INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA AT PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN’S CLINIC

This Information Notice has been prepared to inform data subjects regarding the principles and procedures of processing personal data belonging to patients/clients who apply to Prof. Dr. Çiğdem Ünal Gülmeden’s Clinic ("Prof. Dr. Çiğdem Ünal Gülmeden"), in accordance with Law No. 6698 on the Protection of Personal Data ("KVKK") in Turkish legal legislation, the General Data Protection Regulation ("GDPR") of the European Union, the Regulation on Personal Health Data, and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform.

ENSURING THE SECURITY OF PERSONAL DATA

Ensuring the security of patients’/clients’ personal data is a top priority for Prof. Dr. Çiğdem Ünal Gülmeden. In this regard, all necessary security measures are taken in full compliance with applicable legislation to ensure that personal data is processed securely and to prevent any unauthorized access or data breaches.

DATA CONTROLLER

Your personal data will be processed by Prof. Dr. Çiğdem Ünal Gülmeden, operating at the address: Teşvikiye Mah. Poyracık Sok. Pınar Apt. No:63 İç Kapı No:6 Şişli/Istanbul/Turkey, within the scope of KVKK and GDPR.

Prof. Dr. Çiğdem Ünal Gülmeden is registered with Mecidiyeköy Tax Office, Tax Number: 9070058674, and is considered a “Data Controller” under KVKK and a “Controller” under GDPR.

Within the scope of GDPR, **Prof. Dr. Çiğdem Ünal Gülmeden

YOUR PERSONAL DATA TO BE PROCESSED

Your Personal Data and Special Categories of Personal Data listed below will be processed by Prof. Dr. Çiğdem Ünal Gülmeden in compliance with the fundamental principles set forth under Article 4 of KVKK and Article 5 of GDPR. Your data will be processed lawfully, in connection with and limited to the specified processing purposes, ensuring fairness and transparency. All necessary technical and administrative measures prescribed by law will be taken to ensure data security. Processing will be conducted in accordance with the conditions and purposes set out in Articles 5 and 6 of KVKK and Articles 6 and 9 of GDPR, and within the scope of this Information Notice.

1- IDENTITY INFORMATION:

Your name, surname, Turkish Citizenship Number (T.C. ID Number), Passport Number and/or Temporary Turkish Citizenship Number, place and date of birth, marital status, gender, profession, signature, and other identity data that may identify you.

2- CONTACT INFORMATION:

Your residential/business address, phone number (including landline and/or mobile numbers you provide), email address, IP address, social media accounts, and other communication details.

3- HEALTH INFORMATION:

Your blood type, allergies, chronic illnesses, sexually transmitted diseases, infectious diseases, details of previous surgeries/operations, medications used on a continuous basis, information regarding COVID-19, medical treatments, medical history, family medical history, health reports, test and imaging results, anesthesia records, prescription details, history of harmful health-related habits, body analysis and measurement data, skin analysis data, and other health-related data required for treatments and operations planned for you, including examination findings and data related to the treatments and/or operations you receive.

4- YOUR PHOTO/VIDEO IMAGES AND AUDIO DATA:

Your images and audio recordings captured before, during, and/or after medical procedures, as well as video recordings from closed-circuit security cameras installed for workplace security purposes.

5- YOUR FINANCIAL INFORMATION:

Your bank account number, IBAN number, credit card details, billing and invoice information, and other financial data.

6- YOUR TRANSFER AND ACCOMMODATION INFORMATION:

If you are a Health Tourist visiting under International Health Tourism, your transfer details, flight ticket (arrival and return) information, and hotel accommodation details.

PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your Personal Data and Special Category Personal Data are processed by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN in compliance with KVKK and GDPR for the purposes of creating a patient file, conducting medical examinations, preventive healthcare, medical diagnosis, treatment, medical applications, surgical procedures, and post-operative care services, carrying out follow-ups after medical diagnosis, treatment, procedures, and operations, managing possible complication processes, ensuring direct communication with you, managing appointment scheduling processes, handling patient satisfaction and request management, fulfilling legal and contractual obligations, safeguarding and storing your medical data as required by relevant legislation within the legally determined retention periods, obtaining expert consultation from another specialist doctor if necessary to ensure the correct execution of your treatment or procedure, fulfilling legal obligations in accordance with International Health Tourism regulations, ensuring workplace security, planning transfer, accommodation, and translation services for Health Tourists visiting under International Health Tourism, informing you about medical innovations, new treatments, and applications, providing information to third parties regarding the medical procedure performed, carrying out promotional and marketing activities related to medical services under the International Health Tourism Incentive Legislation, managing and planning healthcare services and financial administration, fulfilling responsibilities arising from the legal relationship between doctor and patient, ensuring compliance with financial and administrative obligations, maintaining technical security, and fulfilling public obligations in accordance with applicable regulations.

Your Personal Data and Special Category Personal Data will be processed by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN within the scope of KVKK and GDPR under the following conditions and circumstances:

• Identity Data will be processed for the purposes of conducting medical examinations, medical diagnosis, treatment/surgical procedures, and post-operative care services, creating a patient file, managing patient satisfaction and request processes, and planning transfer, accommodation, and translation services for Health Tourists visiting under International Health Tourism.
• Contact Information will be processed to manage your follow-up examinations after medical diagnosis, treatment, and surgical procedures, and to organise appointment scheduling. Additionally, subject to your explicit consent, it may also be processed to inform, introduce, and announce innovations in medical treatments and procedures.
• Health Data will be processed to successfully conduct your medical treatments and operations, to obtain consultation from another specialist doctor if necessary during your treatment and operation process, to manage possible complications, to create a patient file, to store and retain health data as required by applicable legislation within the legally determined retention periods, and to fulfil legal obligations under Healthcare Law and International Health Tourism Regulations.
• Photographs, Video, and Audio Recordings will be processed by DR. ÇİĞDEM ÜNAL GÜLMEDEN to observe and manage your treatment and/or surgical procedure and to ensure workplace security. Additionally, subject to your explicit consent, such data may also be used to provide medical information to third parties regarding your procedure/surgical intervention and to manage marketing and promotional activities for foreign patients under the International Health Tourism Incentive Legislation.
• Financial Data will be processed to monitor your payments, issue invoices, and refund any overpayments if applicable.
• Transfer and Accommodation Data will be processed for the purpose of planning transfer and accommodation services for Health Tourists within the scope of International Health Tourism.

Your Personal Data and Special Category Personal Data specified above will be processed in accordance with the aforementioned purposes and legislation so that your medical treatment/operation can be carried out and the obligations related to the provided medical service can be fulfilled. In the event that you do not provide such relevant personal data, the legal obligations imposed upon PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN, who will serve as the physician in your medical treatment and/or operation, cannot be properly fulfilled, and your operation, treatment, and recovery processes cannot be successfully carried out.

METHOD OF COLLECTING PERSONAL DATA

Depending on the healthcare service provided by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN, your Personal Data may be collected:

• By visiting the clinic of PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN for examination, diagnosis, treatment, medical application, or operation, and submitting the health reports, laboratory and imaging results, test results, your ID/passport, as well as the health data, identity, and contact information you provide in order to enable a medical evaluation related to the treatment to be applied to you,

• By filling out the “Patient Information and Consent Form” regarding the treatment and/or operation to be carried out by DR. ÇİĞDEM ÜNAL GÜLMEDEN,

• By filling out the contact form on the corporate website of DR. ÇİĞDEM ÜNAL GÜLMEDEN at www.drcigdemunal.com,

• By sending emails to the corporate email addresses (This email address is being protected from spambots. You need JavaScript enabled to view it.) of DR. ÇİĞDEM ÜNAL GÜLMEDEN,

• By means of photographs/video recordings taken before, after, and/or during the medical procedure applied by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN,

• Upon your request and in necessary circumstances, for the purpose of performing online diagnosis and check-ups via remote access by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN, through written/audio/visual (photograph and/or video recordings) messages you send to PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN using remote communication application service providers (whatsapp/zoom.us/facetime/skype/messanger/google/instagram/facebook/tiktok etc.), whose Privacy Policies and International Data Transfer Principles you accept, and through online voice/video calls made over these applications,

• By sending a direct message to the profile account of PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN on social media accounts (instagram, youtube, tiktok, facebook, twitter, linkedin, etc.) whose servers are located abroad, of which you are already a user and whose Privacy Policies and International Data Transfer Principles you have accepted, or by commenting on the posts,

• By means of the information you transfer by giving automatic permission to process through panels such as “contact us” or “get information” in the promotions and advertisements made by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN on social media accounts (instagram, youtube, facebook, twitter, linkedin, google, etc.) whose servers are located abroad, of which you are already a user and whose Privacy Policies and International Data Transfer Principles you have accepted,

• By closed-circuit security cameras without audio recording capability, installed for the purpose of ensuring workplace security under the legitimate interest of DR. ÇİĞDEM ÜNAL GÜLMEDEN.

Your Personal Data will be collected and processed throughout the examination, medical diagnosis, treatment, operation, and care services, in order for PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN to fully and properly fulfil their contractual and legal obligations, by taking all administrative and technical measures prescribed by KVKK and GDPR.

PURPOSE, METHOD AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
Your Personal Data may be processed by natural or legal persons authorised by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN, acting as “DATA PROCESSOR,” through verbal, written, camera, and photographic recordings, by keeping records in physical and electronic media along with all technical and administrative security measures required by legislation, and, in cases stipulated by the relevant provisions of KVKK and GDPR, by also obtaining your explicit consent.

CIRCUMSTANCES REQUIRING YOUR EXPLICIT CONSENT

Pursuant to Article 6/1(a) of the GDPR and Article 5/1 of the KVKK, your Personal Data may be processed only upon obtaining your explicit consent in the following circumstances:

• Sending SMS and/or emails to you and establishing mobile communication for the purposes of introducing, announcing, and informing about innovations in the medical services provided by DR. ÇİĞDEM ÜNAL GÜLMEDEN will only be possible upon obtaining your explicit consent.
  • Sharing your photographs and/or video recordings taken before, during, and/or after medical procedures for the purpose of observing the progress of treatment on the social media accounts (instagram, youtube, facebook, twitter, linkedin, google, etc.) and corporate websites belonging to DR. ÇİĞDEM ÜNAL GÜLMEDEN will only be possible upon obtaining your explicit consent.
  
• Since sharing your data through service providers whose servers are located abroad constitutes “transfer abroad” and “explicit consent” is required for international data transfers, your explicit consent will be obtained in such cases. However, in the situations listed below, there will be no international transfer performed by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN, meaning YOUR EXPLICIT CONSENT WILL NOT BE REQUESTED by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN, AS YOU WILL HAVE ALREADY GIVEN YOUR EXPLICIT CONSENT TO THE SERVICE PROVIDER YOU USE:
  
• In the event that, by accepting the Privacy Policy and International Data Transfer Principles of the service providers (whatsapp/zoom.us/facetime/skype/messanger/google/instagram/facebook/tiktok etc.) whose servers are located abroad, of which you are already a user, you send written/audio messages and/or photos/videos to PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN or make voice/video calls and thereby request a remote examination/diagnosis service, you will have accepted the policies of said applications and thus, by communicating Personal Data and Special Category Personal Data with PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN through these applications, in line with the KVKK Information Notice and Privacy Principles to be conveyed to you via those applications, you will have given your explicit consent to the applications whose servers are located abroad for your data to be transferred abroad under the policies you previously accepted.
  
• In cases where you wish to be contacted via email service providers whose servers are located abroad (Hotmail, gmail, yahoo, etc.), of which you are already a user, and by accepting their Privacy Policies and International Data Transfer Principles, you will have accepted that DR. ÇİĞDEM ÜNAL GÜLMEDEN processes the Personal Data and Special Category Personal Data shared in the correspondence in line with the KVKK Information Notice and Privacy Principles, and, due to the policies of the said service providers whose servers are abroad that you have previously accepted, you will have given your explicit consent to the email service provider for your data to be transferred abroad.
  
• In cases where you apply via the advertisements and promotions published by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN on social media service providers (facebook, instagram, google, whatsapp etc.) whose servers are located abroad, you will have accepted the Privacy and International Data Transfer Principles of the relevant social media service providers, automatically permitting the processing and transfer abroad of your data, which the relevant social media service provider will then transfer to PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN. Your data will be processed and stored by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN in accordance with the KVKK Information Notice and Privacy Principles to be conveyed to you through the application. In these cases, by accepting PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN’s Information Notice and Privacy Principles, and the processing of your Personal Data and Special Category Personal Data in this manner, including contacting you via the communication details you provided, you will have consented to it.
  
• In the event that you send direct messages to the profile account belonging to PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN on social media accounts (instagram, youtube, facebook, tiktok, twitter, linkedin etc.) whose servers are located abroad, and of which you are already a user by accepting their Privacy Policies and International Data Transfer Principles, you will have accepted that PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN processes your data in line with the KVKK Information Notice and Privacy Principles that will be conveyed to you through the application, and that communication with you can be established via that application.

CASES IN WHICH YOUR DATA MAY BE PROCESSED WITHOUT OBTAINING EXPLICIT CONSENT

• Pursuant to Article 9/2(h) of the GDPR and Article 6/3 of the KVKK;
  In order to conduct examination, medical diagnosis, treatment, operations, and care services, your Health Data, which is classified as Special Category Personal Data, will be processed without obtaining your explicit consent by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN, who is under a legal obligation of confidentiality in accordance with the law.
• Pursuant to Article 6/1(b) of the GDPR and Article 5/2(c) of the KVKK;
  In order to carry out your follow-up examinations after medical diagnosis, treatment, and operations, to manage any complication processes that may arise, to communicate directly with you, and to manage follow-up appointment processes, your Personal Data will be processed without obtaining your explicit consent by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN.
• Pursuant to Article 6/1(f) of the GDPR and Article 5/2(f) of the KVKK, on the basis of our legitimate interests;
  In order to manage legal processes, handle patient satisfaction and request management, and ensure workplace security, your Personal Data will be processed without obtaining your explicit consent by PROF. DR. ÇİĞDEM ÜNAL GÜLMEDEN.