Your Privacy Matters: Our Policy and Commitments
This Privacy Policy (“Policy”), of TPS Özel Sağlık Turizm Ticaret Ltd. Şti. (referred to as “TurkeyPlasticsurgery.org”), is designed to ensure that our users can utilize our services safely and completely. In this context, we fully comply with the Personal Data Protection Law (Law No. 6698) and all other applicable legislation to inform our users about our data processing practices.
The purpose of this Policy is to outline the terms and conditions governing the use of personal data shared with TurkeyPlasticsurgery.org, which is collected from Platform members/visitors/users and medical centers during the operation of the “www.turkeyplasticsurgery.org” website (the “Platform”) operated by TPS Özel Sağlık Turizm Ticaret Ltd. Şti., and from individuals undergoing treatment (collectively referred to as “data owners”) in Istanbul for their treatment operations.
1. Data to be Processed
Depending on the explicit consent of the data owner, TPS Özel Sağlık Turizm Ticaret Ltd. Şti. may process personal data such as credentials, e-mail address, telephone number, and contact information, which may be required for the performance of services and potential health services through the Platform or in a manual environment, in accordance with the Law and all applicable legislation. The user expressly acknowledges the processing of data they may share with TPS Özel Sağlık Turizm Ticaret Ltd. Şti. in accordance with their own desire for the purposes specified in this Privacy Policy.
Data that is irreversibly anonymized, as per the 3rd and 7th articles of the Law, will not be considered personal data under the provisions of this data, and processing activities related to this data will be carried out without any liability under this Policy.
2. Personal Data Processing Purposes
TPS Özel Sağlık Turizm Ticaret Ltd. Şti. may process the personal data provided by the data owner for the following purposes:
- To enable the data owner to benefit from the services offered through the Platform.
- To carry out membership registration and account creation processes and related Platform operations, including record-keeping if a subscription is involved.
- To detect system errors, monitor performance, and improve the functionality of the Platform.
- To provide maintenance, support, and backup services.
- To enable the utilization of relevant health services provided by our business units and to conduct related business processes.
- To carry out the necessary work by the relevant business units for the execution of health services provided by TPS Özel Sağlık Turizm Ticaret Ltd. Şti. and to manage the related work processes.
- To ensure the legal, technical, and commercial-business security of TPS Özel Sağlık Turizm Ticaret Ltd. Şti. and individuals involved in business relationships.
- To plan and execute the commercial and/or business strategies of TPS Özel Sağlık Turizm Ticaret Ltd. Şti..
With the explicit consent of the data subject, such personal information may be used to communicate with the data owner or to enhance their experience on the Platform, as well as for internal reporting and business development activities. It may also be used to generate various statistical evaluations without revealing your identity, create databases, and conduct market research. Such information may be processed, stored, and transferred to third parties by TPS Özel Sağlık Turizm Ticaret Ltd. Şti. for direct marketing, digital marketing, remarketing, targeting, profiling, and analysis purposes, and you may be contacted for the purpose1 of providing information about the promotion, maintenance, and support activities of various applications, products, and services.
TPS Özel Sağlık Turizm Ticaret Ltd. Şti. may also process and share personal data with third parties without the data owner’s explicit consent in the presence of exceptions stipulated in Articles 5 and 8 of the Law and/or other relevant legislation. These exceptions include: (i) being expressly stipulated in the Law, (ii) being mandatory for the protection of the life or physical integrity of the person or another person, where the data subject is physically incapable of giving their consent or whose consent is not legally valid, (iii) being necessary for the processing of personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of2 the contract (between TPS Özel Sağlık Turizm Ticaret Ltd. Şti. and the data owner), (iv) being mandatory for compliance with a legal obligation to which the data controller is subject, (v) having been made public by the data subject themselves, (vi) being mandatory for the establishment, exercise, or protection of a right, (vii) being mandatory for the legitimate interests pursued by the data controller, provided that this processing does not harm the fundamental rights and freedoms of the data subject.
3. Processing of Special Categories of Personal Data
Your personal health data is considered a special category of personal data under Article 6 of the Law. It may be processed without your explicit consent for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services,3 health services management and planning, and financing.
As TPS Özel Sağlık Turizm Ticaret Ltd. Şti., within the scope of the Data Holder’s explicit consent, we may process your special categories of personal data, including health data, for purposes such as providing better visualization of patients’ treatment processes, improving the health services we offer, maintaining health records, internal medical reports, digital marketing, legal processes, and complaint management. This processing will be carried out in accordance with the Basic Law on Health Services No. 3359, Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated4 Organizations, the Regulation5 on Diagnosis and Treatment of Outpatient Diagnostics, the Regulation on the Processing of Personal Health Data and Ensuring its Privacy, the Regulation on Provisioning, the regulations of the Ministry of Health, the decisions of the Personal Data Protection Board, and other relevant legislation.
4. Transfer of Personal Data
TPS Özel Sağlık Turizm Ticaret Ltd. Şti. may transfer the personal data of the Data Holder and new data obtained through the use of this personal data to third parties with whom the Aesthetic Center collaborates to perform the services provided to the Data Holder, limited to the purposes stated in this Privacy Policy. TPS Özel Sağlık Turizm Ticaret Ltd. Şti. may share this data with third parties such as e-mail and SMS senders, hosting service providers, law offices, research companies, and call centers for the purposes of improving and personalizing the Data Holder’s experience, ensuring the Data Holder’s security, detecting fraudulent or unauthorized use, investigating operational evaluations, correcting errors related to Platform services, and for any of the purposes outlined in this Privacy Policy.
The Data Holder acknowledges and consents in advance that such third parties may store their personal data on servers worldwide, provided that it is limited to the above-mentioned purposes. Personal data may be transferred abroad without the explicit consent of the Data Owner under the terms and conditions specified in Article 9 of the Law.
5. Collection Method and Legal Basis of Personal Data
Personal data is collected electronically through the Platform and physically at our medical centers. The personal data collected for the aforementioned legal reasons can be processed and transferred for the purposes stated in Articles 5 and 6 of Law No. 6698 and this Privacy Policy.
6. Rights of the Personal Data Holder
In accordance with Article 11 of the Law, data holders have the right to: (i) learn whether their personal data has been processed, (ii) request information about their personal data if it has been processed, (iii) learn the purpose of processing personal data and whether it is used in accordance with its purpose, (iv) know the third parties to whom personal data is transferred domestically or abroad, (v) request the rectification of personal data if it is incomplete or inaccurate and to request notification of the transaction made to third parties to whom personal data has been transferred, (vi) request the erasure or destruction of personal data if the reasons for its processing have ceased to exist and to request notification of the transaction made to third parties to whom personal data has been transferred, (vii) object to automated decision-making concerning them if it produces an adverse effect, and (viii) request compensation for damages arising from the unlawful processing of personal data.
Requests for the exercise of these rights shall be submitted by the personal data holders6 in person, through a notary public, or via registered mail to [email protected], or in writing to the applicant’s e-mail address registered with TPS Özel Sağlık Turizm Ticaret Ltd. Şti. and to the TPS Özel Sağlık Turizm Ticaret Ltd. Şti.’s e-mail address. TPS Özel Sağlık Turizm Ticaret Ltd. Şti. will finalize these requests within thirty days. TPS Özel Sağlık Turizm Ticaret Ltd. Şti. reserves the right to charge a fee based on the tariff (if any) determined by the Personal Data Protection Board regarding7 such requests.
The Data Holder acknowledges and undertakes that the information they provide subject to this Privacy Policy is complete, accurate, and up-to-date, and that they will update it immediately in case of any changes. Otherwise, TPS Özel Sağlık Turizm Ticaret Ltd. Şti. shall not be held responsible for any damages.
7. Storage Period for Personal Data
TPS Özel Sağlık Turizm Ticaret Ltd. Şti. will retain the personal data provided by the Data Holder for the duration necessary to fulfill the obligations arising from the nature of the services provided and the treatment period. Additionally, TPS Özel Sağlık Turizm Ticaret Ltd. Şti. may store personal data for the duration of the statutory limitation periods in the event of any disputes that may arise between the Data Holder and TPS Özel Sağlık Turizm Ticaret Ltd. Şti., for the purpose of carrying out the necessary defense within the scope of the dispute and in accordance with the relevant legislation.
8. Changes to the Privacy Policy
Beneficiaries of the services offered on the Platform and the health services in our medical centers are deemed to have read and accepted these conditions. This Privacy Policy may be updated without prior notice to Data Owners to comply with changing conditions and regulations.
