courier), visually or electronically; and by wholly or partly automated or non-automated means.

Your personal data are collected on the basis of the following legal grounds set out in Article 5(2) of the KVKK: processing is expressly provided for by law; it is directly related to the conclusion or performance of a contract; it is necessary for the data controller to fulfil its legal obligations; it is necessary for the establishment, exercise or protection of a right; and, provided that it does not harm your fundamental rights and freedoms, it is necessary for the legitimate interests of Prof. Dr. Şadıman Kıykaç Altınbaş. Your health data are collected on the basis of the legal grounds set out in Article 6(3) of the KVKK, in particular processing by a physician under a duty of confidentiality for the purpose of conducting medical diagnosis, treatment and care services. Where none of these legal grounds applies, your explicit consent is sought.

4. To Whom and for What Purposes Personal Data May Be Transferred

Provided that all necessary technical and organisational measures are taken to ensure an appropriate level of security in accordance with the KVKK and applicable health legislation, and for the same purposes for which they are processed as set out above, we may transfer your personal data to official authorities, primarily the Ministry of Health and the Provincial Directorate of Health; public and private hospitals, polyclinics, laboratories and physicians; private insurance companies; banks; our employees and consultants assisting us in fulfilling our contractual and legal obligations; natural or legal third parties specified by you in an oral or written request; and other natural or legal persons as permitted by legislation.

Your health data may be transferred to the natural or legal persons listed above pursuant to Articles 8 and 6 of the KVKK where one of the conditions listed in Article 6(3) exists (in particular for the purposes of protecting public health, preventive medicine, conducting medical diagnosis, treatment and care services, and planning and managing healthcare services and their financing).

Since the servers of services used on our website such as Google Analytics, Google Ads and Meta Pixel are located abroad, data collected through these services may be transferred abroad in accordance with the transfer mechanisms set out in Article 9 of the KVKK (appropriate safeguards such as standard contractual clauses, or your explicit consent). Your health data are not transferred abroad through these services. For further details, please see our Cookie Policy.

5. Rights of the Data Subject

As a data subject, you have the right to apply to Prof. Dr. Şadıman Kıykaç Altınbaş and request to:

learn whether your personal data are being processed;

request information if your personal data have been processed;

learn the purpose of processing your personal data and whether they are used in accordance with that purpose;

know the third parties, in Türkiye or abroad, to whom your personal data are transferred;

request the rectification of your personal data if they are incomplete or inaccurately processed, and request that the third parties to whom your personal data have been transferred be notified of the action taken;

request the erasure or destruction of your personal data under the conditions set out in the KVKK, and request that the third parties to whom your personal data have been transferred be notified of the action taken;

object to any result against you arising from the analysis of the processed data exclusively by automated systems;

claim compensation for damages if you suffer loss due to the unlawful processing of your personal data.

For any questions or requests regarding these rights or any other matter covered in this notice, you may contact Prof. Dr. Şadıman Kıykaç Altınbaş using the contact details below:

Address: Kızılırmak Mah. Dumlupınar Bulv. No: 3, Next Level Ofis, A Blok, Kat: 14, No: 69, 06510 Çankaya/Ankara, Türkiye

E-mail: [email protected]

Phone: +90 538 430 32 10

Website: www.drsadimankiykac.com

We wish you good health.

Kind regards,

Prof. Dr. Şadıman Kıykaç Altınbaş

This document is an English translation of the original Turkish text, provided for information purposes. In case of any discrepancy between the English and Turkish versions, the Turkish version shall prevail.