GLOBAL COMPUTER CONTROL SYSTEMS INDUSTRY AND TRADE LIMITED COMPANY IN ACCORDANCE WITH THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA CLARIFICATION TEXT REGARDING ELRA REMOTE HEALTH SERVİCE PLATFORM MEMBERS’ RELATIVES
1. IDENTITY OF THE DATA CONTROLLER
Within the scope of the Law No. 6698 on the Protection of Personal Data (“Law”, “KVKK”), we attach great importance to the security of personal data. Acting as the data controller, Global Computer Control Systems Industry and Trade Limited Company (“Company”) ensures that all personal data of ELRA Health members’ relatives (The term “relative” does not include the member’s children under the age of 18 for whom the member is a parent or legal guardian) are processed in accordance with the Law.
This Clarification Text Regarding ELRA Health Members’ Relatives Pursuant to the Law No. 6698 on the Protection of Personal Data (“Clarification Text”) aims to explain the personal data processing activities, fulfill the disclosure obligation, and ensure transparency.
MERSIS No: 0396005047500010
Website: https://www.gbks.com.tr, https://elrasaglik.com
Phone: +90 (212) 635 96 81
E-mail: kvkkglobal@gbks.com
Address: Vatan Cd. İskender Saray Apt. No:31/5 Fatih / İstanbul
2. PRINCIPLES FOLLOWED IN THE PROCESSING OF PERSONAL DATA
Personal data are processed in accordance with the principles set forth in Article 4 of the Law:
- Lawfulness and fairness,
- Accuracy and being kept up to date when necessary,
- Processing for specific, explicit, and legitimate purposes,
- Being relevant, limited, and proportionate to the purposes of processing,
- Being retained for the period stipulated in the relevant legislation or as required for the purposes for which they are processed.
3. PROCESSED PERSONAL DATA AND LEGAL BASIS
PERSONAL DATA
LEGAL BASIS
Identity Information (Member’s Relative) — Name, Surname, Date of Birth, Turkish ID No, Gender
Article 5/1 – Explicit Consent.
Note: Information on members’ relatives is not mandatory.
Other Information (Member’s Relative) — Height, Weight
Financial Information — Bank Name, IBAN
For the execution of financial and accounting processes related to services received by members’ relatives through the ELRA Health application:
Article 5/2(c): “Processing is necessary for the performance of a contract to which the data subject is a party.”
Article 5/2(ç): “Processing is necessary for compliance with a legal obligation to which the data controller is subject.”
Contact Information (Member’s Relative) — Address
4. PURPOSES OF PROCESSING PERSONAL DATA
Your personal data specified in Section 3 are processed in accordance with the conditions set forth in the Law for the following purposes:
- Execution of remote healthcare service processes,
- Enabling access to services within the scope of the ELRA Online Health application, provision of services, and execution of telehealth activities,
- Execution of medical diagnosis, treatment, and care services,
- Follow-up of requests and complaints,
- Fulfillment of legal obligations,
- Management of communication processes,
- Ensuring compliance with applicable legislation,
- Conducting and following up legal affairs,
- Execution of management activities,
- Execution of storage and archiving activities,
- Providing information to authorized persons, institutions, and organizations.
5. METHOD OF COLLECTING PERSONAL DATA
Your personal data are collected by our Company, either fully or partially automated or as part of any data recording system, through the following channels:
- https://elrasaglik.com website, ELRA Health mobile application,
- Company websites, printed forms, call center, e-mail, telephone, SMS, fax, courier/post,
- Online communication platforms, public internet sources, written, verbal, and electronic communications,
- Company headquarters, Company IT systems, internal integrated systems, and integrated systems with authorized public institutions and private organizations.
6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
Your personal data, as specified in Section 3, may be transferred to third parties within the framework of the purposes specified in Section 4, in accordance with the provisions of the Law and within the limits of necessity:
- E-Nabız / Ministry of Health – For ensuring compliance with legislation and required notifications to public authorities,
- Authorized healthcare institutions – For the execution of medical diagnosis, treatment, and care services within telehealth operations,
- Law firm – For the follow-up and execution of legal affairs,
- Certified public accounting firm – For the follow-up and execution of financial and accounting processes and compliance with legislation,
- Revenue Administration (GİB), Ministry of Finance, SGK, and other authorized public institutions – For ensuring compliance with financial and accounting obligations, legislative compliance, and execution of business activities,
- Invoiced party – For the follow-up and execution of financial and accounting operations, compliance with legislation, execution of contractual processes, and business operations.
7. YOUR RIGHTS UNDER ARTICLE 11 OF THE LAW
Pursuant to Article 11 of the Law, data subjects have the right to:
- Learn whether personal data are processed,
- Request information regarding processed data,
- Learn the purpose of processing and whether it is used accordingly,
- Learn about third parties to whom data are transferred domestically or abroad,
- Request correction of incomplete or inaccurate data,
- Request deletion or destruction of personal data,
- Request notification of correction, deletion, or destruction to third parties to whom data were transferred,
- Object to results arising from automated processing that are to their detriment,
- Request compensation for damages arising from unlawful processing of personal data.
Data subjects may submit their requests to our Company in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller.”
Requests will be evaluated and finalized free of charge within thirty (30) days at the latest. If the process incurs an additional cost, the tariff determined by the Personal Data Protection Board will apply.
Name – Surname:
Date:
Signature: