THE CLARIFICATION TEXT REGARDING ELRA MEMBERSHIP PROCESSES PURSUANT TO THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA
1. IDENTITY OF THE DATA CONTROLLER
In accordance with the Law No. 6698 on the Protection of Personal Data (“Law”, “KVKK”), Global Computer Control Systems Industry and Trade Limited Company (“Company”) attaches great importance to the security of personal data and, as the data controller, takes all necessary care to ensure that all personal data of ELRA Health members are processed in compliance with the Law.
The Clarıfıcatıon Text Regardıng Elra Health Membershıp Processes Pursuant To The Law No. 6698 On The Protectıon Of Personal Data (“Clarification Text”), has been prepared by the Company in order to fulfill its obligation to inform data subjects under the Law, secondary regulations, and the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform.
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 APPLIED IN THE PROCESSING OF PERSONAL DATA
In processing personal data, the Company adheres to the principles set forth in Article 4 of the Law:
- Being processed lawfully and in good faith,
- Being accurate and, where necessary, up-to-date,
- Being processed for specific, explicit, and legitimate purposes,
- Being relevant, limited, and proportionate to the purpose of processing,
- Being retained for the period stipulated in the relevant legislation or as required for the purpose for which they are processed.
3. PERSONAL DATA PROCESSED AND LEGAL BASIS
Category of Personal Data
Legal Basis for Processing
Identity Information
(Name, Surname)
KVKK Art. 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.”
Contact Information
(Phone, E-mail)
KVKK Art. 5/2(c): Same as above.
For commercial electronic communication: KVKK Art. 5/1 — “Explicit consent.”
Other Information
(Corporate Code for institutional registrations)
KVKK Art. 5/2(c): “Necessary for the performance of a contract.”
KVKK Art. 5/2(e): “Processing is mandatory for the establishment, exercise, or protection of a right.”
4. PURPOSES OF PROCESSING PERSONAL DATA
Your personal data listed in Section 3 are processed in accordance with the conditions for processing personal data specified in the KVKK for the following purposes:
- Conducting remote healthcare service processes,
- Managing ELRA Online Health membership processes and creating user accounts,
- Conducting medical diagnosis, treatment, and care services,
- Handling requests and complaints,
- Fulfilling legal obligations,
- Managing communication processes,
- Conducting post-membership support processes,
- Ensuring compliance with legal regulations,
- Managing finance and accounting operations,
- Conducting and following up legal processes,
- Managing business operations and audits,
- Managing contractual processes,
- Conducting administrative and management activities,
- Managing retention 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 wholly or partially automated, or through non-automated means provided that they are part of a data recording system, via the following channels:
- https://elrasaglik.com website,
- ELRA Health application,
- Electronic media (Company websites, online forms),
- Printed forms, call center, e-mail, phone, SMS, fax, courier/post, online meeting platforms,
- Publicly available internet sources, written, verbal, and electronic communications,
- Company headquarters, information technology systems, internal integrated systems,
- Integrated systems with authorized public institutions and private organizations.
6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
Your personal data processed as specified in Section 3 may be transferred, to the extent necessary and proportionate, for the purposes listed in Section 4 and under the conditions set forth in the KVKK, to the following parties:
- E-Nabız / Ministry of Health
Purpose: To ensure compliance with legal obligations and reporting to authorized public institutions as required by law.
- Relevant healthcare institutions providing remote health services
Purpose: To perform medical diagnosis, treatment, and care services within the scope of remote healthcare services.
- External legal counsel / law firm
Purpose: To follow up and manage legal processes, when necessary.
- Commercial communication service providers (for members who have provided explicit consent for commercial messages)
Purpose: To send commercial electronic communications (SMS or e-mail) according to the member’s consented communication channel(s).
7. YOUR RIGHTS UNDER ARTICLE 11 OF THE KVKK
Pursuant to Article 11 of the KVKK, data subjects have the right to:
- Learn whether personal data are processed,
- Request information regarding processed data,
- Learn the purpose of processing and whether they are used accordingly,
- Know third parties to whom data are transferred domestically or abroad,
- Request correction of incomplete or inaccurate data,
- Request deletion or destruction of data,
- Request notification of correction, deletion, or destruction to third parties,
- Object to the occurrence of a result to their detriment through automated data analysis,
- Request compensation for damages arising from unlawful processing.
Data subjects may submit their requests regarding these rights to our Company in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller.
Requests will be evaluated and concluded as soon as possible and within 30 days at the latest, free of charge. If the process requires an additional cost, the fee determined by the Personal Data Protection Board will apply.
Name – Surname:
Date:
Signature: