PRIVATE PALZ HOME CARE (PALZ HEALTH LIMITED COMPANY) CLARIFICATION TEXT REGARDING REMOTE HEALTHCARE SERVICES PROCESSES UNDER THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA
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. As Private Palz Home Care (Palz Health Limited Company), acting as the data controller, we show the utmost sensitivity to ensure that all kinds of personal data are processed in compliance with the Law during our remote healthcare activities.
This Clarification Text Regarding Members’ Relatives Pursuant to the Law No. 6698 on the Protection of Personal Data (“Clarification Text”) has been prepared in accordance with the Law and its secondary regulations.
- MERSIS No: 0720111921600001
- Website: palzsaglik.com
- Phone Number: 444 15 80
- E-Mail Address: info@palzhealth.com
- Address: Küçük Çamlıca Mah. Çilehane Yolu Cad. A Blok No: 21a Üsküdar / İstanbul, Türkiye
2. PRINCIPLES OBSERVED IN THE PROCESSING OF PERSONAL DATA
The following principles set out in Article 4 of the Law are observed in the processing of personal data:
- Compliance with the law and the rules of good faith,
- Being accurate and up-to-date when necessary,
- Being processed for specific, explicit, and legitimate purposes,
- Being relevant, limited, and proportionate to the purposes for which they are processed,
- Being retained for the period prescribed by relevant legislation or as required by the purpose for which they are processed.
3. PERSONAL DATA PROCESSED AND LEGAL BASIS
Identity Information
(Name, Surname, Turkish ID Number, Passport Number, Foreign ID Number, Date of Birth, Age, Citizenship, Gender)
➡ Law No. 6698, Article 5/2(c): “Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.”
➡ Law No. 6698, Article 5/2(ç): “Processing is necessary for the data controller to fulfill its legal obligation.”
Visual Information
(Photograph)
➡ Law No. 6698, Article 5/2(c): As above
➡ Law No. 6698, Article 5/2(ç): As above
Contact Information
(Phone Number, E-mail, Province, District, Postal Code, Address, Province/District information where the patient receiving remote healthcare connects to the USBS system)
➡ Law No. 6698, Article 5/2(c): “Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.”
➡ Law No. 6698, Article 5/2(ç): “Processing is necessary for the data controller to fulfill its legal obligation.”
Health Information
(Examination Information, Prescription Information, E-Prescription Code, Health Information)
➡ Law No. 6698, Article 6/3(e): “Processing by persons or authorized institutions and organizations under an obligation of confidentiality for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and the planning, management, and financing of healthcare services.”
Customer Transaction Information
(Duration of consultation, Consultation ID Number, Fee, Consulting Doctor, Consultation Status (active/passive), Appointment Time, Request Time, Previous Consultations, Applied Segmentation – Corporate Agreement)
➡ Law No. 6698, Article 5/2(c): As above
➡ Law No. 6698, Article 5/2(ç): As above
Financial and Accounting Information
(Invoice Number, Invoice Date, Fee)
➡ Law No. 6698, Article 5/2(c): As above
➡ Law No. 6698, Article 5/2(ç): As above
Visual and Audio Information
(Sound and Image, Photograph)
Within the scope of remote healthcare services, during the provision of such services, the image and voice of the person receiving healthcare may be accessed instantaneously; however, no image or audio recording is made. Accessing the image and voice of the person during the healthcare service is based on:
➡ Law No. 6698, Article 5/2(c): As above
➡ Law No. 6698, Article 5/2(ç): As above
The data are not transferred.
Other Information
(Organization Code for Corporate Records)
➡ Law No. 6698, Article 5/2(c): As above
➡ Law No. 6698, Article 5/2(e): “Processing is necessary for the establishment, exercise, or protection of a right.”
Other Information
(Height, Weight)
➡ Law No. 6698, Article 5/2(c): As above
➡ Law No. 6698, Article 5/2(ç): As above
4. PURPOSES OF PROCESSING PERSONAL DATA
The personal data specified in section 3 are processed within the scope of the personal data processing conditions set out in the Law, for the following purposes:
- Execution of remote healthcare service processes,
- Providing access to and delivery of services within the scope of remote healthcare,
- Conducting medical diagnosis, treatment, and care services,
- Following up on requests and complaints,
- Fulfillment of legal obligations,
- Managing communication processes,
- Ensuring compliance of activities with legislation,
- Carrying out financial and accounting processes,
- Managing legal affairs,
- Managing and auditing business operations,
- Executing contract processes,
- Managing administrative processes,
- Carrying out archiving and storage activities,
- Providing information to authorized persons, institutions, and organizations.
5. METHOD OF COLLECTING PERSONAL DATA
Your personal data are collected, fully or partially automatically, or through non-automated means provided they are part of a data recording system, via the following channels:
- https://elrasaglik.com/ website,
- ELRA Health application,
- Printed forms,
- Call center,
- E-mail, phone, SMS, fax, courier/post,
- Online meeting platforms,
- Public internet sources,
- Written, verbal, and electronic notifications,
- The company headquarters, IT systems, internal integrated systems, and integrated systems shared with authorized public institutions and private organizations.
6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
Your personal data specified in section 3 may be transferred, limited to what is necessary and proportionate, for the purposes stated in section 4 and in compliance with the conditions set forth in the Law, to the following parties:
- Law firm providing legal services (Purpose: Managing legal affairs when necessary),
- Financial advisor/accounting service provider (Purpose: Managing financial and accounting processes, ensuring compliance with legislation),
- Public institutions such as SGK, District Health Directorate, Revenue Administration, Ministry of Finance, and other competent public authorities (Purpose: Managing financial, medical, and operational processes, ensuring compliance with legislation),
- Software company providing USBS services (Purpose: Managing remote healthcare and operational processes in compliance with regulations),
- Invoiced parties (Purpose: Managing financial, contractual, and operational processes),
- Contracted institutions with allocated institution codes (Purpose: Managing contract and operational processes).
7. YOUR RIGHTS UNDER ARTICLE 11 OF THE KVKK
Pursuant to Article 11 of the KVKK, data subjects have the following rights:
- To learn whether personal data are being processed,
- To request information regarding such processing,
- To learn the purpose of processing and whether they are used in accordance with their purpose,
- To learn the third parties to whom personal data are transferred domestically or abroad,
- To request the correction of incomplete or inaccurate personal data,
- To request the deletion or destruction of personal data,
- To request notification of correction, deletion, or destruction to third parties to whom personal data have been transferred,
- To object to the occurrence of any result to their detriment by means of analysis of personal data exclusively through automated systems,
- To demand compensation for damages arising from unlawful processing of personal data.
Data subjects may submit their requests to the Company in accordance with the Communiqué on the Principles and Procedures for Application to the Data Controller.
Requests will be evaluated and concluded as soon as possible and no later than thirty (30) days, free of charge. However, if the process requires additional cost, the fee set by the Personal Data Protection Board will apply.
Name – Surname:
Date:
Signature: